ML20009G826
| ML20009G826 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 07/27/1981 |
| From: | Miller D MILLER, D.S., SENSIBLE MAINE POWER |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8108050101 | |
| Download: ML20009G826 (8) | |
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Cv to In the Matter of
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Docket No. 50-309
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MAINE YANKEE ATOMIC POWER COMPANY,
)
(To Increase and Modify
)
(Maine Yankee Atomic Power Station), )
Spent Fuel Pool Storage
)
Applicant. )
and Systems; Compaction)
INTERVENOR'S SPECIFIC CONTENTIONS Pursuant to 10 CFR 92.714(b), Intervenor Sensible Maine Power propounds the following Specific Contentions.
1 Neither Maine Yankee, (" Applicant"), nor the NRC Staff,
(" Staff"), has adequately considered environmentally preferable alternatives to Applicant's proposed disassembly / reassembly /com-pactionschleme, ("d/r/c scheme").
Alternatives a - g would avoid or obviate the risks and consequences set forth in the remaining i'
contentions; alternatives h and i would postpone the need for the proposed d/r/c scheme.
The alternatives which should be considered are:
i (a)
The construction of another, new or additional spent fuel pool onsite; (b)
The physical expansion or enlargement of the existing l
spent fuel pool; (c)
The construction of a new spent fuel pool offsite; (d)
The contracting out or transshipment of spent fuel for 8108050101 810727
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DR ADOCK 05000309 PDR I
i
storage at another power plant, or commercial or government-owned spent fuel storage facility, curront information from the Commission indicating that the same will be available by 1984; y
(e)
The development of dry cask storage capability;
( f)
The conversion of the facility enabling it to burn coal, oil, gas, Or other non-nuclear fuel; (g)
Closing or chutting down the facility when the spent fuel pool reaches the currently-approved storage level, and drawing power from: (1) Hydro-Quebec; (ii) Hydroelectric capability under development at' existing damsites within the State of Maine; and (iii) Purchase of power from Point Lepreau nuclear facility in New Brunswick, a nuclear generating station of.about 1,000 magawatts due on line in late 1982; (h)~ Derating the facility, that is, reducing plant output and thereby reducing the generation of-spent fuel; and (1)
Extending fuel burnup times and thereby retarding the rate of the generation of spent fuel.
2 Neither Applicant nor Staff has adequately analyzed the probability or effects of the liquid and gaseous radioactive emis-sions likely to result from the proposed d/r/c scheme, nor has there been any showing that adverse environmental effects from the same will be kept within regulatory limits.
Harmful emissions most likely to occur are Iodine 131, Cesium 137, Stror tum 90 and Tri-tium.
Fur ther, the adverse environmental impact of additional heat likely to be discharged in the vicinity of the plant as a result of the proposed d/r/c scheme has not been adequately analyzed, which failures violate NEPA.
These emissions are rendered more likely by - -.. -
4 the significantly increased handling and rehandlin'g of spent fuel, higher concentrations of spent fuel, and the greater decay heat gen-erated by spent fuel, in Applicant's proposed d/r/c scheme.
3.
Applicant's proposal does not ensure that spent fuel pool a
conditions will be maintained within regulatory or design limite in the event of a Class 9 or other extreme accident in the main reactor.
Neither Applicant nor Staff has shown that in such case the electri-cal systems, colling systems, and plant personnel will function auf-ficiently well to ensure continued safe operation of the spent fuel pool.
Further, cnd given greater amounts of more densely t acked fuel stored in a two-tier configuration closer to the surface of the spent fuel pool, all adverse consequences will be worsened by Appli-cant's proposed scheme, including especially the exothermic reaction of the spent fuel upon loss of coolant.
4.
The instant apllication is defective as premature, in that no need for the immediate approval of the d/r/c scheme has been I
shown.
Upon its own current estimates, Applicant will have no need to increase storage for at least another three years, and other cir-cumstancss are likely to obviate the need for Applicant's proposed amendment.
5.
Applicant has failed to demonstrate that occupational expo-sures resulting from its proposed d/r/c scheme will be kept within regulatory limits.
Workers will receive more than allowable dosages from increased handling of denser fuel assemblies.
This contention refers to the handling oi normal as well as leaking or damaged fuel pins, both during disassembly and reassembly, and over the entire.
useful life of the spent fuel pool.
6.
(a)
Applicant has not identified, described or analyzed the specific operating procedures to govern its d/r/c/ scheme.
Such statement of procedures should include a thorough and detall-ed description of management, personnel and technical practices, including guidelines concerning the hiring, testing, training and supervision of all personnel to be engaged in the d/r/c scheme.
The need for the same is especially critical where insuffici-ently trained, untrained, unqualified or improperly supervised per-sonnel have been engaged in potentially hazardous activities in tuo recent past:
E.g., " Inspection 50-309/80-04" reveals the following failures in Applicant's operation of its spent fuel pool: Fabruary 11, 1980, worker knocked into pool; February 18, 1980, improper po-sitioning of fuel assembly; February 20, 1980, inadvertent removal of CEA from fuel assembly.
(b)
Applicant's failure to furnish the above-described information in a timely manner (1) prohibits the Staff from a prop-er discharge of its duty under NEPA, and (ii) Severely prejudices Intervenor in the formulation and preparation of Specific Conten-tions to the point of working a denial of procedural due process against Intervonor and its members.
7.
Applicant has not demonstrated adequate assurance against materials deterioration or failures in materials integrity result-ing from the increased generation of heat and radioactivity in the spent fuel pool as a result of its proposed d/r/c scheme.
The ad-verse effects include deterioration of fuel cladding as a result of exposure to increased decay heat and radiation levels during extend-.
ed periods of pool storage; loss of materials integrity of storage racks and pool liner as a result of exposure to higher levels of radiation over extended periods; and deterioration of concrete pool structure as a result of exposure to increased heat over extended periods.
8.
Applicant has not presented cufficient assurances against adverse effects from entrene seismic phenomena upon its modified spent fuel storage.
Such analysis should demonstrate the seismic /
traumatic durcoility and tolerance of fuel pins, fuel assemblies, storage racks, pool liner and concrete structure under the changed cances, specifically, a greater weight of more densely packed 4
fuel.
Such inquiry and showing by Applicant are especially critical where nearby geophysic faults and seismic phenomena were not fully known, recognized or appreciated until relatively recently - i.e.,
the "Robinhood Fault", within less than one-half mile of the facil-ity, was the site of an earthquaka registering 4.1 on the Richter 3cale in early April, 1979.
Applicant must show that its proposed d/r/c scheme, including especially new storage racks and the proposed double-tier configura-tion of the same, are designed to and can withstand significant seismic phenomena.
9.
Applicant has not presented adequate assurances that the new configuration of fuel storage in its proposed scheme would with-stand an aircraft crash into the spent fuel pool from the adjacent Wiscasset Airport, less than a mile from Applicant 's facility.
Said airport has recently been undergoing a process of enlargement both in volume of traffic handled and in size of aircraf t accomodated. _ _ _ _
d Applicant's proposed two-tier configuration of spent fuel stor-age brings stored fuel much nearer to the surface of the spent fuel pool, (to within ten feet or less), reduces the protective water-cover, and thus increases the probability of harm in the event of such incident.
Further, the higher volume of more densely packed fuel proposed under Applicant's d/r/c scheme significantly worsens the consequences of such event.
The durability of fuel assemblies, storage racks, and pool containment structure should be demonstrat-ed. by Applicant.
10 Applicant has not sufficiently considered or analyzed the consequences of an accident involving the dropping of a fuel assem-
~
bly or fuel cask in the pool area under the conditions created by its proposed d/r/c scheme.
Given the modified, two-tier storage configuration reducing protective water-cover, and given also the higher concentration of fuel in the spent fuel pool, such accident is more' likely to yield a greater generation of heat and radioacti-vity.
11.
Neither Staff nor Applicant has adequately considered or analyze
- the long-term health, safety and environmental effects of the proposed d/r/c scheme with respect to such periods of time over which the spent fuel pool is likely to be used beyond the expira-tion of Applicant's operating license.
(b)' Further, insofar as Applicant fails to consider the costs of long-term operation and maintenance of the spent fuel pool beyond the expiration of its license, such failure invalidates all cost-benefit analyses relative to the proposed scheme.
12 Applicant has not adequately considered or analyzed the likelihood or consequences of a possible loss of cooling capacity _.
or function in the spent fuel pool under the conditions presented by its proposed d/r/c scheme.
More particularly, Applicant has not sufficiently considered or analyzed the offects of failures of one or more pumps, heat exchangers, transmission lines, or the loss of coolant.
Applicant has not sufficiently shown or analyzed the heat and radioactivity likely to be generated in such cases, nor its ability to control the same within regulatory limits.
13.
Applicant has not adequately considered or analyzed chan-ges in coolant flow characteristics in the spent fuel pool under its proposed scheme.
More particularly, Applicant has not shown that the cooling system will be adequate to prevent " hot spots",
possible boiling, or other uncontrolled high temperature phenomena.
14.
Applicant's proposed scheme significantly teorsens the con-sequences from a loss of coolant or loss of cooling function event because of the greater aass of more concentrated fuel being stored.
In its two-tier storage configuration, Applicant 's scheme also dim-inishes the time period between loss of cooling function and exo-thermic reaction in the spent fuel pool.
Applicant has not shown that the public warning system and the evacuation plan currently in effect are sufficient to protect the safety, health and welfare of persons within an area likely to be adversely affected and requiring prompt evacuation.
Respectfully submitted, David Santee Miller Counsel for Intervenor SMP 213 Morgan Street, N. W.
Washington, D. C.
20001 Telephone: (202) 538-0483
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o a,
CERTIFICATE OF FILING AND SERVICE I hereby certify that I have filed and served the foregoing "Intervenor's Specific Contentions": (1) By mailing the original and twenty (20) copies thereof to U. S. Nuclear Regulatory Commis-sion, Docketing & Service Branch, Washington, D. C. 20555, and (2)
By t. ~ ng copies of the same to the following persons and offices at the addrecaes stated, first class recular mail postage prepaid, this 27th day of July, 1()81 :
Robert M. Lazo, Esquire, Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Cadet H. Hand, Jr.
Director, Bodega Marine Laboratory University of Criifornia P. O. Box 247 Bodega Bay, CA' 94923 Peter A. Morris, Esquire Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Thomas G. Dignan, Jr., Esquire and R. K. Gad, III, Esquire Ropes & Gray 225 Franklin Street Boston, MA 02110 Rufus Brown, Esquire Office of Attorney General State House augusta, ME 04333 Davic Santee Miller Counsel for Intervenor SMP