ML20083L222
| ML20083L222 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/11/1984 |
| From: | Feig D GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8404170183 | |
| Download: ML20083L222 (35) | |
Text
b")J e.
UNITED STATES OF AMERICA Dec g NUCLEAR REGUUGOIU COMMISSION US BEFORE '1HE NICMIC SAFEIY AND LICENSIq$g B06RD.
? ~ n 16 & ,Q In the Matter of )
GEORGIA PCAER CDMPANY ) Dodt ,nd 50-425 et al. ) RANCH
)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
SUPPLEMENT 'IO PETITION EOR IEAVE TO INTERVENE AND REQUEST FOR HEARING~
Georgians Against Nuclear Energy Pursuant to an Order dated March 9,1984 of the Atomic Safety and Licensing i
Board in the above-captioned proceeding Georgians Against Nuclear Energy (GANE) hereby submits the supplenent to its Request for Hearing and Petition for Imave to Intervene filed January 27,1984. 'Ihe contentions which GANE seeks to have admitted in this proceeding are as follows:
GANS la f
1 Petitioner contends that the applicant has not adequately nor correctly mamanaM the potential releases of radionucleides from Plant Vogtle during normal transient and accident conditions, nor the somatic, terategenic and genetic effects of the ionizing radiation. Applicant thus fails to meet 2e requirements of 10 CFR 50.34, 50.36, 20.103, 20.203 and Appendix I of Part 50, and, further, underestimmten the human cost of the project in the cost-benefit analysis required by 10 CFR 51.21, 51.20(b) and (c) and 51.23(a).
Applicant has failed to quantify, to the gret. test extent possible, the facters considered in calo21ating the environmental offects of the project as required by 10 CFR 51.20(b). 'Ihe Applicant has failed to consider the existing radiological burden people residing in the area. It is well decuranted that the of facts of exposure to low levels of radiation are cumulative (Gof. nan, J., Radiation _ and Human Health, 1981, p. 47) routine or accidental radion tive emissions from Plant Vogtle will be added to those of the Savannah River Plant (SRP) ten miles across the Savannah 1
0404170103 040411 TDR ADOCK 05000 2 p]
River. 'Ihis section fails to discuss the results of studies on releases at the SRP (Atlanta Journal-Constitution, Sept. 12, 1982, p. lA). 'Ihe addition of releases frm Plant Vogtle must be calculated in balancing the environmental effects of the facility.
'Ibe petitioner further contends that in estimating maxinum exposure levels frm various radioactive substances (FSAR, Table 11.2.3-4), the Applicant has failed to include doses to whid pregnant or lactating women would be exposed and projected effects from such doses. Gofman (1971) has found that at crucial points in embryonic development, entire organ synptons can be damaged bf exposure to radiation (Gofman, J., Poisoned Power,1971, p. 58). Evidence indicates that embryos are 50 tines nore susceptible to leukemia or other cancers, when exposed to radiation (Ibid., p. 57) Nursing infants are subjected to similar risks, which are not adequately assessed in the ER in violation of 10 CFR 20.104.
Petitioner contends that the Applicant has failed to thoroughly assess the risk from routine and accidental radioactive releases on the food chain in its assessment of recreation activities (VEGP-OMER-2,2.1-8 and VEGP-FSAR-2,2.1.3-2) in violation of 10 CFR 20.106 (radioactive effluents to unrestricted areas).
Cesim-137, a major by-product of uranium fission, will be released into the Savannah River mixed with waste water. 'Ibe Applicant has estimated the number of fish fou'nd in stretches of the river proximate to the nuclear plant (OMER-2, Table 2.1-48,49) and has studied the recreational fishing patterns in the area. Fish readily absorb the radioactive isotope cesium and concentrate it in amounts 1,000 l tines that found in the water (Ibid., p. 54). An ach21t man consuming two pounds of fish per, year from this stretch of the Savannah River is exposed to cesium-137 levels in excess of the maxinum annual allowable amounts (Ibid., p.140) in i
violation of 10 CFR 20.106.
Airborne assium also poses hunan health dangers via the food chain. As airborne 2
i .
j l
j particles travel and eventually land on pastureland, they are absorbed by grazing l cows. The applicant has already determined that the nearest milk cows are only five l l miles southwest of the proposed plants (FSAR,11.3.3-4). Connercial milk production i I
from such a site poses significant health risks not assessed by applicant. Based on l
- i
- an accidental release of radioiodine frem SRP over a five day period in 1961, the ;
f calculated amount of rd Nine found in the cows' milk in the area was nearly the !
mari== ingestable amount of radiciodine permissable for a child for an entire year f (Atlanta Journal-Constitution, Sept. 12,1982, p. 22A) . l 4 :
GANE 2 l Petitioner contends that the Applicant has failed to assess the envirornental l
! and public health effects of the addition of Plant Vogtle within 20 miles of the SRP l 1
l and to quantify this factor in its consideration in violation 10 cm 20.103, 50.34(a)(4), 51.21, 51.23(b), 104, 105, 106, and 201. ,
i The Savannah River Plant has produced radioactive weapons materials for 32 t as '
l years. The emissions of large quantities of bath planned as well/ unplanned radionucleides into the atmosphere as well asthe water in the area is well- i l
(
) documented. Officials of the states of Georgia and South Carolina have repeatedly l i
l j expressed their concerns over the grave impact that this facility has been and is j
] l currently having on the overall environment of this area. Governor Joe Frank Harris I
{ as well as former Georgia Governors Busbee and Carter have stated that no more nuclear facilities, including Plant Vogtle, should be allowed to operate in the !
vicinity of the Sevennah River Plant until a study of the cumulative impacts of
- releases of radioactive offluents from the Sevennah River Plant is undertaken.
l DOE plans to rev the aging L-reactor at SRP in order to increase the l 1 pr W im of plutonium and tritium for our nuclear defense programs. A federal I i i judge has ordered uoE to perform an Environmental Impact Statement addressing the
'l {
) offact that the plant would have on the air, water, and living species around the i .
i facility. The folicwing are responses to the Draft Environmental Impact Statement i 3
u
(DEIS) by experts in related fields:
Yaron M. Sternberg, Ph.D. , Civil Engineering, University of Maryland, states that:
A serious flaw in the Draft EIS is the lack of hydrogeological data for the imediate vicinity of the L-reactor.. 2e DEIS suggests that the geological and hydrogeological conditions at the L-reactor site are similar to those in the F and H areas (Chemical Processing areas). HcNever, there are no data to substantiate this claim.. 2e conclusion that can be drawn based on the data presented is that only sparse data are available for the L-reactor area. We Final EIS nust include aufficient data to dilineate in detail the geology and the groundwater regine at the site and should explain variations, if any, between previous and present grcundwater conditions. Because the Escaloosa aquifer is an inportant source of wate , a detailed investigation of this information is essential particularly in view of the fact tnat in one area this 41uifer has already been contaminated...Large volumes of liquids containing nonradioactive waste have been discharged to the F and H seepage basins since 1954 and 1955, respectfully. So groundwater is contaminated to a reported 20 neters throughout most of the distance between the basins and soepage springs.
De contamination consists of radioactive elenents, mercury, and nitrate. The DEIS provides little monitoring data and no information is given on wnether remedial action is proposed and, if so, what is the status of the investigaiton. Serious contamination has been detected in the vicinity of M-1rea and significant concentrations of organics have been detected in the soils at a depth of about 200 feet. ..It should te pointed out that these estimates, given in the DEIS, are preliminary, and the total weignt may be significantly larger.
Based on the above docanented contamination, it is obvious that adding wate to the F, H, t. M areas as a result of the startup of the L-iteactor would contribute to further contamination and aggravation of the problem. S e above areas should not receive any additional waste loads. Instead, remedial neasures should be taken to restore the quality of the groundwater.
Furthernere, seepage basins should not be used anywhere at the SRP for the disposal of any hazardous material because such activity poses a potential serious health hazard to the users of the groundwater." (Se L-Reactor Controversy: Connunts on the Draft EIS, published oy the Natural Resources Defense Council, Winter 1983) to South Carolina Water Resources Conmission states that although the Draft EIS says that local water levels at punging wells are not expected to continue to decline appreciably, "they have been declining since about 1978 and with incicased punpage both in and peripheral to the plant site, they could continue to decline."
(Se L-Beactor Controversy: Conments on the Draft EIG)
According to the U.S. Department of Interior, "We cperation of the L-Beactor pasos unclear risks to groun&ater and tae preferred alternative (direct discharge of cooling water to Steel Creek and the use of seepage basis for waste disposal) 4
will han significant and unsatisfactory effects on fish and wildlife resources including their habitat." (to L-Beactor Controversy 4 coments on the Draf t EIS) l l
2e U.S. Environnental Protection Agency says that the DCIS fails to address the inpact on the groundwater system from the increases in of fluenct and v.ute volumes whidi will be generated at the supporting facilities when the L-Beactor restarts. Se report states that "at the M area, severo contamination in the upr aquifer poses an iminent tnreat to a deeper atuifer that supplies drinking water to plant errployees and off-site cermunities." Concerning the Low !avel wsate Burial Ground, it adds, '"Ihe present practico of disposing of is level radioactive waste, in corbination with chemcial vsato, into tronenes in the ground does not represent state of the art tecnnology and may violato PClw requirements. To increase the l volumo of waste which nust be handled by this facility before the decomissioning plan has been dowloped, is cut of lo;ical phasing. Practically speaking, SPP needs to dowlop a prcper disposal facility to nandle the present volumes of waste mterials before any additinal waste is generated." (Supra)
Concerning the L-Anactor seepage basin, the EPA statuas "Inpacto on the groundwater system from the discnarge of contaminated water from the disasse:toly l basis to a soepage basin located near L-Peactor haw been discussed in the DCIS.
Westo water disenarged to this basin is primarily contaminated with radionuclides which contaminate the upper atuifer and owntually disenarge to Syeel Creek.
Alternatiws to seepage basin disposal were discussed in the DCIS with the l sutmoquent conclusion that seepage basin disgosal is the preferred altamatin. /w stated before, seepage basins oc not represent state of the art disposal tecnnoloJy and nmy violate Ice reluirements." (Supra)
Dr. Sternberg states on the sana subjects "although the DCIS states tnat present and future contananation of the shallow groun@ater between the L-Reactor area seepape bcsin and Steel Creek is e@vcted (trititen and strontium-90), no monitoring data is available...A detailed quantitative analysis of tne present 5
O contamination in the vicinity of the L-leactor should to addressed in the final EIS." (Supra)
Concerning the f act that cooling water discharges into Syeel Creek will remobilize radioactiw eweium detosited downstream fern the telwactor during
~
previous cperations, Charles T. Hess, Pn.D., Copartnwnt of Fnysics, Uniwesity of Maine stAtas, "most of the swaglands vp to 7 miles downstream from the plant reje l fron 42 670 (milli ves per year) for constant exposure.. 670 milliram/ year own exceek the DDR reswiction os. scotasible areas near defense plants, a fact whien is not stated in tne DCIS. T.em loyils oxceed tne 25 meen/yr. limit for radiation e,<vauro to thu p6Mw for outside the fonce of a comercial nuclear pawor I reacter. . .fortunatw1/ them arow are not gpulated 100n by the people using them."
(Supra) ,
Concerning the fxt t9: on;e the Irltinctor is reactivated and thir. cesium will ts tidshed i'sto the Savanrwh Riwe, cc. Javi M. Croan, Quantitatin Applications, Envivonnental and tkatistical Gcierwes states: " Analysis of data enployed in the DCIS for the 1,&setor to enhoto parararwrs (M the mWel to assess renoullizaticm of rdwesiwn and rMiococalt) denenstrates that (1) data tre insufficient to sinst ovwater cilwlat.ierw, or (2) altornattw calculations t7sulting in iruch hupswr inpact estintor, are as defensible as mipset estimates
! prem nt in the DCIS. M a result, I haw no confidencg in Ot!S conclusions concerniry meawnt of te dw,ocWes apt in 1: teel Creer into the Savannah Riwr.
A6perantly dita do tot exin frun which tectonucliS memnt can to estimated. In atmence of suen inturutton with whir.n 1qects to hivun health can tm estimted, cooling water tron !,-Tav;tt.c should not tas 11amarged into Steel Creenk." (Supra) l With re)4rds to the batety of tin telwactoe alone, Dr. Frank von Ilipiel of the Center toe Energy arti Enytrorwantal ht.klime at Pcinceton Uniwrsity states "...the irt's risk ansessment should fews prinalpally m the degree of ' defense-in depth' 6
t desinged into L-Beactor's safety systens. From this perspectiw , the lack of a passiw containment building, a standard safety feature of all U.S. civilian pcwer reactors, nust be a source of serious concern. A masure of tne inccmpleteness of the L-Beactor risk assessnent is the fact that it does not own include accident scenarios which could lead to a full core m itda m with failure of the radioactiw gas filtration system." (Supra)
It is clear from the statements of these scientific experts that COE has not pecperly assessed the total inpact of adding another nuclear facility, the b-Beactor, at the Savannah River Plant, nor have they own assessed thoroughly the inpacts that current facilities are having on the air, water and living species of the area. Clearly, since IDE cannot make an accurate review of its own facility, Cuorgia Power Conpany cannot possibly make an accurate assessnant of the cumulatiw inpact of Plant Vogtle operations upon this already seriously nuclear-inpacted area.
If a serious accident were to occur at Plant Vogtle and radionuclides weru emitted on and of f site, it would be practically inpassible to detemrine hcw noch of any increases in radioactivity in the area surrounding the plant would be coming from Wgtle. If there were an accident at both facilities at the sam time or close to the sans tina, the difficulty once again as to determining which facility is releasing what effluents would be magnified innansely. W ese scenarios as well sa all of the concerns noted by reviewers of the L-Beactor DCIS are not thoroughly addressed in the PSAR. Applicant notes that "the amounts of nuclear materials produced by the un@ are classified infomation, and that this document represents a best effort at obtaining detailed information for facilities at SRP." Yet Applicant fails to address concerns, including those afore-nuntioned, that have been docunwnted in the unclassified infonnation available on SRP operations. A study of cumulative taalth, safety and environnuntal inpacts of the operation of additional nuclear facilities in the Savannah River area aust support Applicant's claim that it can safely operate the proposed Vogtle Plant.
7
h GNE 3 '
l 4
Applicant fails to show that the fear caused by living adjacent to a nuclear i facility will not threaten the security and well-being of the ocsmanity, in I i violation of various laws and rules and regulations.
Applicant fails to address the psychological inpact of the threat of nuclear contam). nation or nuclear texplosion upon the public. Every nuclear power plant daily leaks carcinogenic and nutagenic effluent. These radioactive materials enhance the level of background radiation to which we are constantly exposed, increasing tne risk of our developing cancer and the risk that our children and future generations will be damaged or die by genetic nutations.
'Ihe average reactor produces. some 400 to 500 pounds of plutonium per year.
Dangerous for at least 500,000 years, this incredibly toxic substance poses a monumental, threat to public health.
Some plutonium, 'perhaps as nuch as 2%, cannot be accounted for and presumably escapes into the water, the' earth and the air during industrial activities and 4
prN===ing. Seaborg, tne isotope's discoverer, has estimated that 1.6 million pounds may be produced bf One year 2000. Therefore, we may have as nuch as 32,000 pounds of these molecules that may te disposed throughout the environment. Dr. John Gofman has indicated that even with 99.99% \
reliability,160 pounds of plutonium would still be released, enough cancer., doses _for alnost 15 times the earth's present population.
Psychological stresses and fears. pose potential narm to all of us, especially l to children and expectant mothers. Childhood fears of' nuclear catastrophe may last a lifetime'and cause irrepairable damage. ' A parents's.oc,ccapation with the genetic fate of'his child living in a' nuclear'world is certainly understandable.
.r
- . ~
4 Plutonium molecules are concentrated by.theitesticles and ovaries, wnere l
inevitably they wil cause genetic autations, which'will be passed on to future 1
- ; . l 1
generations. These molecules are absorbed 1by< infants during the first four weeks of l
.s y s
's s 8 ..
'1 %
'l :
. l
_ . _ _ - - . _ _ . c. ,_ _ f . _ . _ . _ . _ . _ . _ . . . . _ , _ - . - - . . _ . _ -. ,__ l
s life (at which time their intestinal walls permit absorption). We extreme -
i susceptibility of infants is coupounded by the fact that plutonium becones concentrated in milk (human or animal). Children who are exposed to radiation while in the uterus have higher rates of leukemia and other disabilities.
Se nuclear era is relatively young, approximately 30 years for comercial reactors and 40 years for military production. Since the latency period of cancer is 12 to 40 years and genetic nutations do not often manifest for generations, we have barely begun to experience the effects radiation will have upon us.
Ordinarily, not imediately, but cancer has become one of America's most feared diseases, frequently resulting in a painful and slow death. Almost one third of all Americans now living nay expect to contract this ailment. During the '70s alone, 3.5 million people were expected to die from it. And if we should be one of the fortunate ones not to get cancer from this national lottery, then fears and anxieties will threaten the security and well-being of our comunity, inhibiting parenting of children and agonizing over the fate of our offspring. Proceeding with plans to operate a nuclear power plant in light of the fear on the part of the public would be inimical to the public health and welfare.
GANE 4 2e Applicant has underestimated the danger to lives and health of humans, livestock and plants exposed to the electrcsagnetic radiation of the proposed 500 KV transmission lines frcun Plant Vogtle in violation of 10 CFR 51.20 & 51.21 and the National Environmental Policy Act of 1969, 42 USC 4321 et seg.
, h e Pplicant has proposed to build 500 KV transmission lines on 350 feet right-of-ways to transmit power from Plant Vogtle into its existing and expanding grid system. Applicant clearly displays in promotional brochures, i.e., Electrical Transmission: An Environmental Awareness, pictures of gardens, tennis courts, parking lots, golf courses, neight-_ Mci ball parks and playgorunds. his publication claims that to protect the public "high clearances safely free the land beneath the wire for . development as recreational, business or residential areas."
9-
- - . - - -- , - , . - ,,-,,3 y , - , ., , , - -
,-----,33y , .-_c,-r,- ,, .e.,, _ , , - . . . , , , , . +,
1 .
I J
l he Applicant encourages and offers as a benefit the presence of transmission line easementsfor property owners adjacent to the lines. Similarly, the effects on residential areas is claimed by Georgia Power otmpany in recent environmental inpact studies to be an asset by providing additional space for public use without questioning the safety of such lines, i Growing scientific evidence does not support such a position. Dr. Moreno, a ,
scientist at the Veteran's Achinistration Hospital in Syracuse, New York, testifying l l
in cases 26529 and 26559 before the State of New York Public Service Comnission on <
l i " Health and Safety of Extra-High Voltage Transmission Lines", recomended applying ,
I the maximum exposure level of 0.01 KV/M for new lines. More intense fields, 4
according to Dr. Morino, would be tantamount to subjecting the people to involuntary ;
human exposure experimentation in vilation of tne Public Health Laws and fundamental ethics.
3 In its Environmental Analysis of Plant Scherer and Associated Transmission Lines, applicant contends that a field intensity of 5 KV/M "is of no concern to
! humans, animals or plants." To those living near these high voltage lines, there is evidence for concern.
L Additionally, applicant provides no assurance that this level will not be i increased in the future. l
- 2ere is evidence that "non-ionizing radiations...may be nultiplying...so i a
rapidly in the human environment that they...[ result) in health hazards in some areas before we are sufficiently aware of the magnitude of the problem."
+
("Significanoe of Human Exposure to Iow IAvel Radiation," Morgan,- 1978)
Morgan adds, "An overwhelming amount of data already accumulated show there is no safe level of exposure and no dose of radiation can be_so low that the risks do i
not exist." The risks are those of carcinogenicity, teterogenicity,' brain danage l
l and behavioral effects such as irritability, loss of memory, loss of reaction time, 10 I
a 7 ~m -- -
-- , , _ , - . , , , ,%. ,s-. .- . ~-. .. , _w . . - . , - ,. ,-,-w . g n -- - , - , , , , , _ _ , , yy- -y -y -
manges in heart rythms (persons wearing pacemakers may be seriously affected by high voltage lines), changes in blood chemistry, stunted growth and loss of l appetite. A Colorado study indicated a correlation between leukemia in children and the proximity of the d ild's home to relatively low voltage transmission lines.
H. Richard Payne, Head of the Environment Radiation Section of the Region IV EPA, stated in a conversation on April 9,1984 that evidence exists showing an effect on electrical balance in cells from exposure within several hundred feet of high voltage lines.
Robert Helliwell of the Stanford University Radio-Science Laboratory has found that electromagnetic radiation from the Canadian power system was being injected j into one of the earth's magnetic ducts. 'Ihese waves pass into the magnetosphere where their interaction with trapped electrons results in the production of X-rays whicf1 give rise to secondary interactions producing ultraviolet light. Dr. Morino i warns that the ultraviolet light can increase the incidence of skin cancer and j result in global climate changes. He suggests that the scope of tehse hazards, now unclear, might be so great as to necessitate undergrounding the prcposed line.
Applicant has not adequately assessed the alternative of placing the transmission lines underground. Applicant has not adequately examined the nost recent heatlh. risk data on effects of exposure to high voltage field on plants, animals and humans located adjacent to high voltage lines in violation of applicable laws, rules and regulations.
i,
! GATE 5 l
' Die applicant has not prcperly assessed the geology of the site and has not i properly considered the geology of the site in the engineering design of the project, especially in light of new data made available by the U.S. Geological j Survey. This violates NBC rules on seismic standards described in 10 CFR Part 100, l,
Appendix A, and other applicable laws, rules and regulations.
i 11 l
. e
'1he U.S. Geological Survey has postulated the existence of the Millett earttquake fault seven miles frm. the Vogtle reactor site. (U.S. Geological Survey Open File Report 82-156) Petitioner disputes applicant's claim that the fault is not capable.
Further, USGS nas pointed out to NRC that "after several years of intensive study in the Charleston region, no geologic structure or Ceature can be identified unequivocally as the sour of the 1886 Cn:rleston eartiquake." (letter from James F. Devine, Assistant Director for Engineering Geolcgf, USGS, to .%bert E. Jackson, Chief, Geosciences Branen, Division of Engineering, NRC, dated Ibvember 16, 1982)
'Ihe Charleston earthquake was the second worst recorded in Amrican history and was nore intense than the San Francisco earthquake. USGS in 1887 said of the Charleston Earthquake, the " area within wnich notion was sufficient to attract. .. attention would be somewhat nore tnan that circumscribed ty a circle of a tMmand miles radius. Six hundred miles from the origins, the long swaying motion was felt and was often sufficient to produce seasickness (nausea)." USGS reported that the earthquake was felt in the Adirondacks; Ontario, Canada; Micnigan; Milwaukee and Green Bay, Wisconsin; and even Cuba. In eastern Kentucky and southeastern Ohio, "cninneys and bricks were shaken down." USGS went on to say, "In all of .the large tcwns within two hundred miles of Charleston, more or le.ss danage was suffered...dans were broken (on the Savannah River aad naar Barnwcil). ..At.
Augusta,110 miles distant from the epicentru;n, tae danege to buildings was considerable... (For exanple) at the Arsenal,'the comunding officer's residence was so badly cracked and shattered as to necessitate practical reconstruction...In-AtlantIs,250milesdistant, there was no worse injurf than falling chimneys and sme .
slight cracks in the wall,~ but the houses were' instantly abandoned in great alarm and confusion by their occupants, and neny preferred passing the nignt in the.
streets to re-entering their dwellings."
12 n
U Se situation in Charleston itself was, of course, even worse. We words of an eyewitness survivor are particularly relevant to this proceeding:
-)
...It was upon such a scene of cal:t and silence that that snock of the great !
earttquake fell, with the suddenness of a thunderoolt launened from the starlit skies; with the might of ten tnousand thundercolts falling together; with a force so far surpassing all otner forces knw n to men that no similtude can truly be found for it. The firm foundation upon which every home nad been built in unquestioning faith in its stability for all time was giving way...For a few noments all the innabitants of the city stood togetner in the presence of death, in its nest terrible fonn. ..
(Within one minute) Every hone in the city had been broken or shattered--and beneath the ruins lay the lifeless or bruised and bleeding bodies of men, women and cnildren, who had been stricken dwn in the midst of such security as Iray be felt by him who reads these lines at any remte distance of time or space."
Even if Applicant is correct that the Millett eartrquake fault is not capable-a premise Petitioner disputes-the area is of a similar geolcgy to Charleston and tnerefore poses a risk of a devastating earthquake, pernaps as high as XII on the Mercalli scale.
Petitioner naintains that Georgia Pwer has not adequately designed Plant Vogtle for such seismic events as are reasonably expected to occur there.
GANE 6 2e applicant cannot guarantee the safe operation of the reactor for the life of the plant due to unresolved questions of thermal shock effects on irradiated reactor vessels as required by 10 CFR 50 Appendices A, G, and H and other applicable laws, rules, and regulations.
Ser:ral shock and tne effects of operator response, neutron irradiation, and pressure vessel steel impurities remains an unresolved scientific question.
Pressurized water reactors are susceptible to cracking of the reactor vessel due to severe drops in vessel tenperature under nigh internal pressure. Neutron irradiation of tne reactor vessel, especially at tne midline, womens the vessel and raises the reference tenperature at a rate dependent on the inparities in the steel and welds 1
i and the rate of neutron irradiation. Studies by the Oak Ridge National Laboratories l
l showed that conditions created during a routine transient at Pancho Seco reactor near Sacremento, CA might be enough to cause cracu in older irradiated pressure 13
. e vessels. Further analysis and nodel sinulations sncwed that whether pressure vessel ruptures would or would not occur in a Pancho Seco type transient depended on the operator response. If the nodel assued correct operator response then the sinulations indicated the pressure vessel would not rupture during the life of the reactor. Conversely, if the model assumed incorrect operator response, the reactor vessel would be subject to rupture within 3 or 4 years of start-up. Bus, protection fran reactor vessel rupture seems to depend totally on operator response and not on redundant safety features built into the plant (Marshall 1981, 1982).
Se reactor vessel for Plant Vcgtle contains 0.10-0.125 ccpper and 0.012 to O.0204 phosphorous (FSAR sec 5.3.1.1) but no discussion is undertaken by the applicant as to the effects of these levels of inpurities on accelerated crittleness and increased reference tenperature for the pressure vessel. Tne applicant also does not consider the effect of varied fuel rod geoautrics on pressure vessel embrittlenent. In general, the applicant has not considered the 1cng ters safety hazards posed by the problens of ther:ralshock comoined with the ef fects of vessel material inpurities, embrittlenent due to irradiation, and tne confounding effect of operation error.
In addition to not addressing the safety factors outlined above, the applicant does not address the ecrsnome costs of porsible solutions to the problens associated with thermal shock. De applicant states that "no special design features. .. prohibit the M situ annealing of the reactor vessel" (ESAR sec. 5.3.3.1) but do not consider the costs of this process. If annealing is necessary af ter plant start-up, a shutdown of two years may be necessary (Marshall 1981). We applicant also neglects to nention tne economic cost of changes in fuel rod geonetry whien might be necessary to decrease irradiation of the recctor vessel.
2 GANE 7 Applicant has not adequately addressed the value of the groundwater belot the 14 I - -
8 plant site and fails to provide adequate assurance that the groundwater will not be contaminated as required b/10 CFR 51.20 (a), (b) & (c),10 CFR 50.34(a)(1) and 10 CFR 100.10(c)(3).
Tne groundwater underlying the Vojtle Plant is a valuable resource whose protection has not been (and cannot be) assured by tne thorgia Power Conpany.
Approximately 300 feet beim the surface is the Tuscaloosa Aquifer, a permeable sand formation which contains large volunes of excellent quality water. 'Ihis aquifer is an inportant regional aquifer which supplies water to many cities and i connunities across cantral Georgia and nuen of the South Carolina coastal plain. In eastern central Georgia, the 'Ibscalm Aquifer is the najor source of water for many comnunities. In Richmond County just north of Plant Vogtle, eignteen Tuscaloosa wells provide water for 15,000 people. In Girard, which is approximately five miles from the plant, and McBean, only thirteen miles away, tne Tuscaloosa provides drinking water for nest of the com:mnity residents.
Tne Tuscaloosa Aquifer is not the only valuable groundwater resource underlying the plant site. At a depth of approximately 200 feet belcw surface and a tnickness of approximately 100 feet, the sand nenter of the Lisoon Formation also represents a valuable groundwater w xxtrce for the area. Cooling system nake-up ster wells for the plant which penetrate and are cpen to both tne Lisbon Sand Formation and tne Tuscaloosa Aquifer can provide as nucn as eso thot.1 sand gallons per minute of excellent quality groundwater. '1his groundwater is not only inportant as an existing source of drinking water but it is inportant to future development wnien is likely to occur along the Savannah River corridor.
Directly belos the surface at the Vogtle Plant is the water table aquifer.
While this aquifer is not as areally or vertically extensive as the Tuscalcosa or Lisbon Sand Formations, it is used extensively in Burke County as a source of drinking water for numerous donestic supply wells, as a small scale agricultural supply and for some ccamercial establishments. To these individuals, farmers and businesspeople, loss of this source of water tnrougn contamination from Plant Vogtle 15
b c
could endanger health and cause economic hardship.
In the case of a release of radionuclides to the ground at Plant Vogtle, tne water table aquifer would be the first and the nost seriously i:rpacted oding to its close proximity to the surface. In the area of Plant Vcqtle, soils are perneable and virtually no runoff of rainwater occurs. Any release of radionuclide contaminated water would seep innediately into the ground and eventually reach the water table aquifer. De sandy nature of the soils and the aquifer material would offer little retention of radionuclides. S e radionuclides would migrate with the groundwater and aantaminate larger portions of tne aquifer.
A significant contamination incident could result in contamination migrating vertically downward from the water table aquifer into the deeper Lisbon Sand Formation and the Tuscaloosa Aquifer. Mile a clay separating the water table fran the deeper aquifers gay provide sone protection for the deeper aquifers, the 50 feet of hydraulic head on the water table aquifer acts as a vertical force on the groundwater, pushing it through fractures or nure permeable sections of the clay.
It is kncwn that just south of the plant site, tnis clay changes into a limestone, becoming part of a najor regional water supply aquifer, the Principal Artesian Aquifer.
We Georgia Power Conpany's record of groundaater protection is not encouraging as denoristrated by events at the Hatch Nuclear Plant. Groundwater underlying Plant Hatch has been contaminated with tritium fran a source or sources never fully identified.
GANE 8 Agiplicant has failed to enforce a quality assurance program in the construction of Plant Vogtle that provides adequately for the safe functioning of diverse structures, systens and ocmponents, as required by 10 CFR 50 Appendix B.
We success of a quality assurance, program is ultimately tied to the generation of adequate confidence concerning the correct functioning of critical nuclear pcwer 16
o plant systems and mmponents.
Repeated violations of 1.'RC reculations try Applicant in tne construction metnads applied to pipe-fitting and welds mst te interpreted as undermining confidence in the capability of coolant and ccntainnent system to perform their msential tasks.
Although potential deficiencies involving selds in contairant liner penetrations had been raised as an issue at least es early as @ril 29, 1981 II & E file eX78G03-M18), problems involving tne appropriate inspection of welds have
, occurred at least as recently as Septerner 1983.
Violation Notification has been issued in-several instances related to implementing the required test procedures. As indicated in IR 50-424/33-15 Appendix A, the aplicant's construction sheet for examination of reactor coolant pressure boundary welds did not specify the penetrant examination test required by NRC. Sucn a failure, not sinply in the execution of a prescribed test, but the omission of the test from the required procedure, certainly reduces tne confidence in the correct functioning of a vital reactor safety system.
Failure to assure that non-destructive testing is conducted consistent witn applicable codes led to another violation as reported in IR-50-424 and 50-425. In this instance grit-blasting of tne cicsure head weld cladding of Plant Vogtle Unit 1 (IE X7B610) was performed after liquid penetrant examination of the corponent. Tnis represented not only a departure from the stan-irrd prxecure of performing the examination on the conponent in its finisned condition but an unintenced rethod of degrading a critical steam system ccqanent after its final installation and inspection. This is nuch more than a flaw in an isolated procedure; it is a basic failure in established quality assurance retnedclogy.
Any adequate quality assurance program mst take into account a broad range of
" planned and systematic actions necessary" to establish confidence in the system in
~
question. Any quality assurance program predicated exclusively on the 17
W inplementation of dictated procedures without regard to the exercise of critical judgement and standards'of professional practice mst be considered woefully inadequate. In an examination of welding activities involving steel structures and supports in both Units 1 and 2 of Plant Vogtle, the applicant was cited for failure to include the heat-affected zone (HAZ) of the weld in acceptance radiograpns (IR 52 1
50-424 Appendix A Report Details). In response to the notice of violation, the applicant defended its pro dure by replying that tne Code "gives no requirement for including the heat-affected zone in the area of interest" (X78610). 'Ihis response, which erroneously equates nethods cf quality assurance with single conpliance to written procedures, was so unacceptable to the NRC tnat it was directly criticized by Richard C. Lewis even though the violation itself nad been withdrawn. In his words,
" Interpretations of the code by ' Code Experts' make your response appear to set side engineering reason when you consider tnat, based on failure analysis experience, the technical world realizes tnat the heat affected zone of a weld is the most critical area of the welchent."
4 In a related matter on November 18, 1982, welding on sections of the i
containment dome of Unit 2 was conducted during a "very light misty rain." Tne l welding and site OA supervisors felt that the conditions were suitable for welding since the surfaces of the pieces involved were not coupletely covered with moisture (425/82-29-02). 'Ibe inspector, nore concerned with the quality of the weld than witn the " General Welding Procedure Specification for Shielded Metal Arce Processes," prevailed upon the two to stop the work for the day, i
The applicant's disposition to prefer restrictive i:rplementation of prescribed i
j grocedures to the nere circumspect methods of professional practice does not contribute to confidence in tne proper functioning of a completed and operating 4
Plant Vogtle.
In addition to these procedural aspects of quality assurance, there are other questions involving the applicant's " controlling the quality of the ...conponent or ll 18 t
e
.- + - - + . , y . . . _ . .
system to predetermined require: rents." In the case of quality control the repeated discovery of inadequacies and defects in the performance of an essential safety l I
sutsystem would generate a cause for concern. Furthernere, at som point in tune, good quality control practice mandates the abandonmnt of a suspect manufactured article in favor of a nore reliable alternative.
me standby steam generators selected by the applicant for use as an emergency backup pcwer system and manufactured by Transamrica Deloval have been riddled with problems. Se applicant was notified of such problems as early as December 1981.
Eat defect involved the governor lube oil cooler assembly and, according to Transamrica Deloval, "could result in engine non-availability." Tne applicant -
itself reported a starting air valve assemoly problem (X7B603-M29) that also "could result in engine non-availability." Likewise proolens witn piston skirts, reported in October 1982, in the applicant's cwn analysis (X7B603-M36) could, pcstulating a ecxmon node failure, "cause the failure of both engines, resulting in a loss of power to both trains of the emergency core cooling system and :rost of the emergency safety features equipment."
In a report of a defect in the engine nountec electrical cables sutenitted to the NRC in September 1983, TD also noted a potential engine performance deterioration.
2e applicant's responsibility for quality centrol extends beyond collection of individual defect notification and corresponding remedial action. By failing to nake a general assessent of the suitability of the TD diesal generator system for such an extremely inportant emrgency function, the applicant has brought its cwn quality control capabilities into question, undermining confidence in the safe functioning of its operating plant in direct contradiction to tuC QA requirements.
The number of past and continuing failures of the Georgia IN:wer/Bechtel CA/QC program represents a pattern which indicates an undue risk to the health and safety of the public. Violations involving activities at tims resulted from failure to l 19 i
l L _
, j j .
l-i provide documented procedures. '
(For exarrple, Peport tb. 50-424, 50-425/83-04 j
. regarding concrete QC probienu) '
i 'lhe severity of Quality Assurance performance at Plant Vogtle forced a meeting I
, conducted 22 August 1983 at Georgia Power neadquarters on tne sub]cct of .
) Subcontractor Quality Assurance Performance Allegation by Pull: tan Pcwer Products l j quality control personnel about pipe support installation and piping installation i
l as well as job intimidation of quality control workers. Allegations had been nade i 1 ;
f by a Walsh Conpany boilermaker that inproper. welding and work practice had occurred. ;
} Twenty-three concerns which dealt with twelve separate items were discussed. .
1' Defects were found during the reinspection of Pullman Power Products manufactured I
- piping spool pieces. (letter from James P. O'Peilly to Georgia Power, 28 Septammber i
j 1983,
Subject:
Sumnary of Meeting--Docket Nos. 50-424 and 50-425, Vogtle 1 and 2) l Procurement failures continue after numerous I & E Bulletins from past QA/QC i '
a j
inaction. (for exanple, I & E Bulletin 83-06 "Nonconfor.ning Materials Supplied by l Tube-Line Corporation Facilities at lorg Island City New York, Houston Texas, and j Carol Stream Illinois," Westinonouse NLP P.inted Circuit. Cards GI-275, dated 11/3/83 i i
and GN-298, dated 12/27/83; estingnouse tx:i-416 Feactor Trip Breakers G4-235, dated
! June 13, 1983; Westinghouse NSSS Protection System, :'elay cards, G; 244 dated July 20,1983; AKR-30 and AKR-50 Electrically Operated Low Power Cirouit Breakers; Westing' house 3" Gate Valve Closure Problem, Westinghcuse 4" Gate Valve CJosure i Problem, Reliance Electric--Cable Terminations; Brwn Boveri Electric Inc. 7.5 HK
- I
, and 15 HK circuit breakers; and American Delaval backup diesel generators) i
] Repeated questions have been raised about enanges in the Vogtle QAP in addition to the. earlier described letter from Richard Isis of NRC to Applicant. For exanple, there are questions about the completeness of the Vogtle QAP. (Memorandum j from James G. Particw to Assigned Reviewers, 29 Novenber 1983,
Subject:
j Determination of Acceptability of List of VDGP items under QA Program Questions t
9 20 i
i C
f O
.c.-., - -v-,n-, ,-e sLe - - - - - v., .n-, n,,.r,--na,,,-- -,-re.v.w,m,,,. ,.,.---,wn,m,. -~~..--r- -.v-, e -- -
characteristis, unusual or novel design features, and principal safety considerations" in its PSAR (enphasis added).
1 A final safety analysis report (10 CFR 50.34(b)) aust contain "a description and analysis of the structures, systens and conponents of tne facility, with enphasis upon the performance requirenents, the bases witn technical justification therefor, upcn which such requirenents have been establisned and tne evaluations l required to show that safety functions will te c.ccorplished. The description shall be sufficient g permit understanding of the system designs and tnelr relationsnip g safety evaluations." (enphasis added)
Despite these specific regulatory requirenents che applicant has proceeded with the inplementation of a novel design without proviaing informtion adequate for the J
minimum evaluation of its safety inplications.
]
For exanple, in a letter directed to Harold Centon dated October 25, 1983, the applicant prcposed to eliminate the need to postulate longitudinal and i
circumferential pipe breaks in the reactor coolant system primary loop in the design of VIEP. As a modification of an existing design require:aent this cannot be l considered as anything but novel. Unfortunately, even the mininum infor: ration required to understand and assess tne safety ing$ct of suca a departure from standard design has been cradicated trom the restingnouse Electric Ccrporation j report which provides the inpetus for the design cucision.
In " Technical Bases for Climinating large Frimacy Loop Pipe Rupture.s As the Structural Design Basis for Alvin W. Vogtle Units i m3 2," an analysis is gor.eratad fran pipe-loading and fracture-meenanics nodels. N Jetails of the models have been withheld based upon a claim of prcyriety oy tbstingnouse. Tne sanitization of tne report is so severe that even the figures presenting the carparison of the predictions of these nodels with experinental results have been remcrad.
It is inpossible for anyone to evaluate or understand the inpact of such an innovation on the safe functioning of the applicant's operating system.
22
.' e l
About Field Change Notices; Pojuest for acklitional informtion, letter dated 20 Septencer 1983 from W' ster L. Kintner to Doug E. Dutton)
Another threat to the quality assurance, quality control and safety and healtn of the public is the drug and alconol use wnicn has Wen documented and continues to take place on the construction site. We breakJoan of the OaP results in situations such as that described in Preliminary Notification cf Event of Unusual Cccurrence Ptoll-82-115,
Subject:
Arrest of Contractor E ployees on Drug Charges involving Drug Sales and Use, including marijuana, cocaine and valium.
Other allegations frcm a formr e:rployee pertain to inprcper QA testing of backfill mterials and falsification of backfill QC test results. Four allegations made by a former employee pertain to inadequate concrete QC testing and falsification of concrete QC test records. 'No allegations were subsequently partially substantiated.
Four violations were also described in the Systematic Assessment of Licensee Performance Board Assessmnt July 1,1981 thorugn October 31, 1983. Valve mispositioning has resulted in a S40,000 civil penalty. Testing procedures have identified discrepancies involving cadsell cperators. Protection of equipment procedures have been neglected. Failure to establisn adequate radiograpny procedures and welding procedures places the integrity of the entire plant in doubt.
'Ite ccuplete failure of the QA/QC prgren at Vogtle mirrors similar situations at the Zimmer Nuclear Plant and the Byron Nuclear Plant. Plant integrity cannot ce assured at Plant Vogtle in view of tne large nut:bar of violations and inadequacies found to date.
GANE'9
'ihe applicant has failed to submit adequate discussion of novel design features in its preliminary and final safety analysis reports as required by 10 CFR 50.34.
NHC regulations require that Applicant nust include "a summary description and discussion of the facility with special attention to design and operating 21
Models of engineering systens have no intrinsic validity. Se utility of the model is only realized in the otrnparison of its predictions with a body of enpirical data. Without such a cor:parison a model is no trore than a nethod of generating a desired result.
Furthernore, the claim that the results of a r:odel betray a proprietary interest is hard to accept. It is difficult to reconstruct a r:odel of even minor cxmplexity from a handful of numbers. Oddly enougn, if cne could deduce the form of the model from a small set of predictions the model would proba:,1y be so trivial as to have no proprietary value.
Se failure by Westinghouse to provide ade3uata substantiation of its apprcacn and tne applicant's insistance on using the resul:ing claims as a tasis for a major departure in the design of a critical safety system is an unacceptable beteen of the regulatory code.
i GM!E 10 Applicant has not shwn that safety-related electrical and mechanical equipment and ocuponents will be envirormentally qualified at the onset of operations and throughout the life of the plant as required by General Design Criteria 1, 2 and 4 of 10 CFR 50, Appendix A and other applicable NRC rules.
ne concept of environmental qualification, i.e. that safety systens must be able to survive and perform their functions under accident conditions, is "fu:damental to NRC regulation of nuclear pcwer reactors." UCS Petition for '
Emergency and Remedial Action, CLI-78-6, 7 NRC 400, 408 (1978); CLI-80-21,11 NRC 707, 710 (1980). Safety is the "first, last and permanent consideration" and can lead to the shutacwn of noncor: plying plants. Pcwer Reactor Develop::ent Corp. v.
International Union of Electrical Radio an_d Macnine prkers,, 367 U.S. 396, 402 (1961).
Applicant has not demonstrated that its present safety systens testing met.%$s, VDGP FSAR Table 3.11.B.1-1, Figures 3.11.B.1-1, 3.11.B.2, are adequate to ensure 23 8
e !
. I effective operation under emergency conditions. For exanple, in investigating accelerated aging of materials, Sandia Lauratorf has found tnat many materials experience greater damge frati icwer as opposec ta raised dcse rates when the total integrated dose is the sa::.:. Proceeding International _ Netinq on Lignt yhter Peactor Severe Accident Evaluation, August 1983, TS-3.1; Industrial Pescarch and Development, June 1982 at 55-56. Particularly sensitive-are polyners which are found in cable insulation and jackets, seals, rings and gaskets at VEGP. Current methods of testing have used high levels of radiation or only reported tne integrated dose (VEGP P3AR, Table 3.11.8.1-1) and therefore underestimate the effects of the total dose. NUREX3/CR-2157, "Occurance and Inplications of Radiation Dose-Pate Effects for Material Aging Studies," June 18, 1981. Se effects of
. synergisms, involving tne arbined effects of radiation, heat and in scme experiments oxygen concentration, were also studied at Sandia. W e greatest amount of aegradation was found upon exposure to heat folicwed by exposure to radiation (significantly affected ty oxygen during a LfG simlation). tidREG/CR-2156,
" Radiation-2ermal Dxjradation of PE and PVJ: &chanisn of Synergisns and Dose-Rate Effects," June 1981. ,
Sandia has also identitied other interr.stiN "anccalics." In tests of EPR cable material, nutticonductor configuration performed "substantially worse" tnan single conductor configurations. Sandia concluded that qualification testing employing only single conductors as test specinens may not be representative of multiconductor performance. Testing of terminal blocks by prior industry standards (function before and after accidents) is not adequate. Instead, applicant nust show equipment can function during accident conditions. Sinulation of these conditions led t6 instrument reading errors on high resistance instruments of 15-90s, wnich were not conservative. This could have led real operators to think that there was adequate subcooling when in fact the degree of subcooling was significantly less.
l UCS, Petition for Emergency and Remedial Action, Supplemental, February 7,1984.
l 24 l
. 1 1
'lhe results of these reports have not been applied to environmental qualification testing hrformed and referenced by Applicant to denonstrate l conpliance of safety-related equipnent and ccmponents with applicable standards.
Several pieces of equipment specified in VEGP FSAR Taole 3.ll.N.1-1 as being environmentally qualified may in fact be urquaiified. For exanple, on August 31, 1983, NIC issued a Board notification transmitting a sumary of a staff investigation into Franklin l<esearen Center tests on solenoid valves. Over half the valves failed in tests sinulating nontal and accident conditions. BN 83-128.
Several valves manufactured by ASCO failed early after exposure to 340 degrees F., i.e. , they had little or no tine to perform their safety function before failing. Over one year earlier ASCO's can testing had shown poor performance of these valves, and had reported this to the EQB. The EQB memo fran R. Vollmer to D.
Eisenhut (included in BN83-128A) stated the staff " continues to approve" the qualification of valves on the basis of 1978 tests. 'Ihe applicable standard in 1978 was IEEE 382-1980. The EQB concluded that tne early failure of the ASCO solenoid valves makes them unacceptable for use in safety systems and suggested that licensees and applicants be pronibited from using the valves in any application where conditions could be nore severe than those reported in the qualification test report. VEGP FSAR Table 3.11.N.1-1 shows the use of twenty-tnree separate ASCO sellenoid valves. The function of sone of the valves is not listed and in no case is the qualification reference listed.
Also shown as qualified are forty-three (43) separate r.otor operators manufactured by Limitorque. The conpany's own testing, see IE tbtice 81-29, EEQN No. 1 (September 24, 1981), had shown motor failure on initiation of steam spray accident profile. An update, IN 82-52, siaply noted tnat "tnis is an ongoing problem." Westinghouse performed further tests and concluded that "the present motor design will not successfully pass Westinghouse specified test parameters."
25 D
l l
l
'Ihe NRC staff has only confirmed that they will pass IEEE 323-1971, a standard explicitly rejected by the Comiss on in CLI-80-21 as virtually useless.
A critical safety conponent in LOCA is the post LOCA nydrogen recmbiner. One cmmon type of unit manufactured by Bockwell International nas recently been shown to have a large number of defective parts. EEQN tb.14 in IN 83-72 (10/28/83). For example, I'IT pressure transducers failed typical [EEE 323 environmental 7
qualification testing, i.e. , they vx1d not withstand radiation doses of 1 x 10 rad 4
and showed gradual drifting of readings af ter 1 x 10 rads. Inspection of VEGP E R 6.2.5 gives no indication of the manufacturer of the hydrogen recombiner. FSAR,
- 6. 2.5.1.1.A states:
All materials used in the recombiners are selected to be cocpatible witn the environmental conditions inside the reactor containment during normal operation or during accident conditions.
'T However, no specifics can be found. FSAR 6.2.5.4.1 briefly sumarizes testing on
, the hydrogen recombiners in the Westingnouse development program. Tne effect of radiation was not tested. A hydrogen recombiner containing urqualified transdumrs was shipped to E.I. Ilatch 2.
'1he applicant has not satisfied 10 CFR 50.48 wnicn requires a showing that safety equipment is capable of surviving a fire in order to shut the plant down.
I Since the NRC has no testing program to establish that the necessary safety equipment is qualified to withstand the fire environment, there is no assurance that 4
the applicant's equipment can withstand such conditions as high humidity, hign tenperature, spray, corrcsive gas, stroke, all of these probably conr,ined with radiation. Ccanission neeting of January 6,1984, Tr. at 36; 'JCS Per.ition for Emergency and Renedial Action, Supplenental, February 7,1984 at 27-29. Without i this assurance, Plant Vogtle should not be allowed to operate.
Applicant has not determined that suitable scismic qualifications of safety related equipment have been used in selecting equipment for VDGP. The design criteria and metnods for seismic qualification of equipment in nuclear plants have 26
4 5 4 undergone significant change. Consequently, the nargins of safety provided in ,
1 existing equipment to resist seismically induced loads may vary considerably and j nust be reassessed. NfC " Unresolved Safety Issues Smmary," August 20, 1982.
At the Comission meeting of January 6,1984, Sandia Laboratories reported
! numerous "shortaamings" in qualifications methodologies used to test safety
) equipment. For exanple, conpounded effects (related to the order in whicn several i
, , conditions are tested) can be very laportant and produce nonccoservative results 1
(under testing). A broad range of generally accepted methods was also questioned l
! which included:
Can ganma radiation adequately sinulate the ef fects of Leta radiation?
Is it necessary to include oxygen in IDCA sinulaticn enambers?
! Under what circunstances is the Arrnenius mathodology for accelerated tnermal l aging valid?
i Are mechanical stresses significant in aging of electrical equipment (cables, i seals)?
Are the procedms of IEEE standards for ytalifying specific type of electrical equipment ade: st.
] These criticisms . 4 Gestions about current environmental qualification method raise fundanental doubts about the applicant's ability to e@loy only environmentally qualified equipment in all required applications.
Applicant has not accurately defined the paranaters of an accident which would i
affect the operability of safety-related equipment. Further:rore, Applicant has !
i underestimated the period of time safety-related equipnent will be required to f j operate. S. H. Hanauer, NRC, perceived this issue as a problem shortly following
- the accident at Three Mile Island Unit 2
"I think that as a result of the TMI accident we have to rethink: -
- 1. Environmental Qualifications Envelope i
- 2. Tnings wnich may have to be qualified 4
Changes in my tninking include
- 1. Core damage is credible
- 2. Iong-term plant operation is essential, initiation isn't enougn
, 3. IDCA and Sla may not give an envelope tnat includes I41 experience."
t 27
d
--Note fran S. H. Hanauer NRC Assistant Director for Plant Syste:rs Division of Syste:m Safety April 6, 1979
, Such tninking was reiterat.ed by Ittert Pollard, loclear dafety Fagineer of tne l
Union of Concerned Scientists:
1 I tnink it is clear that what is needed is essentially a reassment of the l
, environmental qualifications of safety related equipment in lignt of lessons learned fran the accident."
l
-Special Prehearing Conference, 'IMI-l Restart Hearing, ;
Docket No. 50-289, Ibvember 8,1979, TR at 236.
GA E 11 :
Applicant has not considered generic defects in the Westinghouse Pm constituta I an undue risk to public health and safety.
Westinghouse PWR steam generator tubes have shown evidence of corrosion-induced
- wastage, cracking, reduction in tuce dianeter, degradation due to bubble collapse .
water namter and vibration-induced fatigue cracks. Of pritury concern is the capability of degraded tubes to maintain their integrity during nor.tal operation and under accident conditions. NRC " Unresolved Safety Issues Sumtery" August 20, 1982.
Se applicant has not considered the possibility of pressure vessel failure, and no protection is provided against reactor vessel failure in the design of the
) nuclear facility. However, as plants accumulate service time, neutron irradiation 1 reduces the material fracture toughness and initial safety margins. Pesults fran reactor v'essel surveillance programs indicate that up to twenty (20) operating PMs
-ill have materials with only marginal toughness after conparatively short periods l of operation. NHC " Unresolved Safety Issues Summiuy," August 20, 1932.
Se applicant has not considered nor is sufficient technical infonnation i
, currently available to deal with a steam generator tube rupture (SGIR) accident as cccurred in a Westingnouse Plant at the Scrselle Nuclear Power Station. NRC 24 83-
, 151. De TMI-2 accident convinced Westinghouse to cnange the ECCS actuation logic by eliminating the icx pressurizer level trip, and this was 1:tplemented by licensees 28
^
e
'with Westinghouse plants. Hcwever, the recent SGTR accident at Borssele actuated
- l the ECCS wnict was believed to produce " undesirable attendant problems, such as RCP trip and mntainnent isolation, wnich would m2xe accicent managemnt more difficult." Meno from D. J. Mattson, Director IAI, t'KC to D. disenhut, Director Division of Licensing, NRC, September 26, 1963. I.s stated in the above-described nemo tne NBC staff feels a revision of the ECCS logic to the pre 'Dil accident
, configuration "has the potential to inprow the m2.nagenent of SGTR events."
i Hcwever, the staff did not conclude whetner tnis " revision would have an overall net increase or decrease in plant risk."
GA1;E 12
'Ibe applicant has not properly assessed the a:rount of salt and hydrocaloric
~
acid release frczn the cooling towers and the extent of consequent adverse agricultural and environmental damage in the area of Plant Vogtle. -
'Ihe VEGP FSAR 5.5.1.1 estimtes an approximate salt drif t of 305 pounds per acre per year (see CPSER 5.3.2) witnin a one mile radius of tne cooling towers, assuming a two-unit operation. Naturally this ancunt would decrease at greater j distances. No nuntion was made of hydrocnloric acta releases, althcugh thia point as brougnt up by NRC staff at the Construction Pernat Hearing (personal cormunication from N. Herring). Hydrochloric acid would be expected to be emitted from these towers, since enlcrine is injected directly into the circulating water system, with a maximum system decign cnlorine rate of 10,000 lb/ day. Thus tnere is the potential for tne release of thousrinds of pounds per clay of nydrochloric acid whicn is not addressed in the FES-CP or OLSili (see section 3.6.4.2) and could pcae a l serious envircnnental problem. In the VEGP-OLSER-C-E290.3 tne rate of salt drif t
.l emmission of 305 lo/ acre / year is at.itted to be presently considered in the range of potential damge to vegetation.
GAIE 13 Petitioner contends that Applicant's proposed energercy plan fails to ensure 29
~
T .
l l
that protective measures can and will be' taken in the event of a radiological mishap at Plant Vogtle, aa required by 10 CFR 50.33, 50.47, 50.54 and Appendix E to Part 50.
Applicant's Energency Plan states tnat tne Burke County Civil Defense Director i
will coordinate emergency operations at tne local level. Tne plan fails, nwever, to note tnat Burke County nas no f all-tine emrgency manager or of fice. ne County lacks a hot-line system tie-in to the State urergency Mc2nagemnt Office. S e Acting Director of Emergency Managenunt of Richmond County, Pam Smith, states that she occasionally nas difficulty contacting energency personnel in Burxe County due to the lack of a full-tirn emergency planner. (Conversation tutween Dr. Judy Gordon and Ms. Pam Smith, April 4, 1984) terefore Applicant fails to snw that provisions exist for pronpt cxxmunications among principal response organizations and that each principle response organization has the staff to respond and to augant its initial response on a continuous basis as required by 10 CFR 50.47 (b) (1) and (6).
Similarly, the Plan specifies that tne Burke Ccnnty Sheriff's Office will provide traffic mntrol, law enforcenent and aid in the ewnt of an emergency. Yet the Applicant fails to shN hw the limited staff of 28 deputies and one sheriff will be able to effectively nandle sucn a task in light of the hysteria conditions likely to l
l erevail in an evacuation atacq:hore.
1 Se Plan states that the Burke County Hospital Antaulance Service will provide ambulance service in an emergency situation, yet tne Service maintains only three ambulances. Se Burke County Hospital, wnich the Plan says will handle tne treatment of both radiation-contaminated ard mncontminated in3uries, has a bed capacity of only 52. Such facilities are unlikely to te sutficient to service a large number of injured in tne event of a fairly serioac radiological accident or of
~
- an accident extert.a1 to the plant wnich results in injury to the plant, sucn as an
- earthquake or a nuclear attacr., where non-plant related injuries will also be ranpant. Applicant does not address the fact that in light of its close proximity to Plant Vogtle, the Burke County Hospital might be ordered to evacuate in the event 30 9
0
o O
of a radiation-related accident. Applicant thus fails to show that adequate energency facilities a'nd equiprent to support tne energenecy response are provided and maintained as required by 10 CFR 50.47 (b)(8).
Applicant fails to sncu that initial notification of the public witnin the plume exposure pathway Emergency Planning Zone (EPZ) within about 15 minutes will be possible, as required by 50 CFR App E (IV)(D)(3). Applicant has not shown that the local civil defense offices responsible for notification have the necessary equipment, training and manpwer to activate a prcmpt notification system. 'Ihough Applicant lists a number of warning devices that mignt be implemented such as autos and 1: cats equipped with sirens or loudspeakers, door-to-door contact in remote areas and aircraf t equipped with sirens to M used ia renote areas, it crovides no assurance that sucn equiprent is available to 1ccal governments or tnat personnel will ce ava'ilable to operate this equipmnt. An adequate county-wide siren warninc i
system which Ms. Smith sees as a tcp priority in the ewnt of Vcytle cperation, would require installation of a minimum of 200 sirens at S5,000 each, totalling S1,000,000. '1he County has lacked the funds to install such a system in the past.
(Supra)
In the event of an accident serious enough to require evacuation of all of Richnend County, including the city of Augusta, within 26 miles of the plant, Ms.
- Smith estimates it would take three days to move out ene 145,000 citizens affected.
.I
- Sucn a task is not addressed in the Emergency Plan though Applicar.t should be prepared for the displacenent of a significant number of the population outside tne 1
EPZ due to predictable public response to a limited evacuation. For exanple, during i
the accident at 'Ihree Mile Island-2, over 30% of the people living within a fifteen 1
mile radius of the plant evacuated though only a precautionary warning to pregnant women and small children within a five mile radius of tne plant nad been issued.
'Ibe possibility for a similar masa exodus is not addressed in the Energency Plan.
i
'Ihc evacuation procedures in neithcr Butke nor Richmond Counties have been tested.
31
a l
l Yet, exercises are required to evaluate " major portions of energency response capabilities" and to identify deficiencies "as a resalt of exercise or drills", ty 10 CFR 50.47 (b) (14). Se IE staf f las concluded tnat a successful full-scale exercise is "at the com" of the finding of adequate protection for the public.
SECY-82-185, " Final Anendnent to 10 CER Part 50 and the Appendix Es tdifications to Emergency Preparedness Regulations Pelating to Icw Pcuer Operations", May 3,1932.
Se Governnent Accounting Office has concluded that
% sting energency proceckares with offsite participation would inprove State and local energency preparedness.. 2e types of deficiencies identified during these (NBC-licensed facilities) drills included:
--inadequate cormunication between the various agencies participating in the drill, authority for coordinating and inplenenting energency measures, and
-inadequate offsite radiological nonitoring procedures.
We believe it is better to identify problems in an emergency drill rather than wait until the actual event occurs. Also, by holding nuclear emergency drills, NHC-licensed power plants and local energency service agencies have been able to resolve som of the problems that aere identified.
GAO Beport to Congress, " Areas Around Nuclear Facilities Snould te Better Prepared for Radiological Energencies", EMS 78 11o, Marcn 30, 1979.
Se Applicant fails to explain why the plure exp%ure pthway E.PZ for Vogtle has been set at 5 miles rather than the 10 mile radius recorcended in 10 CFR 50.33(y). In lignt of the severe Pasquille type A weather conditions prevalent in the area, the plane pathway should be wider as oppoced to note narrcw tnan generally required. Based on the sensitivity of cnildren (in utro thro 2gn preschool particularly) the plane exposure pathway Energency Planning Zone should be larger for pregnant women and cnildren. Tne tree Mile Island-2 accident caused a statistically significant rise in the rate of . infant nortality within 13 miles of the plant. "Managenent of Padiological Emergencies," Gordon McCleod, M.D., Text of lecture, May 2,1980. McLeod, fornerly Secretary of liealtn for the state of Pennsylvania, has said.
Any radiological energency plan and response in Pennsylvania nust not overlock population density for at least 20 miles around existing or proposed nuclear reactors.
32 M
-= . _ _ _ _ _ -
- ~
Applicant has not shwn, pursuant to 10 CFR Part 50 Appendix E, IV D.2 and 50.47(b)(6)&(7) that adequate education and notifi;ation procedures will te follwed :
i during normal plant operation and in the event of an accicent at WP-3. These i ,
! requirements include " basic emargency planning :,nformation", " general information as to the nature and ef fects of radiatica", " signs or cther measures. .. helpful if an accident occurs." 10 CFR Appendix E, IV, D.2. /pplicant should be rtquired to utilize such methods as billing or home distribution of public information brochures
- i i to supplenent energency information included in phone books as not all residents can be expected to have phones. Provisions for emergency evacuation education of l
illiterate adults must also be taken.
! Applicant's plan states that possible evacuation routes for persons leaving the -
i reactor site are New River.Foad and Cbenezer Churen Poad and evacuation will primarily take place in individually w ned autos. Applicant cannot claim adequacy of i this evacuation plan until it identifies the nunwr of ^*tos to oc moved, estimate of evacuation tim, and under what conditiona corpany-owrisd vehicles will ce made j available for evacuation purposes.
Applicant claim that the Department of Energy (davanaan River P1 ant Operations l Cffice, Aiken, South Carolina) will provide radi:: logical assistance (advice and i emergency action essential for the control of 1: mediate hazards to nealth and i
safety) in the event of an energency at Vorjele. It fails to address tne possioility that an emergency situation (for exanple, an eart.Nuake) which threatens the safe operation of Vogtle might also endanger operations at Savannah River Plant. In this .
event, not only would Departnant of Energy officials be prevented from providing aid to Vogtle, other federal, state and local assistance resources would be divided between the two sites. Applicant does not address the inpacts of sinultaneous 1
, evacuation from both plants, or overload of sodiosi facilities and emergency
. vehicles in the event of injury to persons by the operation of both plants.
. 33 i
Applicant'ctates 'tnat catimates of predictions of atmospwric effluent transport and diffusioit during and,bmediately iollowing radaoactive releases are based upon ene constant man wb.d nuel. Hatn<tr'awlicant snould prepare estimates encanpassing a variety of vind and westeer condicioru.
In light of the afolo-mnticnir! facts, agiicant 'has tailed to sncw enat in the event o'f an decident at Vcycle, ackW.e ' notit ccica, :omunistion, education, evacuation, and relocation can take place for p<tr;ranent, transient, ana special populations within the Energency Planning 'Jone.
~
April 11, 1984 respectfully sutmitted, i daar. . . ua
. . . ban Feig. forr /
Georgians Against Nuclear Energy 1130 Alta Avenue AL.lanta, CA 30307 e
e e
4 A e
t 9
+
r s
t 0
/ y 9 1
~
tRIITED STATES OF AMERICA NUCIZAR REGUIMORY COlEISSIQECKETED USNR; BEFORE '1HE A'ICMIC SAFETY AND LICENSING BOARD In the Matter of ) M E 16 E M
)
GEORGIA PO6ER CO. , et al. ) Dockagggg-Q,and 50-425
) 00CMEilNG & SERVICI (Vogtle Electric Generating Plant, ) BRANCH Units 1 and 2) )
CERTIFICATE OF SERVICE
'1his is to certify that copies of the foregoing were served by deposit witn Federal Express or by hand tnis eleventh day of April 1984, to all parties in this proceeding.
k(
Dan Feig /
Georgians Aga t Nuclear Energy