ML18079A281
| ML18079A281 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/30/1979 |
| From: | Moore T, Beverly Smith NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML17193A281 | List: |
| References | |
| NUDOCS 7905150192 | |
| Download: ML18079A281 (21) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE ELECTRIC &
GAS COMPANY (Salem Nuclear Generating Station, Unit No. 1)
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Docket No. 50-272 Proposed Issuance of Amendment to Facility Operating License No. DPR-70 NRC STAFF 1 S RESPONSE TO LICENSEE 1 S MEMORANDUM IN SUPPORT OF ITS MOTION FOR
SUMMARY
DISPOSITION The NRC Staff supports the Licensee's February 27, 1979, Motion for Summar:-y Disposition for the reasons discussed herein.
The Staff expressly states its agreement with the Licensee's 11Preliminary Statement 11 and discussion of the
11Background
11 at Parts I and I I of its 'Memorandum in Support of* the Motfon.
The Staff further notes that by 1 etter of Apri 1 12, 1978, the licensee submitted Amendment No. 42 to the Salem Station FSAR, indicating that it plans identical modification to the Salem Unit No. 2 fuel pool.
The Salem Station Final Environmental Statement considered the environmental impacts of the Salem Station - Units 1 and 2.
There-fore, the Staff addressed the cumulative environmental impacts of the
- expansion of both spent fuel pools in its Environmental Impact Appraisal.
Argument with Respect to Colemans 1 Contention 9 and LACT 1s Contention 1 The Staff agrees with the Licensee that the.Colemans 1 and LACT 1s conten-tions 9 and 1 respectively are ripe for summary disposition.
The Staff
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has considered, in its Environmental Impact Appraisal, various alterna-tives to the proposed action of expanding the spent fuel capacity at Salem Unit 1.
Alternatives considered include:
reprocessing of spent fuel, storage at i ndepen<lent spent fuel storage i nsta 11 ati ons, onsite storage in Salem Unit 2 spent fuel pool (SFP), offsite storage in SFP 1s of othe*r reactors, shutdovm of the faci 1 i ty and conservation measures.
(EIA, pg. 12).
As will be discussed below, none of the alternatives as proposed by the Intervenors or independently assessed by the Staff repre-sent a viable option because they will not be available within the time
-frame required to avoid a shutdown of the unit from shuting dm*m in 1983 or losing of the ability to discharge a full core.
(EIA, pgs. 2, 13-20).
In addition, none of the alternatives offer an environmentally or economically preferrable method of storage.
Storage of Spent Fuel at Reprocessing Facilities There are currently no commercial reprocessing facilities operating in the United States.
The U. S. government 1s policy is to defer reprocessing indefinitely~
NRC has terminated proceedings involving reprocessing and has announced that it will not consider applications for commercial facilities for reprocessing spent fuel fabricating mixed oxide fuel, or related functions.
(EIA, pg.14). Therefore, the Staff did not consider reprocessing as a reasonable alternative to the proposed expansion of the Salem Unit No. 1 SFP (EIA, pg. 14).
However, the Staff considered utilizing the Morris Operation, Nuclear Fuel Service, Inc. (West Valley) and Allied-Gener&1 Nuclear Services (AGNS), the three reprocessing facilities in the U.S., as 11 independent spent fuel storage installations (ISFSI). 11 (EIA, pg. 14).
Although the Morris Operation (MO) is in a decommissioned condition it is serving as an ISFSI.
The storage at MO is reserved for General Electric owned fuel or fuel GE has previously committed to store.
There is no such.commitment for Salem (EIA, pgs. 13, 14).
NFS has space to store spent fuel, but is not accepting additional spent fuel for storage even from those re~ctor facilities with which it had reprocessing contracts.
(EIA, pg. 15).
AGNS has applied for a license to store spent fuel.
Action on this request has not been completed and there is no reason to believe that storage will be available within the time frame required by Salem 1.
(EIA, pg 14).
As indicated in the affidavit of Edward Liden, attached to Licensee's motion, the AGNS facility will not be operated for the storage of reactor fuel assent reprocessing.
It is clear that storage of spent fuel at reprocessing facilities is not a reasonable alternative.
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The Staff also considered the construction of new ISFSis and detennined that at least five years would be required to construct an ISFSI, which would cost more than the proposed Salem Unit 1 spent fuel pool modifica-
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ti on.
(EIA pp. 13-16). -The Staff also determined that the environmental impacts of constructing an ISFSI would not be less than those of the proposed action.
(EIA, pg. 16).
Based on the above, new ISFSis can not be considered reasonable alternatives.
The U.S. government has committed to provide interim fuel storage facili-ties, if adequate private storage facilities can not be provided.
These will not be available until at least 1983 or 1984.
These are not precise dates, and therefore, this can not be considered a reasonable alternative (EIA, pg. 16).
Storage of Spent Fuel from Salem No. 1 at the Storage Pools of Other Reactors - Onsite and Offs"ite The Staff considered the use of Salem Unit 2 SFP for spent fuel storage from Unit No. 1.
This alternative would fill both an enlarged pools by 1983, adversely impacting Unit 2 operation, and provides only a temporary alternative.
(EIA, pg. 17).
If this alternative were pursued, it would cause extra handling of irradiated spent fuel and working in the presence of the contaminated racks which would not be consistent with the require-ment of 10 CFR Pa-rt 20, to maintain occupational exposures 11as low as reasonably a chi evab 1 e 11 (ALARA).
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The Staff independently considered the expansion of the Unit 2 SFP rather than that of Unit 1 and use the pools for the storage of fuel from both Units.
This would result in Unit 1 being filled in 1982 and.Unit 2 in.
1989.
As with the case ~escribed above - using both unenlarged pools, thi:s \\tJ6l11 d not be consistent with ALA RA.
Although an acceptable alter-
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nativ.H~~i-t would __ have greater environmental impacts than those associated
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with the proposed'..amendment.
(EIA, pg. 17).
Hope Creek Units 1 and 2, located on Artificial Island, are under con-struction.
It is unlikely that the spent fuel pools would be available to accept spent fuel from Salem Unit 1 before it was filled.
Since these units are BWRs and Salem 1 is a PWR, the racks at Hope Creek 1 and 2 would have to be made compatible with PWR fuel if Salem 1 fuel were to be stored there, and space for fuel from Hope Creek's spent fuel would be reduced.
(EIA, pg. 18).
The alternative of storing at other sites was considered.
In light of the Energy Research and Development Agency's (Now DOE) survey findings that up to 46% of operating nuclear plants will lose the ability to refuel during the period of 1975-1984, it is unlikely that space at other sites will be available for Salem Unit l 1s spent fuel.
(EIA, pg. 18).
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Storage Outside the United States Since storage of spent fuel outside the United States is against the policy of the United States government, this is not a f easible
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alternative.
(Zech affadivat, par. 5).
Shutdown of Facility The licensee estimated that a shutdown of Salem Unit No. 1 would result in replacement power costs of $500,000 per day.
This estimate assumed Salem Unit No. 1 operating at 100% power.
The Staff assumed a more realistic capacity factor of 60-70%.
This resulted in a replacement cost of $300,000 to $350,000 per day, which in a very few days 1'/ould exceed the costs associated with the proposed modification i.e. $3,000,000.
(EIA, pgs. 18, 19).
Conservation Measures Conservation measures were explored as a means of reducing the production of spent fuel at Salem Unit l. If conservation measures reduced demand, Salem Unit 1 ~ the most economical to operate of the PSE&G units, would be operated as a "base load unit.
11 Operating Salem Unit 1 at reduced power, to account for conservation, results in the need to use less economical units.
In fact, assuming that conservation results in extending opera-tion by a factor of two, the k1>1-hr replacement power would extend for twice the time period, but at half the rate. This is equivalent to the cost of a shutdown of the facility.
(EIA, pg. 19).
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Extending the fuel cycle from 12 to 18 months was considered by the Staff as an alternative to the proposed amendment.
This does not change the amount of fuel to be discharged, and therefore is not a feasible alterna-tive.
(EIA, pg. 19)
The Staff evaluated the potential environmental impact associated with the expansion of the storage capacity of the spent fuel pool and determined that:
"[T]he proposed license amendment will not significantly affect the quality of the human environment and that th~re will be no significant environmental impact attributable to the proposed action other than that which has already been predicted and described in the Commission's Final Environmental Statement for the Facility dated April 1973."
This conclusion is based on the finding made by the Staff that expansion of the storage capacity of the Unit 1 or the Unit 2 SFP \\'JOul d not result in:
- 1.
Any significant unavoidable adverse environmental impacts on the land, water, air or biota of the area.
(EIA, pg. 20).
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Creatfon of any significant radiological effects, (EIA 5 20).
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Any change in the evaluation of long term use of the land (EIA, pg.
- 21) *
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Significant change i'n the commitments of \\'tater, land, and air resources.
(EIA, pgs. 5, 9, 21)
- 5.
A commitment of resources that would tend to significantly foreclose the alternatives available with respect to any other individual licensing action designed to ameliorate a possible shortage of spent fuel storage capacity.
(EIA, pg. 21).
The Appeal Board recently affirmed, in a spent fuel pool.expansion case, its prior position that alternatives do not have to be pursued when the proposed action neither (1) entails more than negligible environmental impacts nor (2) involves the commitment of available resources respecting which there are unresolved conflicts.
Portland General Electric Company, et al.
(Trojan Nuclear Plant), ALAB-531, 9 NRC
, Slip. Opinion at pg. 5 (March 21, 1979).
Although the Staff in the exercise of prudent discretion has analyzed alternatives to this proposed action, as a matter of law, it was und~r no obligation to do so once it had made the finding described above~
Conclusion with Respect to Colemans Contention 9 and LACTs Contention 1 As demonstrated above, no genuine issues of material fact remain to be resolved concerning alternatives to the proposed action which is the subject of Colemans' Contention 9 and LACT's Contention 1.
Therefore, the Licensing Board should grant the Licensee's Motion for Summary Disposition.
Argument with Respect to Colemans Contentions 2 and 6
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The Staff agrees with the Licensee's argument that Colemans Contentions 2 and 6 contain no genuine issue of fact and therefore are ripe for summary di~position.
These contentions allege that the spent fuel storage cells, which contain I
the neutron absorption material wiJl deterioriate over their design life time.
The Staff has considered the materials used by the Licensee and has concluded that there should be no significant deterioration.
Even if there is some deterioration of the boral material, this will not affect its neutron adsorption capabilities (SER 2-2, 13, 15). Since the Staff does not anticipate significant deterioration, it did not consider acci-dental criticality due to the increased density or compaction of the spent fuel assemblies.
Description of Racks and Spent Fuel Storage Cells The spent fuel storage cells are constructed of type 304 stainless steel, aluminum clad boral material, with the remaining portions of the rack structures constructed of type 304 stainless steel. This is in accord-ance with the ASME Boiler and Pressure Vessel Eode, Section 3:
(SER
- 2-10, 2-12, Weeks affidavit, pg. 2).
The new spent fuel storage cell utilizes a Boral composite sealed between an inner and outer stainless steel shroud.
Boral consists of 1100 series aluminum and boron carbide (B4C/Al) matrix core sandwiched between two*
layers of 110 series aluminum cladding.
(SER 2-13, Weeks' affidavit pg.
- 2) *.
Th~~ stainless steel shrouds are seal welded together at both ends su\\~h tr~g;t the annulus between the shrouds is leak tight (SER 2-13).
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Potential Sources of Corrosion Two potential sources of corrosion of the spent fuel storage racks are considered by the Staff and Licensee.
The first is the interaction of aluminum with water and the second is the interaction of aluminum in contact with stainless steel in water environment.
Interaction of Aluminum with Water At the Monticello nuclear power plant, leakage occurred in the spent fuel storage cells which are similar in design to those the Staff is considering in this proceeding.
When leaks occur, allowing water to enter the annulus, there is corrosion of the aluminum with hydrogen gas as an off product.
Eventually the pressure builds up and the inner shroud will bulge inward and contact the fuel bundle (SER, 2-13, Week's affidavit, pg. 3, BNL~NUREG-25582.)
If leakage occurs, Exxon Nuclear Company, supplier of Salem Unit 1 's spent fuel storage cells, has determined, by testing, that the worst case
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would be the inability to insert the fuel into the cell.
In ad di ti on if a leak develops while the fuel is within the storage cell, the most severe result would be that the fuel could not be withdrawn with the normal fuel withdrawal force limit of the fuel handling machine.
(SER, 2, 4).
If this were to occur~ the licensee will provide vent holes in the top of th~ storage cell annulus to relieve the pressure on the fuel assembly which will permit routine removal (SER, 2-14).
The Staff does not believe that leakage is likely to occur; however, they have reviewed the tests conducted by Exxon Nuclear, and concludes that the swelling of the spent fuel storage cells does not represent a safety hazard (SER, 2-15).
In order to avoid the problem that occurred at the Monticello facility, bulging of the storage cells, the Licensee is imposing strict welding procecures, nondestructive examination requirements, and leak-tightness tests using helium mass spectrometer tests to ensure 95% leak-tightness with a 95% confidence level.
(SER 2-13).
In addition the quality assurance procedures for materials, the fabrication, the installation and the examination of the new rack structures are in acceptable general conformance with accepted requirements of various codes (SER, 2-11).
Interaction of Aluminum in Contact with Stainless Steel and the Subsequent Effect on Boron Carbide The aluminum cladding which surround the Boral *is in contact with the stainless steel shroud protecting the storage cells.
If water enters
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through the stainless steel shroud, there will be galvanic corrosion wher~ the aluminum cladding is in contact with the stainless steel. This is known as pitting corrosion.
(Weeks affidavits pg. 3, SER; 2-15).
Tes;ts have shown that Boral with a leak in the stainless steel covering
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ha\\h*~ sh-own a corrosion rate to be less than 1.5 x 10-4 mils/day in neutral
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water at 125°C..
- ~bcounting for the water chemistry and extrapolating this datum for 40 years, this results in 0.5 mils in 40 yearso (Weeks affidavit 5 pg. 3). The deterioration is in confined to a small area.
Boron carbide is not dislodged because it is inert to the pool water and becomes embedded in the corrosion productso Therefore, this small and unlikely amount of *deterioration would have no effect on neutron shielding, attenuation properties or criticality.
(SER, 2-15, Weeks affidavit, pg.
- 2)
The Staff has examined studies of Baral material, which has been exposed in water for periods up to 20 years, and the stainless steel rack struc-tures, including operating experience, and has concluded that there is no evidence of significant deterioration.
(SER, 2-14, 15, Weeks affidavit, pg. 3).
At the pool temperature and the quality of the demineralized water (with dissolved boric acid), the Staff has also concluded that there is reasonable assurance that no significant corrosion of the
- stainless steel racks will occur over the lifetime of the plant.
The Staff recognizes the possibility of long-tenn storage of spent fuel,
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therefore, the effects of the pool environment on the racks are under continued investigation (SER, 2-14).
In addition the licensee has committed to conduct a long-term fuel storage surveillance program to -------------
verify that the spent fuel storage cell retains the properties over the design life time of racks under actual spent fuel pool service conditions
{SER, 2-15).
The Staff considered the long-term exposure of Boral to the spent fuel environment with respect to exposure to low-level radiation.
The con-clusion is that there is no effect.
(Weeks affidavit, pg. 4)
Conclusion with Res_Q_ect to Colemans 1 Contention 2 and 6 As demonstrated above, no genuine issues of material fact remain to be resolved concerning the integrity of the neutron absorption material or the integrity of the spent fuel rack structure which are the subjects of the Colemans Contentions 2 and 6. Therefore, the Board should grant the Licensee's motion for summary disposition on these contentions.
Arguments with Respect to LACT Contention 3 As *demonstrated by the attached affidavit of Gary G. Zech, and the rea-soning presented below, we support Licensee 1s determination that Lower Alloways Creak To~nship Contention 3 is an appropriate contention for summary disposition and dismissal.
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Petitioner contends that, s i nee the proposed 1 i cense amendment does not
-iimit the use of Salem Unit l's enlarged spent fuel pool to the storage of spent fuel from Salem Unit 1, spent fuel from other facilities located on and off of Artificial,Island could be brought to Salem Unit-1 -for--
storage.
Such activity, Petitioner contends, would result in increased hazards -which have not been evaluated by the Licensee.
This contention actually refers to three separate activities in which the Petitioner feels the Licensee could engage, although they are not specifically mentioned.
These activities are: l) the transfer of spent fuel owned by other utilities from plants located off of Artificial Island to Salem Unit 1 1 s spent fuel pool for storage; 2) the movement of spent fuel between Salem Unit 1 and Unit 2; and 3) the transportation of spent fuel from Hope Creek Generating Station, the other nuclear power plant located on Artificial Island, to Salem Unit l's spent fuel pool for storage.
This contention does not present a triable issue of fact, because the regulations of the Nuclear Regulatory Commission (NRC) provide the limitation to the license amendment which Petitioner contends is lacking.
That is to say, the Commission's regulations limit PSE&G's use of the enlarged Salem Unit 1 spent fuel pool to the storage of Salem Unit 1 's spent fuel unless a further license amendment is sought by the Licensee and issued by the Commission.
I.
PSE&G May Not Bring Spent Fuel Owned By Other Uti 1 i ti es To Salem Unit 1 For Storage Without First Receiving An Amendment To The Part 30 And 70 Portions Of Its Operating License, Since PSE&G Does Not Now Have The Authority To Receive Byproduct and Special Nu cl ear Material (Spent
.\\ Fuel) Produced By The Operation of Other Facilities For Storage At Salem Unit 1.
Since spent fuel is a combination of byproduct and special nuclear material, the authority ;to receive title to, own, acquire, deliver, receive, posses, use, or transfer spent fuel is controlled by 10 CFR Parts 30 and 70.
These two parts of the Commission's regulations require licenses to be issued by the Commission before receipt, possession, use, et~., of byproduct and special nuclear material can begin.
10 CFR ~~30.3 and 70.3.
The Commission is authorized by its regulations to combine in one license activities which would otherwise require separate licenses.
10 CFR ~50.52.
In its facility operating license No. DPR-70 for Salem Nuclear Generating Station Unit 1, PSE&G has been granted certain rights with respect to byproduct, source, and special nuclear materials.
Section II.B.6 of facility operating license No. DPR-70 states:
11 PSE&G is licensed to posses but not separate such byproduct and special nuclear materials as may be produced by the opera ti on of the facility.
11 The term 11faci1 i ty 11 is defined in Section II.A. of this facility operating license as 11 *** the Salem Nuclear Generating Station Unit 1, a pressurized water nuclear reactor and associated equipment.
11 Section II.B.6 of this license does not authorize PSE&G to receive for storage in Salem Unit l spent fuel pool byproduct and special nuclear materials produced by the operation of other facilities.
Receipt of special nuclear material is specifically authorized in Section II.B.3 of Salem Unit 1 operating license to the extent that it will be used as reactor fuel.
The receipt of byproduct, source, and special n~clear material is authorized in other sections of the operating license fo'r specific purposes such as: sealed neutron soui~e?'for reactor startup, instrumentation and radiation monitoring
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equiprnf-rd: calibra.tion, and sample analysis.
Facility operating license
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No. DPR-70 Sectich~*II.B.4-5. This license contains no specific authori-zation for PSE&G to receive at Salem Unit l spent fuel from any other facility.
In order to store spent fuel from facilities owned by.other utilities, PSE&G would be required to seek an amendment to Section II.B.6 of its operating license specifically granting it the authority to receive byproduct or special nuclear materials from other named facilities.
II.
PSE&G May Not Move Spent Fuel From Salem Unit 2 to Salem Unit 1, Once Salem Unit 2 Is Operating, i~ithout An Amend-ment To Salem Unit 1 1s Facility Operating License Since, In The Opinion Of The NRC Staff, Such Movement Would Involve An Unreviewed Safety Question.
Under 10 CFR ~50.59(c) if a Licensee wishes to make changes involving an unrevi ev1ed safety question either in the facility, or in the procedures described in the FSAR, he must apply to the NRC for an amendment to his operating license.
Such an application must describe the changes requested and, as far as possible, must follow the fonn of his original operating license application.
10 CFR ~50.90. Under the regulations governing applications for an operating license, a safety analysis report of the proposed activity must be compiled and submitted to the Commission.
'_.',. 10 CFR ~50.34(b).
In considering whether to issue such an amendment, the Commission must determine whether the proposed activities will endanger the health and safety of the public.
10 CFR ~~50.91 and 50.40(a).
The Licensee in the most recent version of its FSAR has stated that each
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unit'of the Salem Nuclear Generating Station has a completely independent
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s fuel handling sysi~m~ FSAR s9.7. It also states that fuel will be moved from the reactor cavity through a fuel transfer sys tern to the spent fuel pool.
FSAR ~9.7.2.l. This description makes no mention of the possibility of moving spent fuel from the reactor cavity of Salem Unit 2 to the spent fuel pool of Salem Unit l for storage.
The FSAR makes no mention of how such an activity might be accomplished.l/ Therefore, a change in the fuel handling procedures described in the FSAR would be necessary if PSE&G decided to store Salem Unit 2's spent fuel in Salem Unit 1.
Since the Staff was never supplied any information concerning fuel move-ments between units, it has not had a chance to review the possible safety questions resulting from the additional movement of heavy spent fuel* casks which the proposed activities would require.
Zech Affidavit, para. 8.
It is, therefore, the Staff opinion that the activity would ll Since the issuance of its FSAR and amendments, Licensee PSE&G has stated that it has no need or incentive to store spent fuel from any other facility in Salem Unit 1 spent fuel pool.
PSE&G 1s Molion for Summary Disposition, filed February 27, 1979.
Affidavit of Edwin A. Liden, p. 14.
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., involve an unreviewed safety question.
This means that to move fuel from Salem Unit l to Salem Unit 2, PSE&G must apply for an amendment to its facility operating license No. DPR-70.
At that time the Commission would make the determination.as to \\'Jhether the activity would. endanger the health and safety of the public.*
~--;,r II..PSE&G May Not Transfer Spent Fuel From Hope Creek
-.:,-.,.;~;~Generating Station, The Other Nuclear Plant Located On
- ,'.l.Y*~ Artifici*a:l Island, To Salem Unit l For Storage Without A License~Amendment~ Since Such An Activity Would Involve An Unrevie\\ved Safety Question.
As discussed at page 16, supra, if a change in the procedures described in the FSAR would raise an unreviewed safety question, the Licensee must apply for an amendment to his operating license.
At the time of applica-ti~n for such an am~ndment the Commission would consider the possible safety hazards resulting from the proposed activities.* See, p.
16~
supra.
Hope Creek Generating Station will use boiling water nuclear reactors.
In order to store BWR fuel in a PWR spent fuel pool, the fuel storage racks would need modification.
See, Zech Affidavit, para. 12.
The Licensee made no reference in its FSAR to the possibility of storing fuel from Hope Creek at Salem Unit l.
The FSAR made no mention of the modifi-cations in the fuel storage racks necessary to accomodate BWR fuel.
The NRC Staff did not review the possible use of any storage racks other than those speci fi ca lly described by the Licensee in the FSAR.
Therefore, any
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~, ____ attempt by PSG&E to store the spent fuel from Hope Creek at Salem Unit 1 would, in the opinion of the Staff, give rise to an unreviewed safety question.
PSE&G must, therefore, file an application for a1J!endm~_~t __ of---------
its facility operating license No. DPR-70 to modify the fuel storage racks to accomodate BWR fuel.
In issuing this amendment, the Commission must consider whether the hea 1th and safety. of the pub 1 i c wi 11 be endangered by the proposed activity.
See, 10 CFR ~50.91 and §50.40(a).
Conclusion As demonstrated above, no genuine issues of material fact remain to be resolved concerning the possible shipment of spent fuel from other facili-ties to Salem Unit 1 spent fuel pool for storage at this time, which is the subject of Lower Alloways Creek Township Contention No. 3.
There-fore, the Licensing Board should grant the Licensee's Motion for Summary Disposition.
Arguments with Respect to Coleman's Contention 13 The Staff supports the arguments presented by the Licensee for the reasons given below.
The Staff considered the cumulative impacts of gaseous radioactive material released-to the atmosphere from the increased spent fuel storage pools at Salem Units 1 and 2.
Kryton-85 is the only significant noble gas isotope attributable to storing additional assemblies at Salem Unit 1 and 2.
The Staff concluded that after spent fuel has decayed a few months, there is no significant release of fission products from depec-tive fuel.
(EIA, pg. 6, 7).
To be conservative the Staff assumed an addition 114 curies per year of kryton-85 \\'/Ould be released from Salem Units 1 and 2.
This results in an additional total body dose to an individual at the site boundary of less than 0.005 mrem/year, This dose is insignificant when compared to the approximately 100 mrem/year that an individual receives from natural background radiation.
The additional total body dose to the estimated population within a 50-mile radius of the plant would be less than 0.005 man rem/year.
This dose would be less I
than the natural fluctuations in t~e annual dose that this population would receive from natural background radiation.
(EIA, pg. 7). These exposures represent an increase of less than 0.5%of the exposures from the station evaluated in the Salem 1/2 FES for an individual at the site boundary and the population.
(EIA, pg. 7).
The doses described above are well below the magnitudes alledged in Contention 13 (See Licensee Motion, affidavit of Robert P. Douglas).
The Staff also considered the release of tritium and iodine and concluded that any increase would not be significant. There is a potential for an increase in release of there two isotopes due to a temporary higher*
evaporation rate from the spent fuel pool.
These releases would be small when compared to normal releases of these isotopes from the station.
The normal levels have been evaluated ;ii*: the Salem 12 FES and are control led by the radiological effluent Technical Specifications.
(EIA, pg. 8).
Conclusion with Respect ~o Colemans 1 Contention 13
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As demonstrated aboves no genuine issues of material fact remain to be
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resolved concerntng cumulative impacts which is the subject of Coleman's
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Contention 13.
Therefore, the Licensing Board should grant the Licensee's Motion for Summary Disposition.
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Respectfully submitted Barry H. Smith Counsel for NRC Staff Janice Moore Counsel for NRC Staff