ML20073P991

Petition of Sassafras Audubon Soc of South Central in to Intervene in OL Proceeding,Listing Contentions

ML20073P991
Person / Time
Site:	Marble Hill
Issue date:	04/16/1983
From:	Lynch M AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
NUDOCS 8304280013
Download: ML20073P991 (5)

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, TO THE UNITED STATES NUCLEAR REGUIAT . r - .N i*

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FROM THE SASSAFRAS AUDUBON SCCIETY OF SCUIH CENIRiL

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The Sassafras Audubon Society of South Central Indiana hereby petitions the United States liuclear Eegulatory Commission (NRC) for the right to intervene in the Operat-ing License Proceeding of Marble Hill Nuclear Generating Station Units 1 and 2. The

, membership of the Society lives within the service area of Public Service Indiana.

(PSI), the applicant for the operating license, ard as ratepayers have a financial interest in whether or how well it will operate, as well as a deep concern for the public health and safety were it to operate.

II Sassafraa Audubon's interest in Marble Hill is well established. In 1979, the Society petitioned the NRC for a public hearing at a timely point in the licensing process, on significant issues not considered at the construction license proceed-ing. The Society's petition was denied on a divided vote of the Comnission in March 1980.

Sassafras Audubon petitioned the TnMann Public Service Comission (IPSC) in March 1982 for a public hearing on Marble Hill. This was followed in April 1982 by a pe-l tition for a Hearing by the Office of Utility Consumer Counselor of Indiana, with l the IPSC granting a Hearing on the 1) NEED and 2) COST of Marble Hill. The Hear-1 ing was held from October 11t-26,1982, with the public interest represented by the Utility Consumer Counselor of Lh.

l III It was established at the Hearing that there was no need for Marble Hill and that Public Service Indiana should have recognized that fact as early as 1977 and at the latest by 1979. It was also established by the Utility Consumer Counselor of Indiana l that there was no need for Gibson 5, a large coal-fired unit brought on line in October 1982 by. PSI. Hoosier Energy plans to bring another large coal-fired unit at Merom into operation in the su=ner of 1983 adding to the excessive over-capacity l of power in Indiana. Other utilities in the ECAR Region, the power grid to which l PSI and Hocsier Energy belong, have also over-constructed, and like TVA are having l difficulty finding a mrket for their excess power. There is no narket for Farble l Hill's power in the time frame of it.s projected completion dates, ror in the for-seeable future.

8304280013 830416 DR ADOCK 05000546 I

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IV Witnesses at the October 1982 Hearing on Marble Hill vere divided as to the potential cost. Energy Systems Research Group, Inc. (ESRG), the fim hired by the Office of Utility Consumer Counselor en behalf of the public interest, estinated $8-10 billion and recommended immediate cancellation of the Marble Hill Project on the basis of

~ this excessive cost and the fact that there was no need for its power. National Eco-nomic Research Associates, Inc. (IERA), the firm hired by the IPSC, supported PSI's estimate 'of $5.1 billion, but with the reservation that if "significant uncertainties" such as implementation of new safety regulations or other construction delays raised the cost as much as 20-h05, that the Marble Hill Project should be canceled. IERA also recommended another " Independent Audit" be made of the cest, which is now in progress.

V Intervencrs, ratepayers of the~ PSI service area, and citizens of Indiana in general, are concerned not only with the excessive cost of constructing Parble Hill Units 1

- and 2, but also, with the potentia 13y excessive cost of operating, maintaining, and deco: r.issioning Ihrble Hill, including the full. cost .of the regu3ntory process. Will the power produced by Marble Hill during its active life pay for these costs?

VI The contentions which Sassafras Audubon would nice as intervenor in the Marble Hill Operating License Proceeding have firancial and public health and safety implications of the. highest consequence. Each contention is discussed in some detail to estab-lish the validity of our interest:

A Fracture Tcughness of Marble Hill 1 and 2 Containnents Neutron radiation " embrittlement" of react'or pressure vessels of RWs is oc-curring more rapidly than expected, making them susceptible to fracture and loss-of-coolant accidents and reducing their capacity and life-expectancy.,

Enclosure 6 of the EC "Accentance Review of Application for Ooerating License for Marble Hill Units 1 and 2" _ is concerned with " Fracture Prevention of Con-tainment Pressure Boundary" (6-2) which states:

'"Je have determined that the fracture toughness requirements con-tained in ASIE Code editions and addenda typical of those used in the design of the Marble Hin 1 and 2 containments nay not ensure conpliance uith GDC 51 for n'1 areas of the containment pressure boundary."

The 2C further notes that components of the containnent system which are load , bear-ing and provide a pressure boundary in the perfor ance of the contairnent function, may have materials uhich ud11 not have been fracture toughness tested or udll have been inappropriately tested.

We seek nore than " reasonable assurance" that whatever the metallurgical characteri-zation of the materials, that the Farble Hill 1 and 2 reactor containnent pressure boundary vin behave in'a nonbrittic nanner, and that the probability of rapidly propogating fracture will be mininized by adherence to certain technical specifica-

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tions. Rather, ue seek an evaluation of the materials used in the Marble Hill re- l actor pressure vessel in terra of the effect of neutron radiation and lead rates on similnv materials in operating reactors, after 5, lo, 15 years of operation? What limits have had to be placed on operating levels uith t he? Hou frequent inspec-tion to test for progressive cmbrittlement?

Fressurized Vater Reactor Steam Generator Tube Integrity, and, Vibration and Water Hamer Problens in Westirghouse Model D-Series Steam Generators

• The MlC Stean Generator Status Report of February 1982 acknowledges that no effective solution has been found for preventien of steam generator tube degra-dation, an unresolved safety issue of the Connission. The OiC is critical of the fact that manufacturers of stean generators have sought only technclogical or chemical " fixes" to the problem, whereas a basic systens approach is needed.

Marble Hill's steam generators v41' be susceptible to steam generator tube deg-radation, with all that implies, arxi with the possibility of it cecurring within a few years of operation.

I*arble E477 may have additional stean generater problers, for ths Westirghouse D-Series Models to be installed in Farble Hill have had a problem of excessive vibration which can bpair steam generator tube integrity, and have had to be operated at reduced levels..

The McGuire Nuclear Flant is to have a " technological fM installed (manifolf, in October 1983, but whether that will "selve" the vibration problem, or solve that problem while creating another one such as sludge build-up, vill only be kncun with time.

The Conanche Peak, Byron, and Marble Hill nuclear plants wol have similar D-Series ~ Models (D-h and D-5) and are expected to require " technological fixes" designed specifically for these models. How long ud11 it take to design, install, test and/or determine the reliability of the "fix"?

Water ha=er occurred in the D-h steam generatcr of the Kroko, Yugoslavia plant during testing. While the EC has issued a IIUEEG declaring the water hanner problem resolved on the basis of a Westinghcase " solution", there is a question as to whether there has been sufficient tests.ng of the " solution" to declare it resolved. On that basis, it should be included as a possible prcblem at Marble Hill.

Seismic and D-manic Qualification of Safety-Related Electrical Ecuirnent and Construction at Harble Hill Safety-related electrical construction was halted at Harble Hill in Jan':ary 1983 in response to allegations of a welding inspector that faulty velds and failure te raintain documentation on critical raterials raised doubts about the plant's structural soundness.

A Confir .atory Action Letter (CAL) vas sent to PSI by the : hic on February 2, 1983 which gives the public so e informatien en the type and depth of the prob-l 1 cms v'erified by the EC during the special inspection which they conducted from January 2h-28,1983, but the Report on the results of the inspection has not been issued as yet.

The CAL mentions that "the stop work encompasses fabrication and installntien

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.? o of electrical auxiliary steel; cable tray and conduit hangers; and cable tray and exposed conduit." We are particularly concerned uith the vord " fabrication" for it implies that the quality of the materials used in the electrical work may be unkncun.

Mr. M. J. Landers, the welding inspector who rade the allegations concerning the quality of the electrical work, alleged that much of the buildirg =aterials used were not documented, and that the situation cannot be corrected uithout at least half of the conpleted electrical work being replaced.

The public does not know at this point what corrective action will be required' by the EC to ensure the soundness of electrical constr=' ion at Farble Hill.

Unatever is required, the intervenors should have the opportunity at the Operat-ing License Proceeding to question and determine as far as possible the ade-quacy of the solution and the quality ad soundness of Marble Hill's electrical system.

Seisnic Design Criteria Cassafras audubon's concern for the seismic design of Earble Hill is evidenced .

in a letter of June 21, 1982 to B. J. Youngblood, Chief, Licensing Branch No.1, .

Division of Licensing, E . This concern is based en recent research, the identification by the U. S. Geological Survey of the deep fracture that cauced the New Itdrid earthquakes of 1811 and 1812, some 55 miles long in a northeast dire.ction and uith shifts of 3000 feet in the rock for-ation more than a mile underground, and the warning by seismologists that the Neu Eadrid rift repre-sents a high risk earthquake area where another rajor quake is overdue. The 1cwer Chio River Valley has been cited as a zone of potentially heavy earth-quake damage.

L. L. Kintner, in his reply on behalf of B. J. Youngblood, mentions that the EC did not see, currently, new information that would adversely impact the seismic design input for the Harble Hill site, and did not foresee a revision

-to the requirementa for Marble Hill at that time.

The NRC's Operating License Safety Evaluation Report (OL SER) may reflect re-cent research and re-evaluation of the earthquake potential of the Ohio River Valley, Wabash River Valley, and New Madrid areas. Nevertheless, Mr. Kintner's reply to our concerns was inadequate and we ask that the seismic design of Farble Hill be a content'.on of the Operating License Proceeding.

i Class 9 and Core-Melt Accidents The March 1979 core-melt accident at Three Mile Island-2 (TMI-2) dispelled the opinion that partial core-melt and Class 9 accidents were of such remote proba-bility that they need not enter into licensing decirions.

Defense-in-depth or the redundancy concept of nuclear design is an incompl te answer to nuclear safety and does not insure protection from systens interaction-type accidents where nan is part of T,he system and human error ray contribute to l the accident.

A recent study of the probability of core-melt accidents and their possible consequences must be part of the decision as to whether Marble Hill is an ac-ceptable risk and should be granted an operating license.

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Decomissioning of Farble Hill and Discosal of Farble Hill's Radicactive Wastes Assurances have been given the public that the technology for decomissioning aged comercial nuclest reactors is present, and the ecst-estimates of decom-missioning large reactors hase been modest. No aged, large-scale co=ercial reactor, hcwever, has been decomissioned, nor ultimate disposal been made of its radioactive wastes.

- We contend that dismantling ofalarge-scale, aged, nuclear reactor with return of the plant site to its former condition, with final disposal of the radioactive wastes produced during its operation an integral part of the decommissioning process, will be far more difficult and many times more costly than current estimates.

The scientific kncwledge necessary for the acceptable deco =issioning of nuclear plants and particularly for the firal disposal of their radioactive wastes, is inadequate, and there is still insufficient recognition of the social issues involved which will deter the process.

. .Martle Hill will have a tag-end priority for space in a Federal Repository.

The p2espect i.M fer Mr.rhls Hill to be a higblevel, radicsotive. waste storage site not e.nly d9 ring ite operating life, but for an indetermirate period after-wr.rds . Mhen FSI was granted a construction pernit, a total of one and two-thinis cores, appruimately 3h0 spent fuel assemblies was to be stored on site for any length of time. The prosp6ct now undcr nn operating license would be for all the spect fuel produced during the activa life of the plant to be stored on site. The implicatiens of this change must te addressed at the Cperation Licecse Proceeding.

Emergency Planning and Evacuation THI-2 denonstrated the necessity of emergency planning not only for the imned-iate vicinity of the plant, but for varying distances depending on meteorologi-cal conditions. An emergency pLsn for Marble Hill should be available for public review prior to the Operating License Proceeding,with its evaluation-l.

part of the proceeding. Final details should be worked out and tested prior to operation of F.arble Hill.

VII The NRC indicated in their Accentance Review of Arplication for Ocerating License for Marble Hill Units No.1 and 2 that substantive ceficiencies existed in PSI's application reports and requested additional information in order to complete

! their SER. Will the additional information requested from PSI be made available

to the public as appendices to the FSAR, ER-OL, etc.? This infor ation is essen-l tial to develeping various contentions, e.g. seismic qualification of safety-re-l~

1ated equipment.

vours sincerely

() > bf 4ary Pat Lynch d/

President, Sassafras Audubon Society 605 South Fess Avenue, Apt. 6 Bloonington, Indiana b'Th01 l

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