ML19351D143
| ML19351D143 | |
| Person / Time | |
|---|---|
| Site: | 07002909 |
| Issue date: | 10/01/1980 |
| From: | Mcphillips J SAFE ENERGY ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8010090071 | |
| Download: ML19351D143 (24) | |
Text
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9 D$6 UNITED STATES OF AMERICA gym 0 NUCLEAR REGULATORY COMMISSION t7,g g p p D
Otr s of g a W BEFORE THE ATOMIC SAFETY AND LICENSING BOARD D$ ids In the Mitter of S
APPLICATION OF WESTINGHOUSE S
ELECTRIC CORPORATION FOR A SPECIAL NUCLEAR MATERIAL S
LICENSE FOR THE ALABAMA DOCKET NO.
70 2909 NUCLEAR FUEL FABRICATION S
d, My $O PLANT (ANFFP) TO BE LO-CATED NEAR PRATTVILLE, S
ALABAMA S
SECOND SET PROPOSED VALID CONTENTIONS OF INTERVENOR SAFE ENERGY ALLIANCE OF CENTRAL ALABAMA, INC.
Comes now the Intervenor Safe Energy Alliance of Central Alabama (hereinafter "SEACA") and hereby offers as valid the
. following second set of contentions in connection with SEACA's petition to intervene in the above-captioned proceedings:
ATOMIC EXPLOSION RISK:
I.
The geometric qualities of the uranium to be processed at the Alabama Nuclear Fuel Fabrication Plant in Prattville, Alabama (hereinaf ter "the Plant") are such that, given the concurrence of several possible factors at one time, the Plant could have an explosion similar to that of an atomic bomb.
(Contrary to 10 1
C.F.R. 570.23 (a) (3) and (4)).
A.
Such an explosion could not occur at a nuclear reactor; therefore, the Plant is far more of a risk to the general A
pS 801009007f:
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populace of Central Alabama than any citizen thereof has pre-viously been lead to believe.
AUTHORITY TO POSSESS AND PROCESS 50,000 KILOGRAMS OF URANIUM-235 II.
The License Application of Westinghouse Electric Corporation for a Special Nuclear Material License for the Plant (hereinafter "the Application") requests authority to handle and use enrich uranium up to 5 w/o U-235 for a total of 50,000 kilograms, even though no other nuclear fuel plant in the United States has such a high enrichment authority and even though the same would be i
highly dangerous to the inhabitants of Central Alabama.
(Con-trary to 10 C.F.R. 570.23 (a) (3; and (4).
A.
This high level of enriched uranium authority suggests that the real purpose of the Plant may be for the manufacture of something other than nuclear fuel for nuclear reactors.
.B.
This high e. level of concentration would permit uranium to be used as " bomb-grade" level.
AUTHORITY TO POSSESS AND PROCESS 350 GRAMS OF URANIUM-235.
III.
The Application requests authority to hold 350 grams of Uranium 235 up to an unlimited percentage of_ Uranium 235 content, even as high as 100%, and such a concentration is without precedent in private industry and poses a serious risk to the inhabitants of Central Alabama.
(Contrary to 10 C.F.R. 570.23 (a) (3) and (4), and (6).
A.
The authority to use this high a level concentration for Urahium-235 would easily permit the processing of material for the development of a " neutron bomb."
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B.
Such a high concentration level would invite an unwarranted risk in Central Alabama for Saboteurs, agents provocateurs, geological upheavals, and natural accidents.
AUTHORITY TO HANDLE 5 GRAMS OF URANIUM-233 IV.
The Application requests authority to handle 5 grams of Uranium 233.
U-233 is a strong gamma emitter and must be handled remotely.
The Applicant fails to show any special handling procedures for U-233 and fails to state the purpose for which it will be used.
The risks to the plant workers outweigh'the benefits.
(Contrary to 10 C.F.R. S7 0. 23 (a) (3) and (4).
THE DOUBLE-CONTINGENCY PRINCIPLE V.
The double contingency principle, defined in the Application as the process design incorporating sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in normal operating procedures before a criticality accident is possible, in an inadequate safeguard.
(Contrary 10 C.F.R. S70. 23 (a) (3) and (4).
A.
The double contingency principle is not protective enough.
Witness Three Mile Island.
B.
Too many safety-violating contingencies could occur at one time.
The following four are examples of such contingencies:
1.
Uranium 235 could reach criticality because the amount present is more than it should be.
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2.
The geometry of Uranium 235 is complex and could move around and get into a configuration which would cause problems.
3.
An outside force, such as earthquake, tornsdo, or fire could do damage to the plant building or structure.
4.
The structure of the plant building can not possibl3 be perfect but, even if it were so, it might not be able to withstand the pressure of an internal explosion.
4 ALABAMA AS AN " AGREEMENT STATE" VI.
" Source Materials" and "By product Materials" of the Plant are to be regulated by the State of Alabama as "an agreement state" (See SS-8, Application), meaning that the State of Alabama will assume all responsibility and obligation for said materials,
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yet the State is untrained and unprepared to handle the-same and is assuming an enormous risk for its citizens in doing so.
(Contrary to 10 C.F.R. 570. 23 (a) (3) and (4)).
A.
The State of Alabama has no previous experience in handling such materials and is placing an unwarranted cost and health and safety risk on its taxpayers.
B.-
It is inconsistent for Westinghouse to assure Ala-bamians there is "no risk" in the Plant but refuse to assume any risk itself.
Yet that is what has happened when Alabama became an " agreement state."
SPENT FUEL-PLUTONIUM RISK-VII.
The Application (Section 3-2, page S-9) authorizes the receipt of "other uranium compounds-233, 238, into the SNM Building
_ plant area, and spent-fuel always contains a certain amount of the highly dangerous " plutonium", posing an unwarranted risk to the in-4
i habitenta of Csntral Alabama.
10 C.F.R.
S70.23 (c) (3) and (4),
MORE DEFINITION NEEDED AS TO RESPONSIBILITY FOR OPERATIONS VIII.
The Application (Section 4-1.2, page S-ll) states that the responsibility for all phases of operations, including safety and health protection, shall follow the usual lines of organizational authority.
Such a statement is vague, indefinate, and inadequately protective of the inhabitants of Central Alabama, especially in view of the high risk involved and the poor track record for safety of management in the nuclear energy field.
10 C.F.R.
S70. 23 (a) (3 ) and (4).
"ALARA" AS INVALID STANDARDS IX.
The "ALARA" or "As Low as Reasonably Acceptable" standard used in the Application is invalid, inaccurate, and much too subjective.,
A.
Moreover, Westinghouse's scientists aren't qualified to make that judgement, and as a result poor judgement will eventually threaten the health and safety of Alabamians.
10 C.F.R. 570. 23 (a) (3 ) and (4).
1 DRY PROCESS UNWORKABLE COMBINATION:
X.
The Plant conversion process would include both wet and dry components together, and a combination of the two together is both counter-productive and unsafe.
10 C.F.R. 570. 23 (a) (3 ) and (4).
MOBILE BAY ESTUARY:
XI.
The Mobile Bay Estuary will be contaminated'with radio-active content which will ruin the seafood industry, as the shrimp, clams and fish, etc. will become filled with radionuclides dumped by the Plant into the Alabama river.
10 C.F.R.
S70. 23 (a) (3)
(4) and LS ).
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STRINGENT NEW EPA STANDARDS:
XII:
Under the Resource Conservation and Recovery Act of 1976, the Plant must comply, as of November, 1980,with stringent new requirements promulgated by the Environmental Protection Agency, especially concerning notification and permanent tracting, of hazardous waste materials, and neither the Alabama Nuclear Fuel Fabrication Plant Environmental Report (hereinafter "En-vironmental Report") nor the Application address whether or how Westinghouse will comply with these standards.
10 C.F.R. 570.23 (a) (3) and (4).
A.
Anything hazardous, whether radioactive or not, which will be shipped or stored must meet strict and costly notification requirements and a permanent tract of the location of said materials must be kept.
.B.
The Plant will have numerous waste materials with flourine content, and said wastes must comply with the new EPA standards.
URANIUM 235 A RARE ELEMENT
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XIII:
Uranium 235 is a rare element and its very limited supply should be exhausted well before the 40 year life of the Plant has run its course.
10 C.F.R. S70.23 (a) (3) and (4).
NUISANCE CONDITION CREATED IN RIVER BY MIXTURE OF PAPER MILL WASTES AND NUCLEAR FUEL WASTES.
XIV:
The normal paper mill wastes-from the Union Camp Corp.
I plant in Prattville plus nitrates in the ammonia from the processed materials of said plant, especially when combined with the nuclear i
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wastes coming out of Westinghouse's Plant, will create an ex-tremely hazardous nuisance condition in the Alabama River, threatening the populace of Central Alabama.
10 C.F.R.
S70.23 (a) (3) and (4).
POSSIBILITY OF HYBRID URANIUM 235 - PLUTONIUM COMBINATION BEING MANUFACTURED.
XV.
Since Westinghouse has closed down a plant in Pennsyl-vania manufacturing a hybrid of Uranium 235 and plutonium, it i
is likely or possible that it will shift the same functions to its Plant in Prattville, thus greatly threatening the populace of 1
j Central Alabama.
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FOOD WEB CHARTS TOO THEORETICAL XVI:
The food web charts appearing on pages 2-73 and 2-78 of the Environmental Report are too theoretical to be accurate or
.of value.
Thus, the negative impact of the Plant on animal and plant life is grossly underestimated. 10 C.F.R. 570.23 (a) (3) and (4).
LINE MANAGEMENT ACCOUNTABILITY FOR NUCLEAR CRITICALITY SAFETY.
XVII:
The Application (5 4-1. 3. 2 (4 ), page S-13) states that line management shall be responsible for nuclear criticality safety, yet there are no prescribed standards of responsibility.
In light of the grave risk tc the public involved, more definition is needed.
10 C.F.R. S70.23 (a) (3 ) and (4).
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BACCALAUREATE DEGREE INSUFFICIENT FOR MANAGEMENT RESPONSIBILITY IN MAINTAINING NUCLEAR CRITICALITY SAFETY.
XVIII:
The Application's (S 4-1. 3. 4, page S-14) requirement that a regulatory compliance manager and a criticality engineer have a baccaluareate degree is insufficient training for one directly responsible for maintaining nuclear criticality safety.
10 C.F.R. S70.23 (a) (3) and (4).
A.
In order to prevent nuclear criticality from occuring, a nuclear engineer needs far more training than a baccalaureate degree provides.
NUCLEAR CRITICALITY SAFETY NEEDS OUTSIDE INSPECTION XIX:
The Application states that audit and inspection of nuclear criticality safety will be done internally by Westing-house; given the high importance of safety, such an audit and inspection should be performed by an outside party, including possibly the N.R.C.
itself.
10 C.F.R. 570.23 (a) (3) and (4).
BUILDING INSUFFICIENT TO WITHSTAND EXPLOSION XX:
The 12 inch minimum separation between adjacent suberits in the interaction control areas is insufficient space to prevent criticality.
(Application, 4-3.3, page 5-20) 10 C.F.R.
S70.23 (a) (3 ) and (4).
A.
Other nuclear fuel fabricating plants have frequent e:olosions.
NO DESIGNEE FOR COGNIZAN* SHIFT SUPERVISOR XXI:
Under the Application (4-3. 4.1, page S-20) the cognizant 8
shift cupsrvicor hcs'ths right to nama a "dasignaa" who shall I
have the responsibility of indoctrinating and training a new i
employee in the proper procedures and precautions for performing specific jobs, including coping with emergency situations.
No qualifications are required for this " designee" and without such, he could improperly train Plant personnel to cope with emergencies, including those involving criticality.
10 C.F.R. 570.23 (a) (3) and (4).
A.
Someone more responsible than a so-called " designee" is needed to prevent accidents from occurring.
4 EMERGENCY BULLETIN BOARD NEEDED FOR CHANGES IN PROCEDURES CON-CERNING SPECIAL NUCLEAR MATERIALS.
XXII.
The Application (4-3.4.3, page S-21) states that
" Changes associated with the handling, processing, or storage of special nuclear material...shall be communicated by the use j
l of circulars, routing of. revised procedures..., work place meetings, and/or postings."
In order to guarantee communication, there should be one central bulletin board containing all messages which employees are required to check and sign in on every day, and any changes should be posted in conspicuous-wording and coloring.
10 C.F.R. 570.23 (a) (3) and (4).
A.
Otherwise, under other procedures identified in the Application, it would be too easy for a key employee to miss an important message and thereby make a critical mistake.
MONITORING OF AIR SAMPLING EQUIPMENT NEEDED DAILY, NOT ANNUALLY XXIII:
The Application (4-4.2, page S-21) states that "the l
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- p 4 accuracy of representation of permanently mounted air sampling equipment (to measure airborne radioactivity) shall be evaluated at least annually...". An annual evaluation is far too infrequent monitoring, and considering the' danger of airborne radiation release, a daily evaluation is needed.
10 C.F.R. S70.23 (a) (3) and (4).
RADIATION PROTECTION AND NUCLEAR SAFETY INSPECTIONS SHOULD BE MADE MORE OFTEN THAN MONTHLY XXIV:
The Application (4-4.3, page S-21) states that radiation protection and nuclear criticality safety inspections shall be performed at least monthly during operations; instead, in order to protect the populace of Central Alabama, said inspections i
should be made daily.
10 C.F.R. 570. 23 (a) (3) and (4).
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" SOUTHERN GTANDARD BUILDING CODE " INADEQUATE FOR SPECIAL NUCLEAR MATERIALS BUILDING."
XXV:
The Application (5-1), page S-24) states that the Plant Special Nuclear Materials Building shall comply with the Southern Standard Building Code; the requirements of said code are designed for an ordinary industrial building and are__far too weak for a nuclear materials building.
10'C.F.R. 570. 23 (a) (3) and (4).
A.
A building is needed which can withstand internal explosions and fires involving flourine.
MORE INFORMATION NEEDED CONCERNING INSURABILITY XXVI:
The Application (5-1,'page S-24) states that "The Special Nuclear Naterial Building" shall be designed, l
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constructed, and operated so as to enable insurability with a major nuclear liability and property insurance pool," yet no information is given as to type or amount of insurance, whom it will cover, and what insurance companies carry this type of insurance.
A.
Very few, if any, insurance companies in America will insure nuclear facilities and, if such insurance is offered at all, it must be offered only on a very limited liability basis.
B.
Given the great number of plant workers and other citizens of Central Alabama living in close proximity to the Plant, ample insurance coverage will be needed to cover both.
NEUTRON ISOLATION STRUCTURE CANNOT CONTAIN NEUTRONS GIVEN OFF BY URANIUM-235.
XXVII:. Contrary to the inference of the Application (5-1.
2, page S-25), a neutron isolation structure will be unable to contain the neutrons spontaneously emitted by Uranium 235.
A, A more viable containment plan is needed to protect the public.
10 C.F.R. 570.23 (a) (3) and ' ( 4 ).
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AEROSOLS OF URANIUM SMALLER THAN 0.3 MICROMETERS AND CAN PASS THROUGH HEPA FILTERS XXVII'. :
The Application (5'l.3, page S-25) states that l
the HEPA filters shall be rated at least 99.9 percent efficient for removal of particulate matter 0.3 microns or greater in size; yet aerosols of uranium are smaller than this size and can there-fore pass through the HEPA filters and endanger the public.
10 1
C.F.R. 570.23 (a) (3) and (4).
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BREATHING MASKS NEEDED TO KEEP WORKERS FROM GETTING LUNG CANCER.
XXIX:
Respiratory masks will be needed to protect workers against aerose s of gaseous effluents, which can cause cancer.
The masks should be worn regularly, and the conditions for their occasional use are inadequately spelled out in the Application.
(5-3. 4. 3, page S-61).
10 2.F.R. 570. 23 (a) (3) and (4).
MORE SPECIFICITY NEEDED IN PROCESS DEGRADING URANIUM AS SPECIAL NUCL%R MATERIAL TO URANIUM AS SOURCE MATERIAL.
XXX.
The Application 5-1.5.3, page S-28) states that " pro-vision may be made for degrading uranium as special nuclear material to uranium as source material"; however, in the interests of public health and safety, far more specificity is needed.
10 C.F.R. 570.23 (a) (3) and (4).
A.
Will this degrading process result in a natural isotopic ratio of 99.3% of U 238 and.7% of U 235 or will it be present in some other ratio?
NEED MONITORING OF STORM DRAINAGE DISCRARGES INTO AUTAUGA CREEK XXXI:
The Application (5-1.5.4, page S-28) states that
" Storm drainage may be discharged into Autauga Creek without prior treatment, hold-up, sampling or analysis"; a monitoring point for this discharge is needed to measure and protect dangerous wash off materials from getting into water used by people, animals, and plants.
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A.
Fall-out will inevitably build up around the Plant and will wash down into the creek after a storm; something should be done to at least measure the amount of such drainage and a warning should be issued to the public if necessary.
10 C.F.R.
S70.23 (a) (3) and (4).
MORE SPECIFICITY NEEDED AS TO CRITICALITY MONITORING SYSTEMS AND ALARMS.
XXXII:
The Application (5-1.6.2, page S-29) states that j
the " emergency power system shall be designed to automatichily provide necessary service to criticality monitoring systems and alarms"; more specificity of information is needed as to the i
monitoring systems and alarms which will protect the populace of Central Alabama from a radiation fall-out.
10 C.F.R.
S70.23 (a) (3 ) and (4).
FIRE PROTECTION PLANNING FOR SNh BUILDING MUST PLAN FOR WATER-RESISTANT QUALITIES OF FIRE INVOLVING FLOURINE OR URANIUM DIOXIDE.
XXXIII:
The Application section discussing Fire Protection (5-1.7.1, page S-29) makes no provision for the water-resistant qualities of a fire involving flourine or utanium dioxide, and the Prattville Fire Department needs special training in how to contain such a fire in order to keep such an unchecked fire from caus-ing a bad accident involving criticality.
INTERLOCK SAFETY PROCEDURES NEED CONSIDERATION XXXIV.
The Application (5-1.8, page S-31) addresses a t
systemofintgrlockstobeusedinthe~Planttosafeguardworkers, l
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facilities, and environs against failures of equipment and systems significant to safety; given the importance of these interlocks more information is needed on them.
10 C.F.R. 570.23 (a) (3) and (4).
EVACUATION PLAN NEEDED IN APPLICATION FOR PEOPLE OTHER THAN PLANT WORKERS.
XXXV.
Although the Application (at 5-1.9.1, page S-31) discusses an evacuation plan for plant employees, an evacuation plan is also needed for people in the general environs not employed t
by the Plant, in the event of a criticality accident.
10 C.F.R. 570.23 (a) (3) and (4).
MORE DEFINITION NEEDED AS TO NUCLEAR CRITICALITY SAFETY TECHNICAL SPECIFICATIONS XXXVI:
The Application (5-2, page S-33) discusses the subject of nuclear criticality safety technical specifications,
'yet very inadequate definition is given to certain terms employed, and this lack of information camouflages the real dangers involved for the public.
10 C.F.R. S70.23 (a) (3) and (4).
A.
For instance, what do " fixed nuclear poison" or " mass control" mean?
Do these include neutron absorbing materials such as boron and cadmium?
NUCLEAR CRITICALITY SAFETY SHOULD NOT BE RELYING ON EXPERIMENTAL EVIDENCE XXXVII:
The Application (5-2. 2 (2), page S-33) states, with respect to uclear criticality safety, that " failure modes may be con ' ered incredible based on experimental evidence and/or 14 1
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operation &1 evidence.
In order to maintain nuclear criticality safety, the Plant should not have to rely on experimental or operational evidence.
10 C.F.R. 570.23 (a) (3) and (4).
A.
The Plant operators should be more positive; after a criticality accident it may be too late for such evidence to be
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of any value.
MORE INFORMATION NEEDED AS TO PERSONNEL DOSIMETRY XXXVIII:
The Application (5-3.1.1, page S-40) states that
" initial beta-gamma radiation surveys may be conducted to identify areas and operations where personnel dosimetry is required on a routine basis."
More information is needed, in order to protect the workers, as to what is " routine" and what is not. 10 C.F.R. 570.23 (a) (3) and (4).
COMPENSATION SHOULD BE ALLOWED WORKER RECEIVING CRITICAL DOSE OF RADIATION.
XXXIX:
There is no reference in the Application or Environ-mental Report as to any type of compensation schedule for workers who receive a critical dose of radiatfon; given the likelihood of.
potential for cancer and other harmful health effects, some type of compensation schedule needs to be instituted.
10 C.F.R.
S70.23 (a) (3) and (4).
HIGHER LEVELS OF URANIUM CONCENTRATION IN AIR SHOULD NOT BE ALLOW N
XXXX:
The Application (5-3.1. 2 (a) (2), page S-42) states that " Designated portions of a controlled area may be permitted 15
higher levels (of uranium concentrations in air) if a documented evaluation by the regulatory compliance component demonstrates that l
the protective measures for the area are such that personnel 2
exposure criteria will not be exceeded."
In the interests of the health and safety of the workers, no exemptions from normal l
uranium concentrations in the air should be allowed.
10 C.F.R.
j 570. 23 (a) (3 ) and (4).
l SURVEY INSTRUMENT FOR MEASURING REMOVABLE ALPHA ACTIVITY ON j
PROTECTIVE EQUIPMENT AND CLOTHING SHOULD HAVE A GREATER THAN 50%
EFFICIENCY RATE.
1 XXXXI:
The Application ( 5-3.1. 2 (c), page S-44) states that
}
" Removable alpha activity surveys of protective equipment and clothing shall only be required if a direct alpha activity survey (as read on a survey instrument with.. 50% efficiency). indicates greater than 1500 c.p.m.
Any survey instrument used to measure i
alpha activity should have a much higher than 50% efficiency level in order to adequately protect the workers at the Plant.
10 C.F.R. S70. 23 (a) (3) and (4).
REMOVABLE ALPHA ACTIVITY SURVEYS OF PERSONNEL CLOTHING AND BCDY SURFACES NEEDED FOR MUCH LOWER AMOUNTS OF DIEECT ALPHA ACTIVITY THAN 300 c.p.m.
XXXXII:
The Application (5-3.1. 2 (d), page S-45) states that " Removable alpha activity surveys of personal clothing and body su aces shall-only be required if a direct alpha activity sur
... indicates greater than 300 c.r. *.
Since one particle-of Uranium 235 can cause cancer, the 300 c.s.m.
standard is far too high and does not adequately protect the plant workers.
10 C.F.R. S70. 23 (a) (3) and (4).
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SCRUBBERS NEEDED TO REMOVE AIRBORNE EFFLUENTS XXXXIII:
The Application ( 5-3.1. 3 (a), page S-47) treats the subject of airborne waste materials and yet fails to mention the use of scrubbers to prevent or reduce the amount of such materials escaping into the air.
Scrubbers are needed at the plant to protect people in the vicinity who breath the air.
10 C.F.R.
S70. 23 (a) (3) and (4).
AIR SAMPLES COLLECTED AT THE PLANT SHOULD BE ANALYZED MORE THAN ONCE A WEEK.
XXXXIV:
The Application (5-3.1. 3 (a), page S-47) states that
" Air Samples collected at the location may be com5ined for analysis if they represent a sampling period of one week or less."
Given the irregular nature of discharge of airborne effluents, public health and safety would be much better served by a more frequent (such as daily or hourly) measurement of airborne effluents.
10 C.F.R. 570.23 (a) (3) and (4).
A.
Average measurement levels are inadequate; it is important to know the highest, the lowest, and the mean reports on a daily or hourly basis to get an accurate measurement.
MEASUREMENT OF LIQUID WASTE MATERIALS INADEQUATE.
XXXXV:
With respect to liquid waste materials (discussed in the Ap ication, 5-3.1. 3 (b), pages S-49 to S-50), there is much to' arge a volume or mass of liquid waste materials, there is too much a release of ionizing radiation, and there is too infre-quent a sampling period, and the sum total effect is highly hazardous to thu general public.
10 C.F.R. S70. 23 (a) (3) and (4).
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l RADIOLOGICAL MONITORING OF SOLID WASTE MATERIALS INADEQUATE TO PROTECT WORKERS OR GENERAL PUBLIC XXXXVI:
The radiological monitoring program for solid waste materials set out in the Application (5-3.1.3 (c), page S-50 to S-53) is inadequate in too many respects to protect workers or the general public.
A.
The two charts on page S-52 do not distinguish between U-235 and U-238 content; which is very important since the former is much more dangerous than the latter.
B.
In the first chart, with respect to sediment and fish samples, both the minimum number of sample locations (namely 2) and the minimum monitoring frequency level (annually) is inadequate.
C.
The once every two years measurement of gamma dose equivalent in the dosimetry (See Charts I and II) is most inade-quate.
10 C.F.R. S70.23 (a) (3) and (4).
BETA-GAMMA EXPOSURE LIMITS FOR WORKERS TOO HIGH XXXXVII:
The Application (5-3.2.1 (1) and (2), page S-53) state that individuals entering a restricted area of the plant must wear a personnel dosimeter if he is likely to receive a beta-gamma dose in any calendar year higher than 300 milirem to his 4ead and trunk, active blood-forming organs, lens of eyes
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or, gonads, 1800 milirem to the skin of the body, and 4500 milirem v
to the hands, forearms, feet and ankles.
These milirem limits fer individuals are way too high and exposure in these amounts can head to cancer or other hazardous health effects. 10 C.F.R.
l S70.23 (a) (3) and (4).
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PLANT WORKERS SHOULD BE PROTECTED WITH INSURANCE POLICIES KXXXVIII:
Plant workers, as part of their contract, of employnent, should be given an insurance policy to protect them from the harmful health effects of radiation exposure.
10 C.F.R. C70. 23 (a) (3) and (4).
WORKERS SHOULD HAVE WESTINGHOUSE-PAID RIGHT TO CONSULT OUTSIDE PHYSICIAN IC:
Wo'rkers should be advised by Westinghouse that they have the right to go to an outside trained physician of their choice to measure the level of radioactivity received, and said medical expense shall be paid for by Westinghouse.
BICASSAYS SHOULD BE DONE ON RIVER-DWELLING ORGANISMS C:
The Application (5-3. 2. 3, page S-55) states that bioassays will be performed on human beings; however, a bioassay should also be regularly performed on all organisms in the Alabama River downstream from the Plant, including " bottom-dwelling" organisms, organisms moving with the current, and fish.
10 C.F.R. 570.23 (a) (3 ) and (4).
" AVERAGE" DOSE EQUIVALENT A QUARTER PER RADIATION WORKER IS POOR MEASUREMENT OF RADIATION DOSE
[CI:
The Application (6-2, page S-64) states that, with stdspect to surveys, personnel dosimetry, and bioassays, the regulatory compliance component shall prepare ant maintain charts to graphically display " Quarterly trends in average dose equivalent per radiation worker."
Given the hazardous impact of radiation dosage on the human body, the charts should provide far more information than 19
1 quarterly averages as to all workers.
10 C.F.R. 570. 23 (a)
(3) and (41.
A.
The Charts should show high, low, and mean radiation doses on workers, and should show the statistics at least weekly, if not daily.
A quarterly analysis is way too infrequent.
MORE INFORMATION ON COMPREHENSIVE PHYSICAL SECURITY PLAN NEEDED IN APPLICATION.
CII:
The Application (Section 8, page S-67) simply states that, prior to initiating operations with special nuclear materials at the Flant, an approved Comprehensive Physical Security Plan shall be prepared and distributed to key line management.
Given the importance of this plan to the health and safety of human, animal and plant life in Central Alabama, it is important that such a plan be reviewed and analyzed in detail by both the intervenor SEACA and the NRC in the discovery phase before a hearing
.on the merits of the Application.
10 C.F.R. S70.23 (a) (3) and (4).
MORE INFORMATION NEEDED ON " EMERGENCY PLAN AND IMPLEMENTING PROCEDURES" CIII:
The Application (Section 11, page S-70) simply states that, prior to initiating operations with radioactive materials at the Plant, an approved Emergency Plan and Implementing Pro-ce'{hres for coping with emergencies shall be prepared and dis-tp buted to key line management.
Given the importance of this plan to the health and safety of human, animal and plant life in Central Alabama, it is important that such a plan be reviewed an(. analyzed in detail by both the intervenor SEACA and the NRC 20
,;k in the discovery phase before a hearing on the merits of the Application.
10 C.F.R. S70. 23 (a) (3) and (4).
MORE INFORMATION NEEDED ON DECONTAMINATION AND DECOMMISSIONING.
CIV:.The Application (Section 12, page S-71) addresses the issue of decontamination and decommissioning but fails to provide adequate information on either.
Given the fact that Alabama is an " agreement state" and given the danger and threat that an abandoned radioactive building and other materials pose to human, plant, and animal life, it is important that the decontzmination-decommissioning plan be carefully scrutinized by the intervenor SEACA and the NRC prior to the granting of a license.
NO EXEMPTION SHOULD BE GIVEN WOSTINGHOUSE TO REQUIREMENT OF 10 C.F.R. 20.103 CONCERNING " EXPOSURE OF INDIVIDUALS TO CONCENTRATIONS OF RADIOACTIVE MATERIALS-IN AIR IN RESTRICTED AREAS" l
CV:' 10 C.F.R. 20.103 serves a good purpose in requiring Westinghouse to " notify, in writing, the director of the appro-priate NRC Inspection and Enforcement regional office at least 30 days before the date that respiratory protective equipment is first used.
A.
Westinghouse should not be exempted from this require-ment just because the subject matter is treated in the~ Application.
([5-1,pageS-73).
/
Given the importance of the respiratory protective B.
j l
equipment to the health and safety of the workers, it is important that the NRC be able to examine and inspect to equipment befdre it is used.
21 1
,e NO EXEMPTION SHOULD BE GIVEN WESTINGHOUSE TO REQUIREMENT OF 10 C.F.R. 20.203 CONCERNING " CAUTION SIGNS, LABELS, SIGNALS AND CONTROLS" CVI:
10 C.F.R. 20.203 serves a very good purpose and no exemption whatsoever should be given Westinghouse, as it is seeking in the Application (13-2, page S-73), to the requirement that all containers of licensed material bear a durable, clearly visible label identifying the radioactive contents and stating in bold, capital print the words " CAUTION, RADIOACTIVE MATERIAL" or
" DANGER, RADIOACTIVE MATERIAL".
A.
Given the importance of plant worker safety, it is necessary that the precautions of 10 C.F.R. 20.203 be strictly followed.
10 C.F.R. 570. 23 (a) (3) and (4).
NO EXEMPTION SHOULD BE GIVEN WESTINGHOUSE TO REQUIREMENT OF 10 CFR 20.301 CONCERNING " GENERAL REQUIREMENT FOR DISPOSAL OF LICENSED MATERIAL.
CVII:
Westinghouse seeks exemption from the requirements of 10 CFR 20.301 in its Application (13-3, page S-73), yet'these requirements governing waste disposal are very important to public health and safety.'.
A.
The use of the word "small" in describing quantities of the waste material is misleading as it is not defined.
B.
The requirements of 10 C.F.R. 20.301 were created for
-1 a good purpose and is especially needed in a situation such as t
Westinghouse's proposed plant in Prattville.
-(a) (3 ) and (4).
r 22 l
NO EXEMPTION SHOULD BE GIVEN WESTINGHOUSE TO REQUIREMENT OF 10 C.F.R. 20.401 CONCERNING " RECORDS OF SURVEYS, RADIATION MONITORING,
,AND DISPOSAL.
CVIII:
Westinghouse seeks exemption from certain of the require-ments of 10 C.F.R. 20.401 requiring it to maintain records c' surveys radiation monitoring and disposal.
Yet, all the requirements of 10 C.F.R. 20.401 serve a good purpose in promoting public health and safety and no exemption should be granted.
10 C.F.R.
- 70. 23 (a)
(3) and (4).
NO EXEMPTION SHOULD BE GIVEN WESTINGHOUSE CONCERNING THE REQUIREMENTS OF 10 C.F.R. 70.24 GOVERNING " CRITICALITY ACCIDENT REQUIREMENTS" CIX:
Westinghouse seeks an exemption from certain of the requirements of 10 C.F.R. 70.24 governing " Criticality Accident Requirements" by not being required to have monitor alarms in certain areas; yet, no matter how remote an area may be from operations involving special. nuclear materials, there is nonetheless a great risk to all individuals in the plant vicinity if there is a criticality accident.
10 C.F.R. 70. 23 (a) (3) and (4).
A.
It is important that the requirements of 10 C.F.R. 70.24 be strictly fo'. lowed in all the designated area _s to which Westing-house seekr exemption, as a criticality accident simply bears too great a risk to human life.
Respectfully submitted, SEACA
/
By bM1
~2/Ig,/ b I
- ntrian McPhillips l
P.O.
Box 64 i
Montgomery, Ala.
36101 l
(205) 262-1911 Attorney for SEACA l
23
CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing upon the following named parties by mailing the same to them on this the
/ M day of CO 1980.
John F. Wolf, Esq., Chairman Donald R. Marcucci, Esq.
Atomic Safety and Licensing Board Law Dept.
3409 Shepherd Street Westinghouse Electric Corp.
Chevy Chase, MD 20015 P.O.
Box 355 Pittsburgh, PA 15230 Dr. Harry Foreman, Member Atomic Safety and Licensing Board Sherwin Turk Box 395, Mayo Legal Staff University of Minnesota U.S. Nuclear Reg. Comm.
Minneapolis, MN 55455 Washington, D.C.
Dr. Martin J. Steindler, Member David L. Allred, Esq.
Atomic Safety and Licensing Board 231 Oak Forest Drive Argonne National Laboratory Montgomery, Ala.
36109 9700 South Cass Ave.
Argonne, IL 60439 Dr. Ira L. Myers, M.D.
State Health Officer Atomic Safety and Licensing Board State of Alabama Panel (2)
Dept. of Public Health U.S.
Nuclear Regulatory Comm.
State Office Bldg.
Washington, D.C.
20555 Montgomery, Alabama 36104 Atomic Safety and Licensing Docketing and Service Section Appeal Panel Office of the Secretary U.S.
Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Washington, D.C.
20555 Bart Cowan
~~
Eckert, Seamans Cherin & Mellott Forty-Second Floor 600 Grant Street Pittsburgh, PA 15219
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Julfan McPhillips I
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