ML20090E538

Response to Util & NRC Affidavits Re Transporting & Storing Raw Nuclear Fuel at Site.Fuel Should Not Be Shipped to Site Until Protection from Listed Consequences Provided & Deficiencies Rectified

ML20090E538
Person / Time
Site:	Limerick
Issue date:	03/19/1984
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:
References
OL, NUDOCS 8407190501
Download: ML20090E538 (3)

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Limorick Gon.Sta. Unitto 1&2 .I RESPONSE OF ANTHONY /F0E g., - TO

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March 19, 198(

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'g " igd recTAT a h , ing on March 7,1984 the Boa. directed affidavits be submitted-y with a contention filed by Anthony /F6E en 2"/25/84 as follows:

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- poesnWhethe or not there is any reasonable basis to believe - and of course, there can ce radiological releases sn.geggcEn /[ d,are the reasons why, or not g'N inn vio$' ion-pf the applicable regulations, on site and off site,'in the f 'b -evetf$ damage to the low enriched uranium oxide fuel pellets in the unirra-Mr4tra new fuel rods for I.imerick.

1.The shipping pabkages do not conform to the NRC revisions of August 1984 which became effective 9/6/84 ( L.?yrih Affi., p.7) because they have not been retroactively applied,according to the affidavit.

2. It is apparent,too, that the kckages have not been tested in p mgnner which protects the public safety for tra:$ sport on railway or highway ,to prove that they are are adequate to maintpn the fuels' integrity. ( E rhudy commissioned by NRC occasioned a reco=mendation from REA, Colria mbus,0. . , that' the NRC critsrion for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, Dec.1982.

be raised to a testing of the packgges to withstand 1,600

3. The consequences of a railroad exp1'osion of TNT are not analysed in a way(FSAR fdcuE 3.5 to foresee the effects from the outdoor location and the surrounding hazards. i IseTEe structures between the R.R. and: the fuel piles would be thrown onto the  :

fuel containers and the tangled mass would be thrown against other tanks and s l' structures ending up at the wall of the turbgne building. Il Since the turbine f structure is not a safety one,its wall and roof would be collapsed onto the mass. f f

'III. Two 220 KV towers and wires would be part of the crushing load on the fuel. [

E.The contents of the iron workers! shop, the chemical staff building and thehydrogenbottlestoragewouldbegroundupandpiledwghthefuelagainst f the turbine building and adjacent surfaces in a fire fed welding fuel, chemicals,

-hydrogen and other fuels or explosives. Cushioning material would burn. L The conditions lis ted in N.Ke'tzlach's affidavit would be met (p.2,3.) (a). Rod cladding oME and separation destroyed with grinding , cutting and pulverizing of the pellets. ,

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-no Q@ (b) Uranium dioride would be dissolved by nitric acidfar or other above acids the refrom the t

q.o destroyed structures. Radioactive sterial in massive quantities woulplation be dis- l gg charged into the air and water bringing a severe threat to the environnent and sn u og the public hea,Jth and safety. The force of theRR exp1bsion would be considera1y

1. f 7 higher than the measured d6signhNiguj{d{M fuel storage site,only 350'-4Nr'oaEom ra .

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4. Until protection from the consequences above are previded,no fuel should be shipped to the site.' In addition NRC Inspection 50-352/84-02 (p3,#4}and 84-03 andd84-01 ( p.4 # 6) cite deficiercies in monitoring equipment and personnel which must be rectified before fuel is shipped.

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Cc Judges Brenner,C&ltr, Morris N+- 8---

,NRC Staff, Appeal Panel,'

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3. Training and Qualification program l The inspector reviewed the training and qualification program for the ,

,, health physics / chemistry technicians. The technicians'are required to 1

?, complete a nine day course which covers basic mathematics, chemistry, and physics prior to entry into a 16 week initial technician training course.

The inspector reviewed the initial technician training course syllabus and the examinations of selected individuals. The inspector noted that the normal progression path for a technician is from assistant technician to technician "C" to technician "B" to technician "A." The total time re-quired for progression to technician "A" is 60 months. The inspector also noted that the licensee was rotating technicians through the licensee's other operating nuclear power station for practical factor training. The inspector discussed technician qualification with respect to Regulatory Guide 1.8, " Personnel Selection and Training" which references ANSI N18.1,

" Selection and Training of Nuclear Power Plant Personnel" with licensee personnel. _The licensee stated that the ANSI N18.1 requirements would be met through the use of ANSI qualified contractor technicians. The inspec- l tor also reviewed the qualifications and education of the senior chemist and support chemist. Both of these individuals meet the ANSI N18.1 re-quirements. The inspector stated that this area will be reviewed at a later date after further staffing has taken place.

4. Facilities and Equipment The inspector toured the faciilty including the chemical laboratories and counting room, water treatrent olant and laboratory, various in plant sampling systems,. liquid effluent monitors, airborne effluent monitors and selected ventilation systems. The inspector noted that the licensee's chenistry laboratories, although completed, were not yet occupied and no _ _

instrumentation had been installed. Also,.no instrumentation had been installed in the licensee's ccunting room. At the present time, the li-censee is taking delivery of laboratory supplies and equipment. The 11-censee's sampling systems a a not yet all completed and operational. In i addition, the. process and efflygnt. radiation. monitors are not completely installed and operational. The inspector discussed laboretory and count-t- . ing room egli pent installation with the licensee. The licensee stated l' V that he would_ attempt to have the chemistry laboratory operational by approximately Anril 1984_ and the counting room operational by June,1984. -----

! The inspectordso discussed pr5 cess and effluent ractation inonitor calf-

'_ bration with the licensee as well as air cleaning ventilation system test-ing. The inspector stated that these areas would again be examined during

a subsequent inspection. ,

5. Plansanbriceddres 5 .N The 5n:pector discussed procedures with the licensee. The licensee had.

' written,rpproximately twenty Sh emical analysis procedures. The inspector

'noted that most of the pro'cedsres in areas such as sampling, ins.trument p.,'"

l calibration, radiation monitor calibration, and ventilation system testing v.

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pgg. 2, uq 95.5/8 V-cI The licensee provided the inspector with its contractor's reports of analyses of various environmental media collected from its sampling stations. These reports indicated that the licensee has met its commit-ments as stated in the DES-OL, NUREG-0974, June 1983.

The inspector examined selected environmental monitoring stations inclu-ding water sampling stations, air samplers for iodines and particualtes, and TLDs for direct radiation measurement. All equipment at these stations was operational at the time of the inspection. The inspector reviewed procedures and records for calibration and maintenance of the air samplers and vacuum gauges, and found that these calibrations were per-formed regularly and on schedule.

5. Meteorological Monitoring The inspector examined the licensee's meteorological monitoring system, including the primary and backup meteorological towers, the recorder charts in the equipment houses at each tower, and the digital read-outs, charts, and computerized print-out in the control room. The inspector noted that two separate pieces of meterological tower data were identi-cally labelled as WS6, and that no data were labelled WS5. The licensee stated that the computer had only recently become operational, and that this would be corrected at or before the time of the next system calibra-tion. A second computerized print-out is to be installed in the Technical Support Center.

The licensee stated that new meteorological monitoring equipment had recently been installed, and that new procedures are being written that will better reflect the new meteorological monitoring equipment. The inspector stated that these procedures will be reviewed during a subse-quent inspection in this area (352/84-03-02; 353/84-01-02).

6. -Training The inspector' discussed with the licensee its training program for personnel involved with the LGS radiological environmental monitoring and

/ meteorological monitoring programs. The procedure relevant to this training was reviewed:

1 NES 2.0 " Procedure for Specification of Qualifications of Personnel in l Radiological Environmental Monitoring and Indoctrination and

!. Training"

The inspector noted that certain individuals associated with the LGS l radiological environmental monitoring and meteorological monitoring - l l programs had not received the training required by this procedure. The licensee stated that this procedure currently is. applicable only to its

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Peach Bottom Atomic power Station. and therefore that the training program is not required for personnel involved solely with the Limerick Generating Station. The inspector stated that this and other NES procedures would l require revisions ~to indicate their applicability to LGS when the' facility l a