IA-87-840, Partial Response to FOIA Request for Documents Re to Licensee Transmitting Suppl to Safety Evaluation & Environ Assessment

Partial Response to FOIA Request for Documents Re to Licensee Transmitting Suppl to Safety Evaluation & Environ Assessment

ML20234D908
Person / Time
Site:	Diablo Canyon
Issue date:	01/05/1988
From:	Grimsley D NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:	Graber L NUS CORP.
References
FOIA-87-840 NUDOCS 8801070285
Download: ML20234D908 (2)

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1. . 5' RESPONSE TO FREEDOM O - '

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/' INFORMATION ACT (FOIA) REQUEST g, jq g DOCKET NUMBEAtSt i# esp 6ceNel REQUESTER Mr. Lyle Graber PART 1.- RECORDS RCl2ASED OR NOT LOCATED (See checked bonest No egency records subpect to the request have been located.

No additor.al agency records subject to the request have been located.

Agency records subject to the request that are identifed in Appendix are already available for public inspecten and copymg in the NRC Public Document Room, 1717 H Street. N W., Washington, DC.

l Agency records subsect to the request that are identifed in Appendia A 8,e be,ng made e, suave fo, pubi,e inspection end copying in the NRC Puuic Documeni y Room.1717 H Street. N.W., Washmgton, DC, in a folder under the FOIA number and requester name.

j The nonpr0prietary verNon of the proposaHs) that you agreed to accept an a telephone conversation with a member of my staff is now beeng made available for public inspecten and coying st the NRC Public Document Room,1717 H Street, N W , Washington DC, in a folder under the FOIA number and requester name.

Enclosed is informaton on how you mcy obtain access to and the charges for copying records placed in the NRC Public Document Room,1717 H Street. N W., Washington, DC.

Agency records subpect to the request are enclosed. Any applicable charge for copses of the records provided and payment procedures are noted in the comments secten.

Records subject to the request have been referred to another Federal agency (sos) for review and direct response to you.

In view of NRC's response to the requeet. no further action a being taken on appeal letter oated PART ft.A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certain information in the requested records a bemp wrthheld from pubhc disclosure pursuant to the FOIA enemptons descnbed m and for the reasons stated in Part 11, sec-tons B. C, and D. Any released portons of the documerits for which only part of the record is being withheld are being made available for publiC inspection and Copying in the NRC Public Document Room,1717 H Street, N.W., Washington, DC, in a folder under the FOIA number and requester name.

Comments SIG U . DIRECTOR. Olv1SION 5 ULES D CORDS i .- - m

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880107d2g5 880105" PDR FDIA PDR GRABER87-840 NAC FORM 4641 Pert il 19 451

1 Re: FOIA 87-840 APPENDIX A RECORDS BEING PLACED IN THE PDR I Date Description

1. 10/15/87 Enclosures to letter to Pacific Gas & Electric (Diablo Canyon) transmitting a supplement to the safety evaluation and environmental assessment (Accession No. 8710220412). (15 pages) l i

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siirrLEwENT TO THE SArETY EVALUATION AN" THE ENY!DnNMENTAL ASSESSuENT Et THE Orr1CE Or NUCLEAR REACTOP FEGULATION DEtt ING TO THE CEPACKINr 0F THE SPENT FUEL POOLS AT THE O! ABLO CANYON t:t'CLEAD MWER PLANT, UNITS 1 AND 2 FACILITY OPERA *IffG LICENSF No. DPR-80 FACILITY OPERATING LICENSE NO. OPR-82 PAC!FIC GAS AND FLECTRIC COMPANY j.;

DOCKET N05. 50-275 AND 50-323 s d 0:TOBER 15, 19B7 1

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TABLE OF CONTfhTS Page

1. Isi;CD. CTits IA? E,AD GROUND 1

2. LE' FER* N NG AsrECTS E

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.1 Rock Pernal and Installatier, 2 0.2 Radiatice Prctection and ALARA Considerations 3 2.: Accieerts 3 2.4 Environmental Irnpacts 4 T.5 Alternative, b

3. ECRAr, tv HEL'TPON AB50RE!hG MATERI AL

. 5 A. GEhEEIC FIhAL EhVIPONWENTAL IMPACT STATEMENT 6

5. SEVERE ACCIDEf.' CONSIDEF.ATIONS 7

6. SUv.w.AH A%D CONCLU5!0NS 7

7. CONTSIEUTCP5 8 i

E. G E F F F E h'.E 5 -

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v m "'rs As7 p y r,cnns?

% r ;teic e Gas ar? Flect ric Cor:rany (PGM i, licersee for the Diat ic Canyor.

%,: 4 ; r r e w+ r Piar t , Units 1 and 2, reouested, by letter dated 0ctober 30,195 f

'h' ar e-ercrent to the creratinc license for eect unit that would authcrire er ercrrs,cr c' t&e capecity O' tach of the twe spent fuel pools fror 270 fue1 e ' e +- t s t o F * 'ee l e lene- t s . The sta'f reviewed and evaluated the anendr+rt re u st. ard ce Sa. E , 1 W , issued Arprdment No. F and No. 6 to tre Unit 1 ar: !*'t ^ cre-a tir c licenses PPD-81 and PPE-8', respectively. These amendmcets.

• + 'ck we re st.prorted by the sta"' t !afety Evaluation (SES and Environmental Assessre" (fe', made appropr ate changes to the Technical Speci'irations (Refs. ?

er e 3, respectively i. Eased on the staff's final detenriration that the action irsched et sdeci'icart hazards consideration, the amendrerts became imediately C'#ec 4ve.

Therea'ter, in Septec.ber 1986, the l'.S. Court of Appeals 'cr the Ninth Circuit, rU ed on a petition for review jointly filed by the Sierra Club and San Luis C t'i s pa Wtrers #cr Peace, holding that the NDC inpropeely detertnined that the license a erdv nte scught involved no siorificant hazards consideration (Ref. 41 '

At e corsecuerce, the effectiveness of the amendments was stayed by the Court l urtd1 the cor.pletion o' the requested NRC hearing. 2

!r creer to corply with the Court's holding, while, at the same time providing '

for the centinued operation of the facility, the licensee remved the new, high ders#ty racks which had been installed in Unit 1, reinstalled the original racks ,

and placed the spent fuel fror the Unit 1 first refueling into the original racks.

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The nem- Figh density racks had net been installed in the Unit 2 spent fuel pool.  !

The Ur.it 2 original racks are, as in Unit 1, being used to store the spent i fuel ef*1oaded from Unit 0 from the first refueling. Because of the foregoiro, the re-acking of Unit I and Unit ? with the new, high density racks will now have f tc be perforred in a wet and radioactively contaminated environment rather than in '

a dry and uncontaminated envirornent. The license amendrent application (Ref. 1) provided little inforr.ation concerning installation of the high density racks I

ir a wet environment, noting the licensee's preference to undertake the effert in dry, uncontar.inated pools. Accordingly, the staff's Safety Evaluation and Environmental Assessment did not address the former.

Ttis Supplemer.t provides the staff evaluation of wet "erecking aspects.

F,crafles neutron absorbirg material, and further discussions on certain aspects of the Environmental Assessment in response to the Opinion issued by the Court of Appeals, in particular, that the staff's site specific envirereental assessment was based on a seven year old generic environmental assessmert and that no " worst cese" analysis, in accordarce with 40 CFR Sectier.150'.?? (Pef.17), appeared to have been conducted. The wet rerecking aspects are discussed in Section 2 o' this report and include insta11etion precedures, radiation protection, accidents, radioactive waste, environmental ccrsecuences erd alternatives to wet veracking. The sta#f's evaluation of Boraer reutron absorbing ersterial is cortained in Section 3. Further discussion regarding the Environ ental Assessment and documentation on the adecuacy cf a previous generic environmental afsessment and on the need fer a *werst case

• enelysis are addressed in Sections a and 5, respectively.

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ts discussef 'r Section I, the issV8 Pre of the license amendmeets for the enredor spert fuel rccls and tbt supporting Safety Eveluation and fritroreentai Asso w itt t'v the sta (Pe's. 2 and 3) were based on the assurstion tt6t the rerac6ing process, that is, the removal of the original rects and irrtallatice of the new racks, would take place in a dry and I umcrterinated ert ironment. Since the spent fuel pool rerackirg for both Units l r.a s t rh be pa 'emed in a wet ard possit'ly contaminated environment, the l s'e" has re-rev4ewed and re-evaluated those aspects that are differert and of sigr *ficance regarding the reracking process. They include the following asp

• cts presiously discussed ir the EA and SER:

1 Occupational exposure, EA Section 2.2-1rstellation of racks and load handling, SER Section 5; Radiation protectior and ALARA considerations, SER Sectier P; f Perec6 ug installation. SEP Section 12. Item 7 I l

The staff evaluation for each of these aspects is provided in the following sections of tHs report. The staff also has considered if the wet reracking involves arv alternative action other th6n those previously evaluated, as j discussed in Secticn 2.5 below. The staff review and evaluation of the wet '

rerecking included requests for additional infomation to the licensee (Refs. 5 ard f), a meeting with the licensee on January 22,1987 (Ref. 7) ead edditional information provided by the licensee (Refs. 8 and Ref. 9), i The wet veracting does not change any of the other matters previously evaluated in the stafs Sa'ety Evaluation and Environmental Assessment, and furthermore, dres not require any other changes to the Technical Specifications thar were included in Amend ~ent hos. 8 and 6 for Units 1 and ?, respectively.

2.1 Rath Pemval And Installation i In Section 2 of its SE (Ref. 2) the staff had concluded that the installatico ir a dry and uncontaminated condition will not result in an accident with the petential release of radioactivity. The staff requested additional information on the rack removal and installation aspect for a wet and contaminated condition (Pe's. 5 ard 6), discussed this matter with the licensee in a meeting on Januar" 22, 19P' (Ref. " and the licensee provided further information foefs 8 and 91 In the r ebruary 2.10E7 submitta' (Pef. 94 the licensee stated that procedures will be developed for the removal of the original racks and the installation of tha new, high density racks. These procedures will include requirements for handling heavy loads. -adiation protection, tool control and appropriate special liftirg devices. eurther, the special lifting devices and overhead crane that will be used to remove the existing, low density spent fuel racks and install the new, high density racks will be tested and inspected in accordar.ce with the rectuirement s of ANSI B30.9-1971 and M SI B.30.2.0-1976, retrettivety. Additionc11y, the crane operatnes have been treined in accordance witt M51 P. Y.2.0-197F.

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% y r ' ' u f, o' betr ite erigire! and the new racks is goverred by criteria for ttt r e f ing c' h eo loads, as prescribed in NUPEG-0612. " Control of Heavy be n e t tuclear Pc.er Plants" Pe'.10). These activities will bt performed cen Start witt the licensee's prevuus corritmerts to the NLIPEG-0612 guidelines.

n i t, sta" 's Sa'etv Evaluetion Report Supplement Nos. ?7 and 21, 55EP-27 and 559-M , respec W ely IRefs. 'I and IC the staff concluded that the licenser's r ccee 'cr the Laablo Caryon Diert for the control of heavy loads complies with

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tre guidelires cf NUREG-Ofl2. This cerclusion remains unchanced. The aspects c' a potential accident irsc1ving spert fuel during the reracking operations is discussed in Sectier 2.3 below.

C.: ca diatier Prrtecticn and ALARA Considerations

%e sta" esaluation fer radiation protection ard ALARA consioeratiers was reeviously prosided in Section E of its Safety Evalcation (Ref. 2) for the dr, erc uncontaminated condition. Additional infomation fer the wet and ccria/inatec condition has been provided by the licensee (Refs. 8 and 9).

Underwater lightirg and TV monitoring will facilitate diver and installation cperations. Diver esclusior zones around spent fuel will be established and diver decontamination crews will be provided to ensure exposures ere within the 11rits specified by 10 CFR Part 20 and meet ALAFA Guidelines. Spent fuel stored ir criainal or new racks will be moved to positions furthest away from where divers are performing rerack operations. Diving operatiens will not be pemitted curing fuel bandling operations. The effect on occupational exposure for the wet rerack is estimated to be 9.7 man-ren with a maximum individual dose of 1.1 rea. This esposure is approximately 3% of the plant yearly cumulative dose.

Pegarding the disposal of the original racks, previously discussed in Section 5 and Section 8 of the SE, the licensee will decontaminate the racks in the cask washdown area following their removal from the spent fuel pool. Original racks that are sufficient'v decontaminated will be disposed of as scrap. The disposal of contaminated tnaterials and equipment will be in accordance with plart procedures for radioactive waste. Any additional solid waste requiring lard turial is not expected te be significant and therefore not an environmental burder. This aspect is also discussed in Section 2.4 of this report.

2.2 Accidents in Section 12 of the SE the staf' presented its evaluation of postulated accidents, including an accident during the reracking operations. Because the reracking was expected to be perfomed prior to the first refueling and therefore in a dry end uncontaminated condition, the staff concluded that the prcrebility of an accident involving the release of radioactivity and its consequences were insfori'icant. The sta'f has reviewed the additional in'orretion provided by the licensee with respect to the reracking in e wet and cor+erinated ccedition. Novement of original and new spent fuel racks durirg the recicking operation will be performed only without fuel assemblies in the rac6s. The spert fuel assetnblies will be positioned well away from the area where spent fuel rac6 movement is being conducted. Appropriate procedures arc rec 6 tear < port methods will be developed and adhered to ir order to control the mm. p rt of the spent fuel racts and to preclude the accidental dropping,

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t i; ; , c ;, ce s.tngin; cf a spent 'uel rack into ar adjacent rack in which spent fut' e:se-tlics have been leaded. Safe load paths will be designated to preclude the carry. g o' hea ) loads over racks containing spent fuel. Therefore, crision> with spent fuel stored in racks during the original rack removal and rew ract irstellatier phase is not considered credible, flased on its review of tre ir'en e'icr provided by the licensee, the staff has detemined that an criginal cr rew speat fuel rack will net collide with any spent fuel assemblies.

The s'e " a'so concludes thet tbc consequences of the other accidents previously evaluated in Stetion 12 of the SE, including the spent fuel handling accident, 4 aise addresset ir Section 9 of the SE, are ret affected by the wet reracking .)

and, therefore, tFe consequences do not change.

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The sta " cencludet that the method for remeval of the original spent fuel racks and for the installation of the new, high density racks, as proposed by the licersee, provice reasonable assurance that the reracking will not result in er accideet with a potential for the release of significant amounts of radicectivity er with a pctential for criticality. I 2.4 Emiroemental Impacts The ron-radiological environmental impacts of dry reracking were previously

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addretted in Sectico 4 of the Environmental Assessment (Ref. 3). The ron-  !

radiological environmental impacts o' wet veracking are the same as for dry rerac6ing. The non-radiological environmental effects of the reracking operatier itsel' and of operating the reracked pools are insignificant.

Radiological environmental irpacts of dry reracking were previously addressed in Section 3.0 of the Environmental Assessment. The dry reracking operatier would not have involved radioactive materfels and operation of the reracked pools would not significantly increase the radiological environmental lepects. Radiological environmental impacts of wet reracking are addrvssed in Section 2.2 of this Su.31ement. Two additional, potential sources of environmental '

i consequences were identified by the licensee for wet veracking. The consequences "

of an accident during the reracking operations having offsite consequences were found to be enveloped by the fuel handling accident previously evaluated in i Section 9 of the Safety Evaluation (Ref. 2). Another potential source of environmental consequences is the generation of radioactively contaminated wastes. The exact amount of radioactive waste which will be generated during reracking is not krown at this time. It will partially depend on the extent to which the original racks can be decontaminated. If none of the racks can be 4 decentar'nated a conservative upper bound of the amount would be less than i

half the uncompacted volume of the racks, that is, approximately 9,000 cubic feet per pool (Pcf. 8). Because the radioactive waste from wet reracting will be i packaced, transported, and disposed of in a manner consistent with NRC regulations, there will be nn significant radiological impact on the environment. This weste consists primarily of those orioinal spent fuel racks which cannot he decontar;inated.

It alse includes potential additional filters and other disposable r;aterial generated during the wet reracHng operations. This aspect is also addressed ir Section 2.? of this report.

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e. 7, .*, re,e;.'r, c'tre s po r t f u l pools we re previrr!') corsicered

• 1 [ r $ 3 r, e- t e i A s se ssr.er t (Fef. 3). Tte sin alterretives n 'er .r e 'c W te t c ir eric t tc the litersu 's proposed dry rerecl1r,g.

e:e e.*te- >et os( t een re-( > cr irt d ir c or;. a r i s c r tc wet rera c 61r:g.

:t Sc6 c iterat set were fourf f:? to otter er environrer tel acvar tegt ru t'. .et vt c_i ;rc;cial, becauts ite irpact of v.ct reret6 ing er the re* -

ar c r an-r a ct er ircrrett is net significant the t'urcen to lec6 for er.1 c' trie'1, krer1cr alterretises arc' te exar ,ne relatise cests is elirtiretec.

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• exa-ined tre relative ect nonic e6artage of wet rerac6 irg.

' 't ..;(*ste es* W tes that tre vet reracking effort will rest $13 ri'. lion for ee:r c* t. 'r u is 56 rnllicr rer unit rore than for the previcul) expected en. rera:61r;. fcr a reci fully loaced with 13?4 asserblies, this results in l a cct* c' att : 5' . rer 6; c' storage capacity in 1987 dollars for the wet ver :6 1rg. Irit is still cersicerably less expersive than buildire rew, ace'*';t ei stcrage f acilities either or site or away fror the site, Costs M c"1a ter with rerac61rg relative to new storage were eyrlcree in an IAEt l -c.i>:r.. GrcL: /Speciel151 Meetirg, (Ref. 13). Cap 1tal costs for rere c k ing

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• tre re mt cf 55 per kg to !!5 per kg, whereas (.epital costs for new

• ce' r;els for a t>c reactor site were $5? per 6 9, al'. in 1980 dellers. The

'.te* ' a r t ';ces t*at the wet rt rac6 ino cos t of 57! oer 6 9 (1967 dellars) is correrarle tc tre !! to $15 per kg (1980 dollars) anc is significantly lower Ifef tre cCst f Cr rev. fuel pocls,

2. f GAFiEX hEL'MCh AESCFE!NC KATERIAL Ey < tter cetec Fey 5,1967. Commonwealth Edison filed a report with the NPC re. cirg ga:s reesured in Bora' lex, the neutron absort-ir.g rnateriel used ir the rigt-cersity fuel storage rec 6s for the Quac Cities Statier. Since the f orafle> raterial is alto proposed to be used in the Fiegion 1 racks at Diablo Canfcr. tre AM staff issutt a letter te PG&E dated Jure ?,1967 (Ref.19) encicsirg tre re;crt anc requesting additional infor1 ration.

Ecrofle> 15 a trace ner.e for a beron carbice dispersion in a rubber-line retria raterial (elastor+ric silicone) ranufacturec by Bisce Products, Inc.

'te kra'le, is trarufacturec in lors sheets which are placed on the outsice of iterage ce'is to absorb neutrons ard thereby lower the effective rultit.licatice factor (kg,).

Gers were founc in soc.e of the Boraflex sheets at Ovad Cities, occurring in t*e urrer two-thirds of the cell length. The average gap was li irctes, with tre largest 4 ircres. The problerrs found at Ouad C' ties were also the sur dect c' an hit Irforratien Nctice ho. 67 a3, " Gaps ir heutron-At sorbing Pett 1a' 1r. Hqt-Density Spent f uel Sterage Fac6 s*, cated Septernber 8,1907 1*e reaest for additional inferration for Diablo Caryen was focused on the eccerte*ility cf the bore'les rateriel epplicatior at Diable Caryon, wr velerce prececures, and possible corrective acticrs if needed.

r its retrcrse detec August 4, 19F7 (Gef. ?C.), PGLE stated that it does not est et t tre (,ued Citiet problen tc cccur et Diablo Canyon, citing design ciffercrces. nevertheless. pCAE will vronitor onooing indus try progrars to e.eloete t' nature erd corsecuentes of borefler shrir6 age, further, PG&E rrrr uted to irt titute e nrveillance prograr to rcr itor f cr rrssitle Icog-terr

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,,,,e **a* 6 e x c ee;4 the Terteito l Spec 1'1(et ce s.;;M,.c:esnet t cf th3* rreara , PG? E will per'On- er irit el

r si '4-n m .. ta a s,es< it s t ic N " con inr tt+ unif m Presence c' f

F:q,* 3' te r-csitt a data F irt #0" f u ture referenct u t,..

re , 3 % * **e suru' ' lance prepeam estat lished by PG',[ end have

- ' u f. ; it31 it st; ' r* be e'fec'*se in dett.c t inc p ssit.le Fora fles 9 erg ? '

be'o't **r*Nid bo( P a probltn, Should significant cec'adatien d tiora' blackNss test? en full-ler gth e::< . t % ste '

• 1' recu re that per's t e cc a r tt ' te e s t a til is h the fui ' ext (nt of actual riegradat ter 4n the vt:ks.

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- it- c tw ier. t*e United States Fourt c' Appeals observed tFat . . .the site-s p. <- em -reemer tal assesseer.t w=s t.ased on a seven year old gereric envirrerental e<<ps.-t .

, apparertl y re'errirg te N ?fG-Pr.'!, the Final Generic frvironmentel

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i without specifying any particular area of cr'* em ., thet reither site-specif ic nor current inforr.ation was censidered in

+*e E*.tr'ce.ieeta' t<ses.rert (Ge'. 3). The continuing validity and site-specific t;; 's:at'l'ty c' the cerclusions ir the NUDEG-0575 have been confimed in the fr. ire-+e-tal Assessments for the Surry and the H 9. Robinson plants independent spec t 'ut ' storace irstellatioes (c e 's'. If and 16. respectively), and again in to fr teorv rtal Assessmert for the proposed reracking o' the Diablo Canyon r 3rt sper. fuel pools, pcth site-specific and current in'omation have been (cesid+rt-d in these frvironmenta' As!essments.

!c tr( certent o' rerachirg, the only potential Diablo Canyor, site-specific impacts are t*:se associatte' with the increase in waste heat; other irpacts are generic in nature. TFus, tFt- staf f deten ired in its Environmental Assessment for the Etat 1c Caryer flert, that *tre increase in waste heat frorn the additional storage c ' s pe r * 'uel wi'1 rave a negligible ef fect on the Pacific Ocean water temperature rear tre discharge." The lati c' site-specific discussion of terrestrial and radic.'ogical it;ects is dc e to the fact that causes 'or such impacts are net associatec with rerecking and operation c,f the high density pools. In addition.

• r tf* atserce ce significant environmental irrpacts frorr the proposed action, ar erwiroerer tal inpact statement (as opposed to ar. environmental assessrvnti nead tr* tm prepared and the burden of looking for environmentally superior alternatives 4 5 elirir a ted. However, due to the interest in possible alternatives to reracking e discussict o' alternatives was presided in the Environmertel Assessment which suwr-arized some of the significant problems associated with each.

Witt capact tc the currency c' the inf umation relied upon. the dis assion in t*e in.4ronmarta' tssessrent does take into account infomation rTre recent trar v ert.re r, for eva*p'e, the Nuclear Weste Policy Act o' 198? and the E r v i r r r-+ * ' i ' Assessments for tFe Surry and H. B. Robinsor Plants independent sport f uC storage insta11etiers, prepared as part c' the staff's IIcensing re , 4. erd is*,ue: ir April 19M and March inPf , respect ively (Pef s.15 and if ' .

Furth m re, to the erten* that the relierce was placed or WPEG-wr , the sta'f eg< r.4- n.d trat cata ord assured itself that the infomation is still ct,rrent .

'!,! ace !ri' ' FN M E ;;' H t c, N '*< n; 3 < u r, the Ceurt c' Ar rea's also otiserved that rc " worst cast" are'y!'s ar; ears t c r e s e t't'e r c orcut tee f or the sg.ert f uel pool est ar sion et

u t'c i.ar fer Units 1 and T. As rec;uired by 40 CFR IM'P.TP(b) (kef. 17),a

%rrst (ese" analysis ir er ersirenrettal impact statement was to be perforred eer M e rcatict cercernin; sigr4ficant echerse impacts relevert to f ull ccrs teeratin c' a prepesec action wcs r ot known. le 1986, this regulatier. was ererced it celete t'e recuirerert foi a *werst case" arelysis and a reovirenent was sutit'tuted tret a- impact steterert irclude, sutdect to the rule of reasor ,

u r !'cere' '(- ti the 'reescrat'ly foreseeable significant adserse impacts" of P' act10r (Le'. M). .

Tre st?, 1r its Sa'ety Evaluatier ano Envircrrrental Assessment (Pef. Ea) has accressec tctF tre se#ety anc ersironrental aspects of a fuel handlirg accidcnt, er ese-t w&4ct t cents the pctertial edstrse consequences of eccioents attributaMe tt c;eretier c' a spent fuel poci with high density rec 6s, irrespective of tr e Fer the irstellatico of the high der ,ity racks was accortplished in a vry, ur:crtea inatec cr a wet , contaminated pocl ers ironeert. A fuel handling " cident ray te $1ewec es e reasonatly foreseeable" design basis event stich the pcci erc its asscciated structures, systens and components (including the racks) are desigrec ard constructed to prevent. The envircrrental impacts of this accidert were tccre ret te be significant.

Ir 6eeping with 4 CFR 1502.??(b), the staff has corsidered accidents whose ccrsecuences right exceed a fuel handling accident, that is, beyond design tesis events. Such occurrences include a criticality accident and a rircelo) clac fire caused by overheating due to a loss J ment fuel pool cooling caused by e rcel failure. Corpliance with General Design Criteria C1,

• Fuel Storage ard Faedlir.g anc Racicactivity Centrol" and (2, " Prevention of Criticality in fuel Storage ard Hand 'g' of 10 CFR Fart 50, Appendix A, and adherence to a;;rc.ed irdustry CV 5 ard standards as set forth in the licensee's rerac6 ard icatier (which i ludes cortpliance with certain design erd construction criteria contained 1. the final Safety Analysis pepert) provides assurance ttat such events are of ery low probability by ensuring that pool and rack integrity and rool cooling capatility are maintained. Acceptance criterie for the Gereral Design Criteria consider all reasonably foreseestle events. Fcr enartl e, ir this ci,se, criticality is prevented by providing very strong racks l wtich will maintain the proper spacirg between fuel assemblies; the spent fuel  !

pool walls are rade of reinforced cercrete about six feet thick, rendering j pccl well failure a very urlikely event.

Ir bcth situatiers, the environmental irrpacts could be sicrificantt however, reither cf these events is considered to be within the rule of reason, that -

is, tre) are not reasonably foreseeable everts, in light of the design of the )

sEn t 'uti pools and racks. Trerefore, further discussion of their inpacts  !

it ret warrerted and the staff continues to conclude that the reasonably foreseeable irrects attributable to the proposed action are not significant l cre tr at er ervironeer tal irrect staterent neeci not be prepared. .

6. SU",*M V AC CO C US!0h5 it'e ste bes resiewec anc esclusted the reracking aspects associated with a

,e' te c contaminated rendition for Drits 1 and ? erd the gaps reported in the Ftraer reutron afscrbing raterial. The staff effort was based on ir'cen* ion provided t,y the licensee in subrittels ard during t'( Jaruary 22.

W ' reeting. based or its evaluation the staff concludes:

.p.

'*e rerosa' n' the origiral spent fuel racks ard the installation l c' the new, tigh density racks will be performed using Qualified and I tes*ed ecuir ent and in accordance with procedures to provide reaso.at'e essurance that an accidert with a potential for the r*' ease of a significant amount of radioactivity or for criticality kill rct occur.

2. Radietion p"otection and ALARA considerations have been taken and will be implemented te minirire perge9nel exposures.

The d4spesal o' the orioinal racks does not involve new or unique technicuts with respect'to the handling, decontamination and ultinate disresal.

4 There will be ne non-radiological impacts. The radiological impacts remair enveloped by the consequences of the fuel handling accideret previously evaluated for the spent fuel pool expansion. There will be no significant irpact te the environment from any waste disposal associated with tbc wet rerocking.

c. hone of the alternatives previously evaluated by the sta" is superior to wet reracking.

6. The commitments for surveillance and other actions contained ir PG&E's letter of August 4,1987 regarding Boraflex should be effective in detecting Bora'les degradation should it occur.

• be staf f cencludes that the proposed reracking of the Diabic Canyon Uni +> 1 and ? spent 'uel pools in a wet and contaminated condition is acceptabl'.

The sta'f has given further consideration, as suggested by the U.S. Court of Appeals for the Ninth Circuit, to the adequccy of the generic environmental impact statement and to the need for a " worst case" analysis with respect to its Environmental Assessment of Pay 21, 1086 for the spent fuel pool eFP8nsion.

The staff concludes that the consideration of more recent information does not charge its conclusion regarding the environmental impact statement and that even though a " worst case" analysis is not reovired, the potential adverse consequences of e4ther a wet or dry reracking operation are bounded by the staff's fuel hardling accident analysis.

7 CONTRIBUTORS ThO report was prepared by the staff of the NRC Of' ice of Nuclear Reactor Pegulation. Individuals participating in the preparation are:

Donald Clearv

• Robert Fell Hans Schierling Ar.arjit Singh Chseles Trannell James Wing

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! r? ~E:P ret OMI Letter DCL 85-33'. October 30, 1985 fror. D. A. Brand (PG&E) to

b. R . Den tor., Sub iect : License Arnendnent Recuest 85-13, Reracking of Spent rue' Peris.

a. U.S. Nuclear Peculatory Comission Letter from H. Schierling (NPC) tu J. D. SM"er IPGgr' dated May 30, 1986, transmitting Safety Evaluation, hetice, and Arwnd ent No. O to Facility Operating License DDR-80, Diablo Carven Unit 1. Docket Nr. SC-?75, and Amendment Fo. 6 to Fccility Operatirg

~

t icetse rs-S~, Diablo Canyon Unit 2, Docket f.'o. 50-3?3.

N rederal Pegister Notice, Vol. 51, No. 117, 72751, dated June IP,1986.

3a. U.S. huclear peculatory Ccernission, letter dated May 1,19% from H.

ScHerling f NRC) to J. D. Shiffer (PG%E),

Subject:

Environmental Assessment ard Finding of No Signi'icant Impact - Spent Fuel Fool Exper.sion, Diablo Canyon Nuclear Power Plant Units 1 and 7.

35. Federal Pe;ister Notice, Vol. 51, No. 103, 19430, dated May 29, 1986.

4 United States Court of Appeals for the Ninth Circuit, *0PINTON", dated September 11,1986 [799 F.?d I?68 (9th Cir.1986) and 804 F.2d 523 (9th Cir. 10EE.

5. U.S. huclear Pegulatory Comission Letter dated hovember ?4,1986, from H. Schierling (NPC) to J. D. Shiffer (PG&E),

Subject:

Diablo Canyon Spent Fuel Poc1 Peracking - Request 'or Additional Infomation.

6. U.S. Nuclear Regulatory Conriission Letter dated January 15, 1986, from W. Schierling (NRC) to J. D. Shiffer (PG8Ei,

Subject:

Request for Additional infomation on Wet Reracking.

7 U.S. Nuclear Regulatory Comission Meeting Sumary dated January 28, 1987 by H. Schierling (NRC),

Subject:

Meeting Sumary - Wet Reracking of Spent Fuel Pools, January 2?,1987.

8. FGAE Letter DCL 86-360, December 18, 1986, from J. D. Shtffer (P W ) to S. A. Varga (NRC),

Subject:

Diehlo Canyon Units 1 and 2, Additional Inforrition on Spent Fuel pool Peracking.

9. PGAE Letter DCL 87-018, February 2,1987, from J. D. Shiffer,

Subject:

Diablo Canyon Units 1 and 2, Recuest for Additional Information on Wet peracking.

1r. U.S. Nuclear Regulatory Comissior, Report NtfREG-0612. " Control of Heavy Losh at Nuclear Fower plants, Resolution o' Generic Technical Activity A 4 ,* July 1940,

11. U.S. Nuclear Regulatory Comission, " Safety Evaluation of the Diablo Canyon Nuclear Dower Station Units 1 and 2," NUREG-0675, Supplement M. ??, July 1944

l i

0 .

)l

!?

• Suclear Pegulatory Comnission, " Safety Evaluction of the Diable  ;

C a n ver Nuclear Power Station, Units 1 end I," NUREG-0675, Supplement l Nc 31, April 19AS.  !

? P.S. Department of Enerev, D07-30-0009 (UC-851, " Spent Fuel Storage Alternative,* Proceedires of an IAEA Advisory Group / Specialist Meetinc,  ;

Las Vegas, Nevada , USA November l'-21,19fC. 1 14 U.S. Fuclear Regulatory Commission, Report NUREC-0575, " Final Generic l Environmental frpact Statement on Handling and Storage of Spent light Water Fewer Reacter Fuel," Volumes 1 ? and 3 August 1979.

15. L'.S. Nuclear Regulatory ComPission, " Environmental Assessment Related to the Construction and Operation of .the Surry Dry Cask !ndependent Spent FLel Sterage Inste11ation, Letter from L. C. Rouse (NRC) to W. L. Stewart IVirgiria Electric Power Company), dated April 12, 1985.

16. U.S. Nuclear Regulatory Commission, " Environmental Assessment'Related te ,

the Construction and Operation of the H. R. Robinsen independent Spent '

Fuel Storage Installation," Docket No. 50-261, Caro 11ra Power and Light Corpany, March 1986.

17 Code of Federal Regulations, 40 CFR, Section 1502.2?(1985).

IF. Federal Register Notice Volume 51, No. 80, 15618, dated April 25, 1986.

19. NOC letter dated Jure 7,1987 fron C. M. Trarre11 (NRC) to J. D. Shiffer (PG&E),

Subject:

Reouest for Additional Information re: Boraflex.

rr. PG4E letter DCL 87-190. August 4, 1987 from 1. D. Shiffer (PG&E) to hDC, Sub.'ect: PGRE's response to NRC staf# request for additional information on Beraflex.

i i

9

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7590-01 FUCLEAR DFCL'LATORY COM"!SSION rA IFIC GAS A M FLECTPIC COMPANY DI AEL O CANv0* NUCLEAR POWER PLANT DOCKET N0!. 50-275 AND 50-323 NnTICE Gr Stl0PLFFENT TO ENVIRONMENTAL ASSESSwENT A C F!NDING OF NO SIGNIFICAt: T IFPACT The U.S. Nuclear Regulatory Conenission (the Conenission1 has issutd a Supplener.t to its oricinal Environmental Assessment and Finding of No Significant Irrect issued on May 21, 1996 and published in the Federal Pegister on May 29, 1986 (51 FR 19430) regarding proposed amendments to the cperating licenses authorizing modifications to the Diablo Canyon spent fuel rcols. The modifications would increase the capacity of each pool from 270 fuel asserblies to 1324 fuel assemblies.

Identi'ication of Proposed Action: The proposed action is an amen *nent to the operating licenses for Diablo Canyon Units 1 and 2 to authorize increased storage capacity of spent fuel by the installation of storage racks with closer spacing. The Supplement addresses the environmental impacts of conducting the conversion to the new spent fuel storage racks with spent fuel now stored in each spent fuel pool, which now are full of borated water (" wet reracking").

The original environmental assessment did not address this matter since the conversion was origirelly planned before the first refueling of each unit and therefore could be perforried in dry, empty spent fuel pools, y ,; f s af

.?.

?r addi+icr the supplement explairs how the riral Generic Environmental Ica:t Statement er Nrdling and Storage of Spent Light Water Power Peactor Fuel (M4EG-0575, August 1979' was relied upon in the staff's original site-srecific ersironmental assessment. The supplement also briefly discusses seve v beyond-design-basis accidents. Both of these discussions are in restense to corrents made by the U.S. Court of Appeals for the Ninth Circuit ir San Luis OH spo Mothers for Peace and the Sierra Club vs. NRC, 799 F.2d 1268 (9th Cir. 1986).

Suerary of Environmental Assessment: With respect to the matters discussed above, non-radiological environmental impacts due to the " wet reracking" are the same as those due to " dry" reracking, i.e., there are no additional environmental impacts due to this chance, and the impacts are insignificant.

As for radiological environmental impacts, the consequences of fuel damage during the wet reracking are enveloped by the standard fuel bandling accident previously evaluated. The wet reracking would generate additional '

contarirated waste, but its disposal would not create a significant radiological impact on the environment. The previous analyses of six alternatives is not impacted by the change to wet reracking; the alternatives _l considered continue to be inferior to reracking.

The supplement confirvis the continued validity of the generic j environmental impact statement and its site-specific applicability to recent environmental assessments at Surry, Robinson, and Diablo Canyon. ,

Beyond-design-basis accidents, such as a criticality accident and e i

rircelloy cladding fire caused by overheating due to a loss of pool water i l

caused by pool failure, are very low probability acciderts and are not viewed i as reasonably forseeable events. Therefore, further discussion of their irnparts is not required nr presented.

,j i

l The Comission has reviewed the proposed l

r3 : _ c' Sc 54ce cant Irpact:

t%. cr - and rther matiers discussed ahnse relative tc the requirernents set

'c r 9 'n 13 0~C P Fesed uper the supplerfnt to the environmental assessrent, the Comission centinues te conclude that there are no significant radielegicr1 cr non-radiological impacts associated with the proposed action a'd that the r-opesed license arnendments will not have a significant effect on t"e coe'ity c' the human environment. Therefore, the Comission reaffirrs its deteerination, pursuant to 10 CFR 51.31, not to prepare an environmental irract statement fer the proposed action.

For further details with respect to this action, see (1) the Environmental Assessment and finding of No Significant Impact dated May 21, 1987 and related hotice published in the Federal Register on May 20,1986 (51 FR 19430) and re'erences cited therein, and (?) Supplement to the Safety Evaluation and the Envi-onrental Assessment dated October 15, 1987 and references cited therein.

All o' these items are available for public inspection at the Corr-ission's Public Document Room,1717 H Street, N.W., Washington, D.C. 20555, and at the California Polytechnic State University Library, Government Document and Pass Department, San Luis Obispo, California 93407 Dated at Bethesda, Maryland, this 15th day of October, 1987.

FOR THE Nt! CLEAR REGULATORY COP.!SSION

[ fr Charles M. Tramell, Project Manager Project Directorate V -

Division of Reactor Projects-I!!, IV, V and Special Projects

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