ML19323C067
| ML19323C067 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/28/1980 |
| From: | Miller D, Tupper S MILLER, D.S., SENSIBLE MAINE POWER, TUPPER, BRADLEY & MCDOWELL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8005140622 | |
| Download: ML19323C067 (9) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
)
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 Capacity
)
Applicant. )
and Systems; Compaction)
INTERVENOR'S SPECIFIC CONTENTIONS Pursuant to 10 CFR 82.714(b), Intervenor Sensible Maine Power propounds the following Specific Contentions.
1 Neither Applicant nor Staff has adequc;ely considered alternatives to the proposed disassembly / reassembly / compaction scheme, (hereinafter "d/r/c scheme").
Alternatives which should be considered are set forth below. Those lettered (a) through (5) will avoid altogether the potential risks and adverse consequen-ces of:I the increased liquid, gaseous and heat emissions ' refer-enced in Contention 2; the Class 9 or other severe reac, tor acci-dent situations referenced in Contention 3; the occupational ex-posure or' health'and safety considerations referenced in Conten-tion 5; the opernting procedures deficiencies referenced in Con-tention 6i the materials integrity or deterioration hazards.ref-erenced in Contention 7; the failures due to external traumatic I While the Commission's regulations may assert that Contentions should stand alone for pleading purposes, the instant incorpora-tion is made for che sake of brevity, to avoid verbatim reitera-tion of the Contentions cited; further, the issues there developed constitute sufficientt reasons to consider the alternatives here suggested..whether or not the cited Contentions achieve indepen-dont validity.
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causes.re(erenced in Contentions 8an19; handling accidents refer-enced in Contention IOP, the long-term storage consequences refer-enced in Contention 11 (regarding compaction only); the loss of water or loss of cooling function from internal failures refer.
enced in Contention 12; and the impairment of coolant-function or flow characteristics referenced in Contention 13 The alterna-tives lettered (h) through (1) would significantly postpone, for a period 'of at least several years, any necessity of enduring the risks and' consequences referenced immediately above.
The alternatives which should be considered are:
(a)
The Construction of another, new or additional spent fuel 1
pool onsite; (b)
The physical expansion or enlargement 6f the existing spent fuel pool;'
(c)
The construction of a new spent' fuel pool offsite; (d)
The contracting out or transshipment of spent fuel for storage at-another power plant, or commercial or government-owned spent fual storage facility, current information of the Commission indicating that the same will be availgble before 1983; (e)
Other alternative storage opportunities, whether govern-mental or' private, currently under study, analysis or review; T
( f)
Conversion of facility enabling it to burn coal, oil, gas, or other non-nuclear fuel; (g)
Closing or shutting down the facility; (h)
Derating the' facility, that is, reducing plant output and thereby reducing'the generation _of spent fuel; (1)
Extendibg fuel burnup times and thoreby reducing the gen-eration of spent fuel;
(j)
The purchase of less expensive electrical power from l
readily available sources, (E.g., The Hon. Rene Levesque, Prime Minister of Quebec, recently visited Maine seeking a market for less expensive Canadian hydroelectric power);
(k)
Development or utilization of hydroelectric capability at existing damsites within the State of Maine; and (1)
Development of other power sources.
2 Neither Applicant nor Staff has adequately analyzed the probability or effects of the liquid and gaseous radioactive emissions likely to result from the proposed d/r/c scheme, nor i
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, Strontium 90, and Tritium.. Further, the adverse environmental impact of additional heat likely to be discharged in the vicinity of the plant as a re-sult of the proposed d/r/c scheme has not been adequately analyzed by Applicant or Staff,.and such failures violate NEPA.
Such emissions are rendered more likely by the significantly increased handling and rehandling of spent fuel, higher concentra-tions of spent fuel, and the greater decay heat generated by spent fuel, in the proposed d/r/ccache;ne.
3.
Applicant's proposal does not ensure that spent fuel pool conditions will be maintained within regulatory or design limits in the event of a Class 9 erxdther extreme accident.in'.the main.re-actor..:Ngither'Applicadt;nor:Staffchus,ishown that'in auch case the electrical. systensprecoling: systems,..andglant personnel will func-tion :sufficiently.,uallito tensureKcontinued safe operation of the -
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spent: fuehpool.
Further, and given-greater amounts of more: dense-ly packed;. fuel,.all adverse consequpnges will.be worsened by Appli-cant's schemeLincluding;cl&dding firea. anql spent fuel explosions.
-4.
The instant application is defective for the following reasons:2 (a)
Said application is premature in that no need for the im-mediate approval of the d/r/c scheme has been shown.
Applicant will have no need for the increased storage capacity for the next four years, and other circumstances are likely to obviate the need for Applicant's. proposed amendment; (b)
Applicant has failed to submit to the Commission a speci,
fic and detailed description ands analysis of the operating proce-dures to govern itp d/r/c scheme; within any reasonable due process framework'auch statement must be furnished by Applicant before its proposal can be considered; and (c)
Applicant's failure to furnish said specific and detailed statement'of operating procedures, and the Commission's consequent failure to analyte the same, violate NEPA, and severely disadvantage Intervonor in the formulation and preparation of Specific Conten-tions to the point of working a denial of due process against Inter-venor and its members.
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5.
Applicant has', failed to demonstrate that occupational expo-
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sures resultingufros'the# proposed d/r/c scheme,'will be kept within J 3 ;,
re gulat!ory; limits; workers wi11' receive more than allowable dosages 2The assertian of these defects in the instant application is nei-ther to enumerate allLdefects in the application nor to isive In-tervonor's rights of objection to others; rather, these particular i
defects'are raisedcaow-inforder to make a complete record upon the same.
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I from increased handling of fuel assemblies.
This contention refers to the handling of normal as well as leaking or damaged fuel pins, both during fuel assembly, disassembly and reassembly, and over the entire useful 11I' -
spent fuel pool.
L 6.
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 detailed de-scription'of management, personnel and technical practices and guideline 4 concerning the hiring, testing, training and supervi-sion of all personnel to be engaged in the' d/r/c scheme.
The need for the same is especially critical where insuflici-ently trained, untrained, unqualified or improperly supervised per-sonnel have been engaged in potentially hazardous activities in t
the recent past: E.g.,
" Inspection 50-309/80-04" reveals the fol-lowing failures in Applicant'aroperation of its' spent fuel pool:
February 11, 1980, worker knocked into pool; February 18, 1980, improper positioning of fuel assembly; February 20, 1980, inadver-tent removal of CEI. from fuel assembly.
7.
Applicant has not adequately considered or analyzed the materials' deterioration or failkres 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 scheeme.
The adverse effects include deterioration of' fuel? cladding as a result 4
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of exposure to" increased' decay heat and radiation levels during extended periods' of pool storage; loss of r.aterials integrity of storade racks;and pool liner as a result of exposure tn higher levels ~of'rsdiation over ^ extended periods; and deterioration of c
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concrete pool structure as a result of exposure to increased heat over extended periods.
8.
Applicant has not adequately considered or analyzed the effects of extreme seismic phenomena upon the modified spent fuel l
pool and its contents.
Such analysis should demonstrate the sels-mic/ traumatic durability.tnd tolerance of fuel pins, fuel assem.
blies, storage racks, pool liner, and concrete structure.
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 facility, was the site of an earthquake registering 4.1 on the Richter Scale in early April, 1979.
9.
Applicant has not adequately considered or analyzed the effects of an aircraft crash into the spent fuel pool from the ad-jacent Wiscasset Airport, less than a mile from facility.
- Further, said airport has recently -been undergoing a process of enlargement both in volume of traffic handled and in size of aircraft accomo-dated.
In addition to the structures, devices and components noted immediately above, (Contention 8), here the traumatic tolerance of the spent fuel pool enclosure must_also be considered.
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 creatad by its prr, posed d/r/c scheme.
Given higher concentrations of fuel in l
the sient fuel pool, such accident is likely to yield a greater geners. tion of heat and radioe ;civity.
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11.
Neither Staff nor Applicant has adequately considered or analyzed 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.
Further, insofar as Applicant fails to consider the costs.of long-term
- operation and maintenance si tne 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 cons'idered 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 effects of failuree 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 changes in coolant flow characteristics in the spent fuel pool under its proposed d/r/c 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.
Neither Applicant nor Staff has shown that persons in the facility area will be safely evacuated in a timely manner in the event such action proves necessary.
An adequate means of giving I
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prompt public alarm or notice, and a safe, workable and effective evacuation plan, are essential, given the increased likelihood of accidents under Applicant's d/r/c scheme and the worsened adverse consequences resulting therefrom.
Respectfully submitted, A
/Y Ya'v'id 5 tee Miller Co-Counsel for Intervenor 213 Morgan Street, N. W.
Washington, D. C.
20001 Telephone:(202)638-0483 I 8/
i Stanley / Tu'pperip#er DSM)
Co-Counsel for Intervenor T uppe r &
Bradley 102 Townsend Avenue Boothbay Harbor, ME 04538 Telephone:(207)633-4000 CERTIFICATE OF SERVICE I hereby certify that I have mailed copies of the foregoing "Intervenor's Specific Contentions", first class. regular mail postage prepaid to the following persons and offices at' the ad-dresses stated, this 28th day of April, 1980.-
J
- ' avid Santee Miller D
Co-Counsel for Intervenor Office of the Executive' Legal Director U. S. Nuclear Regulatory Commission Washington,
.D.
C. '20555 l
Robert M. Lazo, Esquire, Chairman l
Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.
C.
20555 __
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Dr. Cadet H. Hand, Jr.
Director, Bodega Marine Laboratory University of California P.
O.
Box 247 Bodega Bay, CA 94923 Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D.
C.
20555 Thomas G. Dignan, Jr., Esq.,
and R. K. Gad,' III, Esq.
Ropes &
Gray 225 Franklin Street
- Boston, MA 02110 John M. R'._Paterson, Esq.
Deputy Attorney General Office of the Atty. Gnl.
State Eouae
- Augusta, ME 04333 4
6.
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