ML050630380
| ML050630380 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/10/2005 |
| From: | Zamek J San Luis Obispo Mothers for Peace |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 69FR76481 00001 | |
| Download: ML050630380 (3) | |
Text
P.O. Box 164 Pismo Beach, CA 93448 (805) 773-3881 www.mothersforpeace.org February 10, 2005 Chief Rules and Directives Branch Division of Administrative Services
(
Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Comments regarding: Docket Nos. 50-275 and 50-323 - Pacific Gas and Electric Company, Notice of Consideration of Issuance of Amendments to Facility Operating Licenses for DPR-80 and DPR-82 Pacific Gas and Electric Company (PG&E) has proposed amendments that would revise Technical Specification 3.7.17 and TS 4.3 to allow installation and use of a temporary cask pit spent fuel storage rack for Diablo Canyon Nuclear Power Plant (DCNPP) Units 1 and 2.
The San Luis Obispo Mothers for Peace (MFP) opposes this proposed modification because of safety concerns.
It also objects to the mockery of the Nuclear Regulatory Commission (NRC) amendment process.
Safety Concerns Despite denials by both PG&E and the NRC, MFP finds that the proposed amendment WOULD (1)involve a significant increase in the probability or consequences of an accident previously evaluated; and WOULD (2) create the possibility of a new or different kind of accident from any accident previously evaluated; and WOULD (3) involve a significant reduction in a margin of safety.
Pool Fires:
The increase of storage cajipccity b-yanother 308 Spent Fuel Assemblies (SFA's) will inevitably lead to an increase of the risk to the citizens of California's Central Coast. Diablo's Spent Fuel Pools were originally designed, licensed, and built to contain no more than one and one third reactor core, i.e. 207 SFA's for each pool, and for no longer than five years. The re-racking which occurred in the 1980's brought the storage capacity to its present capability. The current storage situation is already stretching safety margins. It has substantially prolonged the stay of SFA's under more intense radiation, and it has created the additional danger of pool fires, where next to none existed prior to the re-racking. The possibility of pool fires has only been recognized by the NRC since 10/2000.
Security:
Moreover, the existing pools were not built with a 9/11 security situation in mind, and these pools lie outside the containment domes. Yet, they contain far more dispersible long-lived radioactivity than the domes which are structurally much stronger. Common sense indicates that any further increase of the radiation load in the pools will make the ramifications for the surrounding environment and population more severe should an act of malice lead to a substantial release of radiation. >-CaZbs - :7
- 5z75p ? ct2 4etfv SI $vk L C65:5) 7 Z2w "91-tLe -67/:3
Seismic:
With the recent seismic activity (2003 San Simeon and 2004 Parkfield quakes) in the region, such concerns must be taken into consideration. They are not, however, even discussed by either PG&E in its amendment request or by the NRC in its Federal Register notice. Much has been said regarding the integrity of the pools and the racks in the event of an earthquake, but can the fuel assemblies withstand the stress of an earthquake?
What effect have g-forces during earthquakes on older, possibly embrittled SFA's, boraflex panels, racks and racking alignment, and other aging components of the pools? Can the panels or other aged components be replaced? At what cost? Have studies been done to evaluate these questions?
Full core offload capability (FCOC):
FCOC is apparently not mandatory but only a "current operational practice" [last sentence 3.1, page 21.
- PG&E's argument-that-it must install the pit racks to avoid the loss-of -FCOC-is not compelling,-yet this is its sole given purpose for the amendment request. (See 3.1, page 2, "Purpose for Proposed Amendments".)
Contrary to PG&E's claim, the proposed amendment will only delay the loss of FCOC, not eliminate it.
When cask loading begins, the SFA's will have to be removed from the pit to the FCOC area in order to remove the pit rack and begin the cask loading. Each cask will take about three working weeks to load
[estimated 113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br />; Table 2.5 FEIR for ISFSI, page 2-30]. That assumes that all goes smoothly. That means the total time of loading the casks for clearing the FCOC area in the pools would take a minimum of:
154 SFA's .... 32 SFA's per cask = - 5 casks per pool at 113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br /> = 565 working hours. With 40 working hours per = - 14 weeks per pool. For a minimum of 28 weeks, FCOC will be lost if the temporary racks are installed. Even if PG&E or the NRC contests these numbers, provides double shifts, etc., it cannot be denied that the removal of racks from the cask pits and preparations for cask loading will take many working hours, and there will be many weeks when FCOC will be lost.
Movement of SFA's:
Any reshuffling of SFA's in the pools will add additional risks. The pit rack will not be loaded with only new SFA's from the reactor. As with the existing racks, a proper mixture of older and newer SFA's is required. This means that older SFA's need to be moved from the existing racks to the pit racks [4.4.3 "Fuel Handling accidents", page 25]. PG&E also may have to re-shuffle SFA's in the existing racks in order to accomplish the correct mixture there. This means that there will be juggling of many SFA's in the pools. The older SFA's have been subjected to intense radiation for at least 10 years longer than was anticipated when the racks were placed into the pools in the 1980's. As mentioned above in regards to a seismic event, can these older assemblies sustain the stress of movement? What impact does this prolonged radiation exposure have on the older SFA's? Have studies been done on the effects of prolonged radiation on: SFA's, the racking materials, the boraflex panels, other aging pool components? What about material embrittlement due to much longer than anticipated radiation exposure? Will the cladding break down?
Is it assured that the additional moving of older SFA's does not deteriorate their integrity for acceptance at final repository? Can assurance be given that the older SFA's will not lead to problems of removing them again from the pit racks? Might the assemblies jam? How can cask loading begin if SFA's cannot be removed from the pit racks? Isthere a method or equipment in place to remove a "stuck" SFA from the pit rack? None of these concerns or questions has been addressed by PG&E or the NRC.
Mockery of the Process Delays:
PG&E has caused the untimely filing of this license amendment itself. It filed for an ISFSI in November 2001, but it has been known since at least 1998 that more waste storage capacity would be needed at Diablo Canyon Nuclear Power Plant. It has also been well known since 1995 that Yucca Mountain would not become available in time to solve the waste storage situation for Diablo Canyon. The only alternative for shipping the SFA's off site would have been the proposed temporary Federal above-ground facility near Yucca Mountain. That proposal passed both houses of Congress, but then it failed on a veto by Clinton. This also happened before 1998. Why did PG&E wait until November 2001 with their application for an ISFSI?
In addition, delays during the application process itself should have come as no surprise to PG&E, given the long history of delays at Diablo.
Notification:
Although MFP is on the PG&E Diablo Distribution list, its License Amendment Request 04-07 was not delivered. MFP had to request this document after learning of the opportunity for a hearing in the Federal Register.
NRC Policy:
MFP finds the NRC policy regarding the issuance of this proposed amendment request offensive. As stated in the Federal Register, December 21, 2004, Volume 69, Number 244:
"Normally, the Commission will not issue the amendment until the expiration of 60 days after the date of publication of this notice. The Commission may issue the license amendment before expiration of the 60-day period provided that its final determination is that the amendment involves no significant hazards consideration. In addition, the Commission may issue the amendment prior to the expiration of the 30-day period should circumstances change during the 30-day comment period such that failure to act in a timely way would result, for example in derating or shutdown of the facility."
This policy discourages public involvement, for it clearly states that any outside input - regardless of merit - is completely ineffectual. The NRC has obviously already made its determination.
==
Conclusion:==
The many uncertainties, reduced safety margins, unanswered questions, additional risks, and costs weigh against the amendment request. The possibility of potential problems with the removal of the temporary pit rack and the temporary loss of FCOC is especially disturbing and should decide against the amendment. MFP asks that the NRC denies PG&E's request.
Submitted by, Jill ZamEk San Luis Obispo Mothers for Peace