ML18081B184

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Memorandum & Order Re Intervenors a & E Coleman Motions. Denies Reinstatement of Contentions 7, 9 & 13.Grants Motion to Supplement Contentions 2 & 6.Clarifies ASLB 790418 Questions & Sets Evidentiary Hearings Per Separate Notice
ML18081B184
Person / Time
Site: Salem 
Issue date: 02/22/1980
From: Milhollin G
Atomic Safety and Licensing Board Panel
To:
References
NUDOCS 8003130101
Download: ML18081B184 (24)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Gary L. Milhollin, *Esq., Chairman Dr. James C. Lamb, III Frederick J. Shon In the Matter of Docket No. 50-272 PUBLIC SERVICE ELECTRIC &

GAS COMPANY

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(Proposed Issuance of Amendment to Facility Operating Li6ense No. DPR-70)

(Salem Nuclear Generating Station, Unit No. 1)

MEMORANDUM AND ORDER (February 22, 1980)

This memorandum and order is in response to four_ motions filed by Alfred and Eleanor Coleman, who have intervened in this proceeding, and to objections filed by the Staff of the Nuclear Regulatory Commission to a question which was propounded to the Staff by the Board.

In this memorandum and order we deny three of the four motions filed by the Colemans, clarify the question we propounded to the Staff, and set the date for further hearings.

The Colemans' Motion to Reinstate Contention 7 The Colemans' Contention 7 was dismissed on May 25, 1978 by our Order Following Prehearing Conference.

The Contention asserts that the Licensee, Public Service Electric & Gas Company, has given inadequate c onsidera tfon to the effect of *.....

storing spent fuel in the spent fuel storage pool at th~. -~~'~;m /<\\l

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Nuclear Generating Station, Unit 1, at Salem, New Jersey, for a period of. time exceeding the duration of Salem's Unit 1 operating license.

In our Order, we held that consideration of storage beyond the duration of the operating license was expressly excluded by the decision of the Atomic Safety and Licensing Appeal Board in Northern States Power Company (Prair-ie Island Nuclear Generating Plant, Units 1 and 2) ALAB-445, 7 NRC 41 (1978).

The intervenors-have now moved to reinstate Contention 7 because, since the date we announced our Order, the United States Court of Appeals has remanded the Prairie Island decision to the Commission.

State of Minnesota v. NRC, 602 F.2d. 412 (D.C. Cir., May 23, 1979).

The Commission, in response to the remand, has** issued a notice of proposed rulemaking addressing the questions which the court remanded.

The rulemaking includes the issue of storage at reactor sites for periods exceeding the duration of operating licenses.

In the notice the Commission said:

"During this [rulemaking] proceeding the safety implications and environmental impacts of radioactive waste storage on-site for the duration of a license will continue to be subjects for adjudication in individual facility licensing pro-ceedings.

The Commission has decided, however, that during this proceeding the issues being con-sidered in the rulemaking should not be addressed in individual licensing proceedings.

These issues are most*appropriately addressed in a generic proceeding of the character here envisaged.

Furthermore, the court in the State of Minnesota case by remanding this matter to the Commission but not vacating or revoking the facility licenses

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involved,.has supported the Commission's con-clusion that licensing practices need not be altered during this proceeding.

However, all licensing proceedings now underway will be subject to whatever final determinations are reached in this proceeding."

44 FR 61372, 61373 (Oct. 25, 1979).

Judging from the language of this notice, we believe it would be contrary to the Commission's poticy for us to entertain Contention 7.

The notice states clearly that long-term storage is to be addressed by the Commission generically, and not by Licensing Boards in individual proceedings.

Since this and all other individual proceedings now. underway will be subject to the outcome of the rulemaking, the Commission will undoubtedly provide an appropriate means for addressing long-term storage further if the Commission finds, as a result of the rulemaking, that on-site storage of spent fuel will exceed the duration of operating licenses.

We find that Contention 7 was properly dismissed by our earlier Order, and, for the reasons stated above, we can find no basis for reinstating it now.

  • The Colemans' Motion Regarding Contentions-r*2 and 6 Contentions 2 and 6 assert that the Licensee has given in-adequate consideration to accidental criticality caused by deterioration of the modified spent *fuel racks proposed to be installed in the spent fuel pool, and to the qualification and testing of the Boral material which the racks contain.

We conducted evidentiary hearings on these Contentions in May of

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1979.

Since the record has not been closed on these Contentions, we will treat this motion as one to supplement the record, rath~r than to "reopen con~idera.tion" as the Colemans have requested.

The Colemans would have us supplement the record by adding a report dated April 10, 1979, made by the Commission's Office of Inspection and Enforcement. *The report (No. 50-263/79-02) is based upon an inspection conducted from March 19 to March 23, 1979 at the Monticello Nuclear Generating Plant, operated by the Northern States Power Company at Monticello, Minnesota.

The report found that after new spent fuel storage racks had been installed in the spent fuel pool at Monticello, 11 of the 676 fuel storage cells would not accept a go/no-go gauge used to check the dimension of the cells, and that of these 11, two would not accept a dummy fuel element.

The change in the dimensions of the c~lls appears to have been caused by swelling of the cell walls due to the buildup of gas released within the walls by a chemical reaction between water and the Boral material.

After the cells had been removed from the pool, vented (by drilling holes in the top of the cell walls), resized, and re-installed in the pool, 6 of the original 11 cells would still not accept the go/no-go gauge.

All of the cells accepted the dummy fuel element, however.

The Colemans' motion to include this report is opposed by the Staff and the Licensee on the ground that the report is not relevant to the Licensee's pro-posal to install new racks at Salem 1.

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At the ev~dentiary hearing in May, we received extensive testimony on the likelihood of swelling, the effects of swelling, and the possibility of venting the cells at ~alem 1.

In light of this, we do not believe that the inspection report can be dismissed as simply irrelevant to Contentions 2 and 6.

We have also received testimony concerning differences in design between the racks at Monticello and Salem 1, and testimony concerning the Salem Licensee's plan not to use swollen cells, but this testimony affects the weight to be given to the inspection

. report rather than its relevance.

We grant the Colemans' motion to supplement the record on Contentions 2 and 6 by including the inspection report.

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The Colemans' Motion to Reinstate Contention 13 The Colemans' Contention 13 asserts that the Licensee has failed to consider adequately the cumulative impact caused by expanding spent fuel storage at Salem Unit 1 while also ex-panding spent fuel storage at Salem Unit 2, particularly with regard to releases of radioactivity.

We dismissed this Con-tention on April 30, 1979 in response to a motion for summary disposition filed by the Licensee.

Our dismissal was based upon the failure of the Colemans to assert, at that time, a genuine issue of material fact.

In support of their motion to reinstate this Contention, the Colemans now argue that the Board should receive additional

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testimony for the purpose of comparing the occupational exposure which would result from the proposed reracking of Salem 1 to the occupational exposure which would result from the alternative of transshipment of spent fuel from Salem 1 to an expanded pool at Salem 2.

The Colemans also argue that we should hear ad-ditional testimony on the question whether a reduction in the capacity factor of Salem 1 would make increased storage at Salem 1 unnecessary.

These arguments are based upon a statement at the hearing by a witness for the Staff to the effect that the witness was unsure whe.ther the occupational exposure required to expand the pool at Salem 1 would be greater than the exposure caused by transshipment to Salem 2, and that the witness' estimate was that the exposure from transshipment would be smaller (Tr. 1140-42).

An additional basis for these arguments is a letter from the Licensee which states that the number of fuel assemblies which are estimated to be removed annually from the Salem 1 reactor is 56 instead of 64.

We agree with the Staff's. position that these arguments and this testimony are irrelevant to Contention 13, which, after all,*

refers solely to the impact of the radioactive dose to the public from concurrent expansion of the pools at Salem 1 and Salem 2.

The arguments and testimony concerning alternatives have no apparent connection with the level of emissions from the ex-panded pools, cumulatively or individually.

The Colemans have

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never asserted, and apparently still cannrit assert that the emissions for either or both pools will or could exceed per-missible levels.

The Colemans had a fair opportunity to assert a genuine issue of fact *regarding these emissions at the time of the Licensee's motion for summary disposition, and failed to do so.

The consequences of this failure cannot be avoided now by alleging that there may be new evidence which relates to matters not within the scope of the Contention.

The question of alternatives to the proposed expansion of Salem 1 was presented originally by the Colemans in their Contention 9, which expressly covers the alternative of storing spent fuel from Salem 1 in the storage pools of other reactors.

We now turn to the Colemans' motion to reinstate that Contention.

The Colemans' Motion to Reinstate Contention 9 Contention 9 asserts, among other things, that the Licensee has.not considered adequately the alternative of shipping the spent fuel from Salem 1 to an independent storage site away from the reactor, or the alternative of storing spent fuel in the pools of other reactors after the pool at Salem 1 becomes full.

We dismissed this Contention on April 30, 1979 in response to the Licensee's motion for summary disposition, finding at that time that the Colemans had asserted no genuine issue of material fact.

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In support of their motion for reinstatement, the Colemans' first point out that the Staff, in concluding that the pool at Salem 1 would be filled before an independent facility becomes available, assumed that the reactor at Salem 1 would operate continuously during 1979 except for the normal refueling outage.

In fact, the reactor was shut down for a substantial period in 1979 following its refueling outage in March.

Second, the Colemans note that in a letter dated July 5, 1979, the Licensee has stated that instead of discharging 65 spent fuel assemblies annually, as originally planned, the Licensee now intends to discharge 40 assemblies during the first outage, 52 during the second, and 56 in subsequent annual cycles.

The Colemans ask us to consider these two developments, together with the delay in the startup of the reactor at Salem 2, as new information, adequate to reinstate the portion of Contention 9 which refers to shipping

~he spent fuel from Salem 1 to an expanded pool at Salem 2, rather than expanding storage at Salem 1 as proposed by the Licensee.

We are unable to grant the Colemans' request because we

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do not believe that the new information, if taken as true,.is significant, in the sense that it could alter materially the testimony which has already been received on the question of alternatives.

At the evidentiary hearing on July 10, 1979, a witness for the Staff (Mr. Gary Zech) testified that, based

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upon the new ~ate of discharge of spent fuel from the reactor, the date upon which the present spent fuel pool would be filled was estimated at 1983 rather than 1982.

Tr. 1026.

The Staff had stated previously in its environmental impact appraisal that the date would be 1982, assuming the higher annual rate of dis-charge.

The Colemans cross*-examined Mr. Zech extensively upon his conclusion from the new information.

Tr. 1027-1045.

Counsel for the Colemans also asked Mr. Zech about the effect on his conciusion of the extended period in 1979 during which the reactor at Salem 1 was shut down.

Mr. Zech responded that the effect of the shut down period would be to cause the pool at Salem 1 to fill in 1983 on the month on which the Salem 1 reactor was restarted in 1979.

Tr. 1030.

Mr. Zech also responded to questions concerning the effect of possible delay in beginning operations at Salem 2, Tr. 1031-1033, to questions concerning the possible expansion of storage capacity in the spent fuel pool of Salem 2, Tr. 1033-1039, and to questions concerning the possibility of shipping spent fuel from Salem 1 to the spent fuel pool at Salem 2 after an expansion of capacity at Salem 2.

Tr. 1029-1040, 1043-1045.

In his responses Mr. Zech indicated that the testimony given earlier,by the Staff was not materially affected by the new information.

Mr. Zech still concluded that the pool at Salem 1 would require expansion despite the shut down in 1979 and the lower rate of annual dis-charge described in the Licensee's letter.

Of course, these

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responses were subject to being tested in the same cross-examina tion which elicited them.

The Colemans' motion to reinstate Contention 9 comes almQst four months after Mr. Zech's testimony was given.

The motion still does not assert that the new information should now result in any particular alteration of.the Staff's findings or should affect the outcome of this proceeding in any particular way.

The motion says only that the information '~ould likely have produced a far different.result.... "if it had been known when the Staff conducted its initial review of the application.

In our judgment, a generality such as this falls far short of the specificity appropriate to a motion to reinstate a contention for newly-<:Iiscovered evidence.

If the proponent of such a motion cannot state clearly why the new information could significantly affect the testimony which has been received on the outcome of the proceeding, the motion should fail.

See, e.g., Kansas Gas & Electric Company (Wolf Creek Generating Station, Unit 1) ALAB-462, 7 NRC 320, 338 (1978).

In light of the vague statements in the motion and the full opportunity, described above, to probe the new information on cross-examina-tion, there is no ground upon which to alter the consequences of the Colemans' failure to assert a genuine issue of fact when Content1on 9 was dismissed in April of 1979.

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Objections to One of the Questions Posed by the Board on April 18, 1979 On April 18, 1979 the Board posed three questions to the Staff.

They were as follows:

1.

To what extent did the accident at Three Mile Island affect the spent fuel pool at that site?

2.

If there had been an explosion or "meltdown" at Three Mile Island, what effect would that have had upon the spent fuel pool?

To what extent would it have mattered how much spent fuel was present at the pool?

3.
  • If an accident such as the one at Three Mile Island occurred at Salem, to what extent would the accident affect the spent fuel pool?

If an explosion or "meltdown" occurred at Salem, to what extent would that affect the spent fuel pool?

To what e~tent would it have mattered how much spent fuel was present at the pool at Salem?

The Board agreed to withdraw question number 2 as unnecessary after a telephone conference call with the parties on April 19, 1979.

We held evidentiary hearings on question 1 and the first sentence of question 3 on July 11, 1979.* We now take up the Staff's objection to the second and third sentences. o'f question 3.

  • The Staff's objection proceeds from the theory that the type of postulated accident to which these sentences refer, is a "Class 9" accident, and that the Commission's policy is that such accidents are not to be considered in individual licensing proceedings.

A Class 9 accident has been described as follows:

The occurrences in Class 9 involve sequences of postulated successive failures more severe than those postulated for establishing the design basis

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for protective systems and engineered safety features.

Their consequences could be severe.

However, the probability of their occurrence is so small that their environmental risk is extremely low.

Defense in depth (multiple physical barriers), quality assurance for design, manufacture, and operation, continued surveillance and testing, and conservative design are all applied to provide and maintain the required high degree of assurance that potential accidents in this class are, and will remain, sufficiently remote in probability that the environmental risk is extremely low.

For these reasons, it is not.

necessary to discuss su?h events in applicants' Environmental Reports.!

In order to clarify the meaning of proposed Annex A, we asked the Staff whether the accident in March of 1979 at Three Mile Island-2 was a "Class 9" accident.

We asked the Staff whether, in light of the fact that the accident produced a breach of the containment, the accident involved a sequence of successive failures more severe than those which the safety features of the plant were designed to prevent.

On August 8, 1979 the Staff responded that the accident at Three Mile Island-2 2/

was indeed a Class 9 accident.-

The Staff also stated that the 1/

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Proposed Annex A to Appendix D to 10 CFR Part 50 (36. FR 22851, Dec. 1, 1979).

The Staff supplied the Board with a statement by Mr. Jim Martin, of the Staff's Division of Site Safety and Environ-mental Analysis, expressing Mr. Martin's view that the accident at Three Mile Island-2 was not a Class 9 accident.

The Staff also furnished a statement by Mr. Frederic D.

Anderson, of the Division of Siting, Health & Safeguards Standards, to the same effect, Earlier, on June 29, 1979, Mr. Lee V. Gossick, Executive Director for Operations, had stated in a letter to Congressman Robert J, Lagomarsino that "the Three Mile Island accident is not a Class 9 accident."

The Staff took its official position before us notwith-standing these other opinions.

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. amount of radioactive material released was small, and represented a very small number of additional health effects to the opposite population.

Taking all the Staff's statements together, the Staff's position is that 1) the consideration of Class 9 accidents is contrary to Commission policy, 2) the reason for this policy is that the probability of such accidents is remote, and 3) a Class 9 accident nevertheless occurred at Three Mile Island-2 in March of 1979.

The source of the Commission's policy on Class 9 accidents is the proposed Annex, which has never been adopted as a rule.

The Annex did state, however, that the "CoI1ll!lission expects that the provisions of the proposed amendments will be useful as interim guidance until such time as t~e Commission takes further action upon them."

36 FR 22851.

The purpose of the Annex was to meet the Commission's obligations under the National Environ-menta::1 Policy Act of 1969.

Pursuant to the Annex, the Staff does not require applicants to describe the environmental effects of Class 9 accidents in their applications, nor does t_he Staff conduct an environmenta 1 review of such accidents in its evaluation of an application.

The Commission's legal staff has defended the Staff's practice in court, and has prevailed on'the theory that the low probability of these accidents means that NEPA does not require them to be considered.

See, e.q.,

Carolina Environmental Study Group v.

AEC, 510 F.2d 796 (D.C.

Cir. 1975); Hodder v. NRC, Nos. 76-1709 and 1 78-1149 (D.C. Cir.,

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December 26, 1978).

The Commission's most recent discussion of Class 9 accidents occurred in Offshore Power Systems (Floating Nuclear Power Plants) CLI-79-9, 10 NRC (September 14, 1979).

In that case the Commission declined to review the generic question whether Class 9 accidents should be considered for land-based reactors; it did hold, however, that the Staff was correct in deciding to consider Class 9 accidents for floating plants.

The Commission also stated that the generic question of Class 9 accidents for land-based plants would be better dealt with by rulemaking and it directed the Staff to develop recommendations for interim guidance and to bring to the Commission's attention "any individual cases in which it believes the environmental consequences of Class 9 accidents should be considered." Slip op.

at p. 10.

The Offshore Power case was decided after the Staff filed its objections to our question.

The Staff's decision in Offshore Power to evaluate Class 9 accidents resulted from the Staff's conclusion that the overall risk of harm associated with a floating plant, because of the "liquid pathway" of a radioactive release, was higher than for a land-based plant, and that license conditions designed to mitigate the higher risk might therefore be imposed.

The Staff conceded that the probability of an accident at a floating plant was no higher than the probability of an accident at a land-based plant.

Because, however, the consequences would be more

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.... severe the Staff considered the risk to be higher (risk being probability multiplied by consequences).

The Commission per-mitted the consequences to be considered, although the Commission's decision did not specifically address the Staff's argument that the Annex was based upon risk rather than probability.

The Commission limited itself to considering only one of the Staff'~

arguments, which was that the Annex did not apply to floating plants since these plants were not within the Commission's contemplation when the Annex was issued.

A majority of the Atomic Safety and Licensing Appeal Board had agreed with this argument, but in its affirmance of the Appeal Board the Commission said only that it agreed with the Appeal Board's result.

The Commission appears to have reached the result it did because the Staff had already analyzed the relevant data, and the Staff had concluded that there was "an environmental risk that requires speci,fic mitigative actions."

The Commission said the question really was whether the "Licensing Board... [should] blind itself" to this risk, and the Commission's answer was that it should not.

It is difficult to find the precise direction in which the Offshore Opinion points.

Salem 1 sits on an artificial island at the head of an important estuary.

It is surrounded by liquid pathways.

Salem 1 does not float, but according to the analysis in Offshore Power, pathways, rather than floating, are the critical factor.

It is also true that the possibility

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of greatly expanding the storage capacity of spent fuel pools was probably not within the Commission's contemplation when the Annex was issued in 1971.

Should one therefore conclude that the Annex was not intended to apply to such expansions?

Finally, if we now order the Staff to prepare an environmental impact statement which considers the effect of a Class 9 accident at Salem 1, and the Staff in doing so finds that the additional fuel in the pool would significantly 'increase the consequences of an accident, we could not under Offshore Power blind *ourselves to that fin~ing in the hearing.

If we rule that we have no power to order such a study, we leave open the possibility that such consequences may exist but will never become known.

When one remembers that the Annex itself rests upon the assumption that Class 9 accidents are improbable, and one considers that a Class 9 accident recently happened, matters become difficult indeed.

We believe our surest course is to keep in mind our basic responsibility as a Licensing Board.

We must determine whether the proposed increase in storage of spent fuel at Salem 1 can be accomplished without undue risk to the public.

Risk, by its nature, includes consequences.

The Appeal Board, in its review of the Offshore case, found a "cogent" argument in the notion that investigation of a Class 9 accident might be justified if

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the consequences alone exceeded the perimeters of the analysis.

which the Commission had in mind when it proposed the Annex.

Offshore Power Systems (Floating Nuclear Plants) ALAB-489, 8 NRC 194, 219 (1978).

Indeed, the dissenting member would have excluded Class 9 accidents on the basis of probability alone, (8 N.R.C. at 225) but the majority did not.

The Appeal Board's result was sustained by the Commission.

The Commission did not address, and surely did not* discredit, the notion that severe changes in consequences might justify I

exami_:i:;ting Class 9 accidents.

In fact, the Commission directed the Staff to call attention to land-based plants where such an examination might be justified, thus suggesting that the acceptability of such an exam~nation would not hinge entirely upon* the notion that land-based. and floating plants were different.

We are inclined to interpret these precedents as suggesting that where the consequences of an accident are qualitatively different from any analyzed before (or so different quantitatively as to be tantamount to being qualitatively different) we would not be precluded from giving that accident our attention, despite its low probability.

We are encouraged in this direction by the Staff's finding, with which we agree, that a Class 9 accident has now happened., In light of the accident at Three Mile Island-2, we believe that the assumption of low probability upon which the Annex rests must be reconsidered, and pending that reconsidera-tion we are reluctant to view the Annex as covering any matters beyond those clearly contemplated when the Annex was promulgated.

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...... *._ We have before us testimony (as yet not formally admitted) to the effect that the fuel pool expansion, per se, vastly in-creases the consequences of one particular accident occurring through one specific mechanism, viz, loss-of-water (Testimony of Dr. Richard E. Webb, in Respect to Board Question #3).

The proposed increase in storage is alleged to be equivalent to "the construction of 24 large power reactors from a radiological hazards standpoint" (Id. at p. 22).

While this difference may or may not truly exist we have no proffered testimony to the contrary.

We have therefore determined that, as matters now stand, we cannot say that the increase in consequences which increased storage presents does not constitute a qualitative change iil the_ consequences of a low-probability accident.

We cannot say, therefore, whether that accident must be addressed in an environ-mental impact statement.

Under.the Commission's decision in Offshore Power, it is clear that we must consider such qualitatively different consequences if they are found to exist.

Accordingly, we shall require an answer to a somewhat modified form of Question No. 3, a form that focuses upon a specific mechanism and upon the specific nature of the change which will occar with expanded storage.

The question is:

In the event of a gross loss of water from the storage pool, what would be the difference in consequences between those occasioned by the pool with expanded storage and those occasioned by the present pool?

I,:t, I

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We will accept in answer whatever measure of consequences each.party sees fit to present; however, we encourage all to use some common measure, perhaps the potential dose to an in-dividual who remains at the exclusion area boundary for a given period.

We expect, of course, that each party will postulate and make appropriate calculations for some specific sequence of events, including heating, possible melting, and possible dis-persion mechanisms.

Only after we have such a measure of the quantitative difference which th~ fuel pool expansion entails will we decide whether this accident should be addressed as a potential environ-mental impact.

Evidentiary hearings for the purpose of considering evidence on the above question shall be held in Salem, New Jersey at the time and place announced :i,.n the notice which accompanies this Memorandum and Order.

The testimony already filed in response to the Board's question 3 shall be considered as pertaining to the above reformulation of question 3.

SO ORDERED Dated at Bethesda, Maryland this 22nd day of February, 1980.

FOR THE ATOMIC SAFETY AND LICENSING BOARD

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION, ATOllfIC SAFETY AND. LICENSING BOARD

. Gary L. Milhollin, Esq., Chairman Dr*. James C. Lamb, III Frederick J. Shon In the* Matter of

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PUBLIC SERVICE ELECTRIC &

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G-AS COMPANY

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    • ~;'~'(Salem Nuclear Genera ting
  • Station, Unit No. 1).

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Docket No. 50-272 (Pr*oposed Issuance of Amendment

. to_ Facility Operating License No. DPR-70)

NOTICE OF EVIDENTIARY HEARING*

(February 22, 1980)

An evidentiary hearing by the Atomic Safety and Licensing Board will be held in the above-captioned proceeding on April 22, 1980* at 9*:30 A.M. in Courtroom 3, Salem Courity Courthouse, 92 Market Street, Salem, New Jersey.

The parties shall address the following question:

In the event of a gross' loss of water from the spent fuel storage pool _at Salem 1, what would be the difference in consequences between those oricaiioned by the pool with the expanded storage proposed by the Licensee and those occasioned by the present pool?

Testimony, in addition to that previously filed on an

  • earlier. formulation of this question, shall be filed by March 2,4, 1980, and objec~ions to all testimony*shall be filed in writing by Ap~i1 4, *1980.

SO ORDERED FOR THE ATOMIC SAFETY AND

. LICENSING BOARD

. £.*"'~~

~ilhol_lin, Chairman Dat~d-at Bethesd~,- ~aryland

  • this 22nd day of February, 1980.

In the ~atter of e:*

UNITED STATES, OF AMERICA NUCLEAR REGULATORY CO:t-fMISS ION

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.e PUBLIC SERVICE ELECTRIC AND GAS

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Docket No. (s) 50-272.

(Salem Nuclear Generating Unit 1)

Station,)

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CERTIFICATE OF SERVICE I here~y certify that I have this day served the foregoing document(s)~

upon each person designated on the official service list co~piled by the of =ice of the Secretary of the Commission in this proceeding in acco~cance with the requirements of Section 2.712 of 10 CFR Part 2 -

Rules of Practice, of the Nuclear Regulatory Commission's Rules and Regula t:ions.

Dated at ~ashington, D.C. this A6CZ.

day of ____,,.dJ;J"--"=-* ___ 19~ll_.

Off ic 4r;__pcf£;,~

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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PUBLIC SERVICE ELECTRIC AND GAS

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Docket No.(s) 50-272 C011PA11Y

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(Salem Nuclear Generating Station~

Unit 1)

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SERVICE LIST Gary L. Milhollin, Esq.

1815 Jefferson Street Madison, Wisconsin 53711 Mr, Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555

  • Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Alan S. Rosenthal, Esq., Chainnan Atomic Safety and Licensing Appeal Board.

U.S. Nuclear Regulatory Commission Washington, D.C.. 20555 Dr. Lawrence R. Quarles Kendal-at-Longwood, Apt. 51 Kennett Square, Pennsylvania 19348 Michael C. Farrar,' Esq.

Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission l~ashington, D. C.

20555 Cuunsel for NRC Staff

  • u. s*.. Nuclear Regulatory Commission Washington, D.C~

20555 Troy B. Conner, Jr., Esq.

  • ' *conner, Mo'ore and Corber 1747* Pennsylvania Avenue, N.W.

Washington, D.c.,* 20006 Public Service Electric & Gas Company ATTN:

Mr. F.P. Librizzi, Gen. Mg~.

Electric Production Production Department 80 Park Place Newark, New Jersey 07101 Rebecca Fields, Esq.

Deputy Attorney General 36 West State Street Trenton, New Jersey 08625 William C. Horner, Esq.

67 Market Street Salem, New Jersey 08079 Keith A. Onsdorff, Esa.

Assistant Deputy Public Advocate Department *of the Public Advocate 520 East State Street Trenton, New Jersey 08601 Mr. Alfred C. Coleman, Jr.

Ms. Eleanor G. Coleman 35 K Drive Pennsville, New Jersey 08070 Ms. Ruth Fisher "The Sun People 11 Alternate Energy Advocates South Dennis, New Jersey 08245 Richard Fryling 1 Jr., Esq.

Frederic~ M. Broadfoot, Esq.

'Public* Service Electric & Gas Company 80 Park Place Newark, New Jersey 07101 t*-**---**

[~.:_-:-:-~~:-~

Board and parties continued;-

June D. MacArtor, Esq.

Deputy Attorney General Tatnall Building P.O. Box 1401 Dover, Delaware 19901 Carl Valore, Jr., Esq.

Valore, McAllister, Aron and Westmoreland, P.A.

535 Tilton Road Northfield, New Jersey 08225 50-272

Information copies sent to:

Ms. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant Postponement 810 West 25th Street Wilmington, Delaware 19802 Mr. Marvin I. Lewis 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 Ms. Evelun Boon Route 2 Salem, New Jersey 08079 Mr. Francis Ponti Yorktown-Friesburg Road RD f/3 Elmer. New Jersey 08318 Mr. Brian Graff 401 Shireen Terrace

  • Malaga, New Jersey~.* 08328

.Mr. *John Prince, General Manager Jersey Information Center, Inc.

P.O. Box 132 Salem, New Jersey 08079 Mr. Theodore A. Peck Chairman, Energy.Task Force Unitarian Church of Princeton 11 Glenview Drive Princeton, New Jersey 08540 Hs. Gladys Brandon 15 Grancis Drive Pennsville, New Jersey* 08070 Ms. Dorothy Eldridge, Director SMTE 324 Bloo~field Avenue

.* Mop.tclair, New Jersey 07042

.e 50-272 Hr; Lawrence K. Elrod R.D. #2 Black Road Woodstown, New Jersey 08098 Ms. Margaret A. Wasson, Coordinator Utility-Users for Reasonable Rates 110 Memorial Lane Mount Laurel, New Jersey 08054 Mr. Daniel A. Rita, Jr.

30 Tinker Drive Mount Holly, New Jersey 08060 Mr. Sidney J. Goodman 170 Villanova Drive Paramus, New Jersey 0~652 Ms. H. Joan Pennington 94 Railroad Avenue Penns Grove, New Jersey 08069 Mr. Thomas A. Pankok, Director Board of Chosen Freeholders Courthouse Salem, New Jersey 08079 Mr. Martin A. Herman District 3, Assemblyman 59 North Broad Street Woodbury, New Jersey 08096 James W. Shue, Esq.

P.O. Box 2317 Princeton, New Jersey 08540-Ms. Isabelle G. Sayer Citizens for Responsible Power Policies 167 Edgerstoure Road Princeton, New Jersey 08540

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