ML20059H372

Amend to Petition for Leave to Intervene.* Expresses Appreciation for ASLB Consideration in Scheduling Prehearing Conference & Suppls 900723 Petition by Showing That Intervenor Has Standing to Intervene Through Membership

ML20059H372
Person / Time
Site:	Vogtle
Issue date:	09/12/1990
From:	Carroll G GEORGIANS AGAINST NUCLEAR ENERGY
To:	Atomic Safety and Licensing Board Panel
References
CON-#390-10817 90-617-03-OLA, 90-617-3-OLA, OLA, NUDOCS 9009170133
Download: ML20059H372 (11)

Text

. lbal1 UNITED STATES OF AMERICA gg;tp NUCLEAR REGULATORY COMMISSION usHRC ATOMIC SAFETY AND LICENSING BOARD

$0 EP 12 b9544 Before Administra tive Judges:

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Charles Bechhoefer. Chairman Niickf 6HG 'a 'd"Y"A Dr. James H. Carpenter HGkCh Dr . Emme th A. Luebke In the Matter of Docket Nos. 50-424-OLA 50-425-OLA GEORGIA POWER CO., et al. ASLDP No. 90-617-03-OLA (Vogtle Electric Genera _ing

, Plant, Units 1 and 2)

Facility Operating Licenses NPF-68 and NPF-81 AMENDMENT TO PETITION FOR LEAVE TO INTERVENE GANE apprecia tes the considera tion of the Atomic . Safe ty and Licensing Board in scheduling a prehearing conference. GANE supplemen ts its July 23 Petition by showing the following -

1. GANE has standing to intervene based on the attached 1 affidavit of Mr. Frederick Points.

2. GANE has standing to in:ervene through its membership.

In par ticular, Fred Points, a GANE member in isod standing, has authorized GANE to represent him and his in teres ts in this-proceeding.

Mr. Points is a homeowner who resides within 45 miles of Plant Vogtle. He is threatened with injury to his health and proper ty in the event the proposed appilcation is not as safe as f

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Georgia Power (Applican:) con tends . If the bypass permits the diesel generator :o overheac and stop functloning during an emergency, off-site damages can be reasonably expected. Mr . Po in ts lives close enough to Plant Vog tle to suffer real injury from the

-- failure of the emergency genera tor .

3. The GANE of ficers have demons tra ted tha t Glenn Carroll has authority to represent GANE in this proceeding. See affidavits of Carol Stangler and Ca te Morrill.

4. GANE desires a hearing to fully air the issues raised by Georgia Power's applica: ion to oypass the high jacket wa te r

emper a ture trip.

5. GANE has attached its e igh t con ten t ions regarding the Georgia Power application.

Respectfully yours,

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yg-Gle$n Carroll for a, Georgians Against Nuclear Energy

i UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD v Before Administrative Judges:

Charles Bechhoefer, Chairman Dr. James H. Carpenter Dr. Emmeth A. Luebke

~~

Docket Nos. 50-4 24-OLA In the Ma tter of 50-425-OLA et al. ASLDP No. 90-617-03-OLA GEORGI A POWER lVogtle Electr CO. , ic Genera ting Plant, Units 1 and 21 Facility Opera ting Licenses NPF-68 and NPF-81 AFFIDAVIT Comes now FREDERICK POINTS, who being duly sworn, deposes and states as follows:

1. I am a member in good standing of Georgians Against Nuclear Energy lGANEl. I authorize GANE to represent me and my interests in the above proceeding involving Georgia' Power's request

o bypass the high jacket water temperature switch on The backup generator. More specift ally I_ authorize Ms. Glenn Carroll or anyone she designates to represent me and my interests.

2. I reside at 3216 Sycamore Drive, Augusta, Georgia 30909.

I am buying my home in which I have lived there for /2 years.

I own substantial household goods. IJbelieve my health, home and  ;

property are jeopardized by Georgia Power's requested changes.

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3. I reside within 45 miles of Plant Vogtle. In the event of the failure of the backup generator during an emergency at Plant Vog tle, a more serious accident than occurred on March 20, 1990 may transpire. -My personal health would suffer serious consequences.

The value of my property will decline.

4. I have read GANE's 7/23/90 Petition for Leave to Intervene. If GANE's position is upheld, there is a reduced

. likelihood of serious accident'at Plant Vogtle: Plant Vogtle will be safer. I am less likely to suffer injury from it.

THIS STATEMENT IS MADE UNDER PENALTIES OF PERJURY.

hAOelkrtI HA FREDERICK POINTS

-4 UNITED STATES OF. AMERICA NUCLEAP REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Charles Bechhoefer. Chairman-Dr. James H. Carpenter Dr. Emmeth A. Luebke 1

Docket Nos. 50-424-OLA In the Matter of 50-425-OLA GEORGIA POWER CO., et al. ASLBP No. 90-617-03-OLA (Vogtle ElectrTc Generating Plant, Units 1 and 2)

Facility Operating Licenses NPF-68 and NPF-81 AFFIDAVIT I am a duly elected officer of Georgians Against Nuclear-Energy (GANE). I am personally aware of the' 7/23/90 petition for leave to intervene in the above-styled matter- filed by Glenn Carroll on behalf of GANE. Glenn is a Co-Coordinator of GANE.

GANE supports and directs her to continue this. intervention on our behalf. GANE has authorized her to do so, and to obtain the assistance of whatever experts as she deems appreoriate.

This statement is made under penalties of perjury.

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W bli LLLLP' Cate Morrill, Secretary

/ f?0 Date

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ]

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: i

' Charles Bechhoefer, Chairman  ;

_. Dr. James H. Carpenter Dr. Emmeth A. Luebke Docks' Nos. 50-424-OLA In the Matter of 50-425-OLA '

, GEORGIA POWER CO., et al. ASLBP No. 90-617-03-OLA (Vogtle Electric Generating Plant, Units 1 and 2)

Facility Operating Licenses NPF-68 and NPF AFFIDAVIT I am a duly elected officer of Georgians Against Nuclear Energy (GANE). I am personally aware of the~7/23/90 petition for leave to intervene in the above-styled matter filed by Glenn Carroll on behalf of GANE. Glenn is a Co-Coordinator of GANE.

GANE supports and directs her to continue 'this intervention on our behalf. GANE has ' authorized her to do so, and to obtain the assistance of whatever experts as she. deems appropriate.

This statement is made under penalties of perjury.

, b4d f Carol Stangler, Co-Coordin tor

~ /~ 90 Date Stang lev /

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GANE Contentions

1. GANE contends the high jacket wa te r tempera tu r e trip should not be bypassed during emergency star ts because it involves a significant hazard. The switch is designed to prevent the generator engine from overheating during an emergency. The Applicant's evaluation (enclosure 2, 4 with its May 25 letter to the NRC) does not explain what will aler t the erator to potential overheating.

2. We believe the high jacket water temperature trip of the T.D.I. diesel gene ra tor in Plant Vogtle is designed by the manuf acturer not to be bypassed.

a. We expect TDI has reason for said trip, and we contend the Appilcant has not shown a reasonable basis to change the device.

b. We contend it is safer to have this essential trip operate automatically so as to eliminate the possibility of operator error,

c. We wonder what additional operating procedures and training, the Applicant is planning to c ovide to its personnel to prevent or respond to over-heating during emergency.

I (d) " Plant operating experience" (See Enclosure 1 of the May 25 letter to the NRC) suggests the Applicant-has had difficulties getting the jacket water high temperature sensor .to function (See

" Loss of Vital AC Power and the Residual Heat Removal System During ,

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Mid-Loop Operations at Vogtle Uni: 1 on March 20, 1990", h3 REG 1410, Appendix I) . We contend that rather than bypass the switch.

he Applicant must demons tra te the reason the sensor " spuriously

rips", and correct the f ailing (s) .

(e) If the Applic.an c can demons tra te the sensor can safely be bypassed, we con tend tha t the Applicant must provide reasonable assurances that the generator will not overheat in an emergancy, w i thou t some warning to the operator.

( f ) We do no t understand how the Applicant will be forewarned of :he generator overheating, other than by the ultimate failure of the generator. We contend the Applicant's " evaluation" is inadequate because it falls-to provide such an analysis (g) We contend the proposed bypass is unsafe because it does not provide au toma t ic indication and prevention of emergency generator overhea ting.

3. GANE agrees that a reliable diesel generator makes for a safer nuclear plant. Georgia Power proposes that to increase :he

r el iab ili ty " of the diesel generator it is necessary to bypass the manufacturer's trip on high jacket wa ter temperature. GANE agrees :his bypass will permit ' che genera tor to run with les." risk of shutting down as Georgia Power states now occurs.

However. GANE contends reliability will be decreased since the diesel generator can overheat wi thou t the automatic trip. The results of the generator overheating during an emergency would cause an impermissible power station black-out which could lead to a meltdown.  ;

4. GANE con tends the application for amended 1icense is defective in at least two regards. The application does not explain who "de te rmined " tha t the trip on the high jacket water l

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empera ture "should" be bypassed during . an emergency s tar t (see Enclosure 2 4 of the 5/25/90 letter :o the NRC ) ., Also, Georgia Power does not explain what empirical data was the basis for this determination.

5. GANE contends there is no automa tic redundancy provided for the high jacket water tempera ture trip a t Plant Vog tle. GANE contends th is is inadequate and does not address the po ten tial problem that the generator engine may overhea t.

6. GANE contends that Enclosure No. 2 of the Appilcant's May 25 letter to the NRC is inadequate. A full analysis of_ the generator in question must be undertaken before Georgia Power may be permitted to bypass a safety device tha t the generator's designers and manuf acturer included on the specific model used at Plan t Vog tie.

7. On November 25, 1985, the Atomic Safety and Licensing Board of the NRC (Docket No. 50-4240L and 50-4250L) held as follows:

"The Board concludes that Applicants have under taken a well-considered, in-dep th approach to qualifying their TDI EDGs for reliable nuclear service at the VEGP. The Board fur ther concludes the program provides reasonable assurance that the emergency diesel l

l generators manufactured by TDI to be used at Plant Vog tle will provide a reliable dependent source of onsite power as required by 10 CFR Part 50 App. A, General Design Criteria 1 and 17. Whereas evidence of the ultimate success of Applicants' effor ts must await the results of preoperational testing of the VEGP EDGs, we find no basis at this time to challenge the likelihood of that success."

(Memorandum and Order p. 6).

As yet the Applicant has not provided to GANE reasonable assurance tha t the emergency diesel generator will function i i

reliably. The Applicant's pre-operational testing d id not j i

an tic ipa te the cr itical f ailures that occurred on March 20, 1990. i I

GANE contends the Applicant must provide reasonable assurance  ;

by either operational testing, a more complete evaluation (than enclosure 2 to the Applicant's May 25 letter to the NRC) , or other evidence that the Applicant's proposed mod if ica t ion to the high jacket water temperature trip will permit the generator to function reliably in an emergency.

8. All of the par ties to this proceeding are well aware of the myriad design flaws with the TDI generator line and the general '

unreliability of the TDI generator does provide a background basic for our contention that there is a real possibility that must ' be exploted that failure of the TDI generator may occur if the high jacket water temperature switch is bypassed. This situation could leave Plant Vog tle comple tely withou t power to its nuclear safe ty systems. GANE contends that until the ques tion of why the TDI s r generators a t- ' Flan t . Vog ele are unreliable is resolved --tha t the -

. t Applicant is- not :in _ compliance with the conditions- of its-license =

to opera te Nuclear Plant _Vog tie., GANE con tends the Applicant must=

not- opera te the power plants at Vogt1e until such time 'as _. these j

s serious safety questions are resolved.

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