ML18082A373

Transcript of 800428 Hearing in Salem,Nj.Pp 1,352-1,434

ML18082A373
Person / Time
Site:	Salem
Issue date:	04/28/1980
From:	Atomic Safety and Licensing Board Panel
To:
References
NUDOCS 8005130438
Download: ML18082A373 (99)

Text

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UNITED ST.AT ES NUCLEAR REGULATORY COMM!SSiON In the matter of:

PUBLIC SERVICE ELECTRIC & GAS COMPANY SALEM 1 DOCKET NO. 50-272 p I a c e :

Salem, New Jersey Date: Monday, April 28, 1980 pa 9 es: 1,352 to 1,434 INTERNATJONAl.. V~SAilM Ra-oA~. INC.

499 SCUTH C:APrrCL sr.RE£7'. s. w. sum: 101 WASHINGTON. C. C. 2CJ02

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I APPEARANCES PUBLIC SERVICE ELECTRIC & GAS COMP~NY Mr. Mark J. Wetterhahn, Esq.

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NEW JERSEY PUBLIC ADVOCATE -

INTERVENOR -

COLEMANS Mr. Menasha J. Tausner, Esq.

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STATE OF NEW JERSEY Ms. Rebecca Fields, Deputy Attorney General

. STATE OF DELAWARE -

DIVISION OF ENVIROMENTAL CONTROL Harry W. Otto, Ph. D.

STATE OF DELAWARE Ms. June D. MacArtor, Esq., Deputy Attorney General TOWNSHIP OF LOWER ALLOWAY CREEK Mr. Carl Valore, Esq.

I NUCLEAR REGULATORY ST~FF Ms. Janice E. Moore, Esq.

Mr. William D. Paton, Co-Counsel Mr. Gary Zech IWW"DlflAtiCllM. '/'UltM'ftllt" AIP:;>ci UE1. IMC.

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TABLE OF CONTENTS WITNESSES DIRECT CROSS Dr. Al Benjamin 1,385 Mr. Walter F. Pasedag (Questions By Board) 1,393 EXHIBITS INTO EVIDENCE*,

Mr. Pasedag's Testimony &

Professional Qualifications Dr. Allen Benjamin's Profess-ional Qualifications 1,387 1,389 1-~

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RE-DIRECT

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FOR IDENTIFICAT]ON i I l i

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P R 0 C E E D I N G S CHAIRMAN:

Good morning ladies and gentlemen.

The Public Service Electric and Gas Co. has applied for permission I

I I I I I I to expand the storage capacity of the spent fuel pool at Unit 1 I of the Salem Nuclear Generating Station.

We are* an Atomic Safety and Licensing Board convened by the Nuclear Regulatory Commission for the purpose of considering that application.

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I On my right is Dr. James Lamb who is a professor of Environmenta!l Engineering at the University of North Carolina.

On my left is

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I Mr. Fred Shon, a Nuclear Physicist and Engineer who is a full time member of the Atomic Safety and Licensing Board panel.

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I am.Gary Milhollin, an Attorney and am also a faculty member I of the University o*f Wisconsin Law School.

We have scheduled a j hearing today in order to receive testimony on.

. I a quest ion wh*ich I I

l tJ we posed on February 22, 1980 to the parties in this case.

to 17 1a 19 11 I

The question is as follows:

In the event of a gross loss of i

l water from the spent fuel storage pool, what would be the I

difference in consequences between those occasioned by the pool!

I I with expanded storage and those occasioned by the present pool?i I

So our business today is to entertain testimony which addresses I that question.

I will now ask counsel for the parties to the I case to identify themselves.

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i MR. WETTERHAHN:

Good morning Mr. Chairman and

. i memb.ers of the Board.

My name is Mark Wetterhahn from the firm!

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.of Connor & Moore.

Seated to my left is Richard Fryling, Jr.

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I with Public Service Electric & Gas Co.

MR. TAUSNER:

Good morning, my name is Menasha J.

i ! Tausner.

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.I am a Deputy Public Advocate with the New Jersey i

Department of the Public Advocates.

I am here representing intervenors Colemans.

MS. FIELDS:

Mr. Chairman and members of the Board, I am Rebecca Fields, Deputy Attorney General of the State of I

'I New Jersey as an intereste*a state.

MS. MAC ARTOR:

June D. MacArtor, representing the State of Delaware, Deputy Attorney General for Delaware.

MR. CARL J. VALORE, representing the intervenor I

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1'2 Township of Lower Alloways Creek.

Sitting with me is Dr. Richa~d I

Webb.who is an exJ?ert witness for my consultants*.

1 J, MS. MOORE:

Mr.. Chairman, my name is Janice Moore, t..S -

Counsel for NRC staff and to my right is William Paton, co.:.

to counsel.

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• 1 CHAIRMAN:

Thank you.

Does any party* or interested state have a matter to take up before we begin discussing procedure for the hearing.and our ruling on objections?

MR. WETTERHAHN:

There is one matter, Mr. Chairman.

There is a pending motion to impose sanctions against the licensee and to bar the ~icensee and his attorney from this l hearing.

I would ask that this motion be denied out of hand and stricken as totally unsupported and frivolous.

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1 come to ii CHAIRMAN:

Well, that motion in our

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Mr. Wetterhahn, we do intend to normal procedure this morning.

there any other matters which we should take up now before 1,354 I '

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announcing procedures?

Yes?

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MR. VALORE:. I was delivered on Thursday, a Part III I

. i Supplement to Dr. Webb's testimony and also an addendum which I

I j I was delivered on Sunday.

Because of complications I have not I I

I I had an opportllnity to make copies of these or to serve them on 1

the parties.

I was also served with further testimony this morning from the NRC and I could bring that to the Court's

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attention depending on how events unfold this morning.

I want I the Court to be aware that there will be some supplementation i'

i (attempt to supplement) Dr. Webb's testimony.

CHAIRMAN:

Very well 1 thank you.

MS. MOORE:

Mr.* Chair:f!lan, in regards to the staff's additional testimony it has been served on the parties this morning and I do intend to offer it, but I will do that at the I

tl.me that our witnesses take the stand.

CHAIRMAN:

Very well~

Any other preliminary matters?

MS. MAC ARTOR:

Mr. Chairman, in that regard if additional testimony is to be offered, we would request 20

)minutes as the appropriate time to take at least a quick* look*

at it.

CHAIRMAN:

Very well.

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MR. WETTERHAHN:

Mr. Chairman, I'm not consenting*

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I that 20 minutes is adequate on the part of the licensee for I

what we've seen of Dr. Webb's previous testimony is complicated with many calculations.

I think we will get to argument on I

whether it should be admitted and I just don't want my silence I I

to be taken as.consent that we are.agreeing to admit this with 1

I 20 minutes notice.

i CHAIRMAN:

The Board plans to take an adjournment I

this morning.

It might be possible for Mr. Valore to distribut1 I I that material when we begin our adjournment.

I MR. VALORE:

I think I can make arrangements to do f

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that.

MS. FIELDS:

Mr. Chairman, the State of New Jersey*

has not yet been served with the staff's testimony just I

I I referred to, and Iwould ask the Chair's indulgence to CHAIRMAN:

Before we go further I th.ink I should say I i

a:e:o::::d a:::t t::r p::::i::i::n::d::::g c:::. ap::::a:::d to I expand.the storage capacity of the Spent Fuel Pool.

Our juris~

I diction is limited to that question.

We have no jurisdiction I I

from the Nuclear Regulatory.corui:ission to.consider things whic~

go beyond that question.

So it is important during the I

hearings we are now going to have to keep have received proposed testimony from the i

that in mind.

We I

staff of the Nuclear I I

Regulatory Commission, from _the licensee, and from the Township l 1"1"111MA1"tCIU&.o.,,,...,... ~:ow:>>et-utL r...c..

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i.m I of Lower Alloways Creek.

We have also received objections to. I I

I the testimony of each of those parties, and this morning we have received some additional materials.

Thus* far we have received from the NRC Staff a copy of some further testimony ofl I I Mr. Walter. Pasadag in response to our questions.

We have I

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received also this morning from the NRC Staff a copy of the action taken by Mr. Harold Denton, who is the Director of the I

Office of Nuclear Reactor Regulation of the Commission con-I cerning a petition by Mr. & Mrs. Alfred Coleman.,The Director*b action is dated April 16, 1980.

We have also received a I

notice of appearance by Mr. Tausner.

I MR. WETTERHAHN:

Mr. Chairman, just for clarification!,

perhaps you could request the staff to make a statement as to the purpose of submitting this action by Harold Denton to the I

i I I I parties at this point. *r think the other matters, the Addendumf to the testimony of Mr. Pasadag is fairly obvious, but I would like to know the use of this second piece of paper that you received this morning.

CHAIRMAN:

Would the Staff care to respond to that invitation?

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I I MS. MOORE:

Yes, Mr. Chairman, the reason that that. I document was served on the Board and parties this morning is that it is truly for Board notificatio~ purposes.

We thought there might be a portion of that document, specifically the portion that begins on Page 28, that could be relevant to this

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MR. WETTERHAHN:

Then for clarification purposes, I I i

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• Mr. Chairman, it is only the material beginning on page 28 that I is relevant to this proceeding at this time -- up through page I I

39 is that correct?

I MS. MOO,RE:

As far as the Staff knows at this time I

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that is correct Mr. Chairman.

MR. WETTERHAHN:

Thank you.

I CHAIRMAN:

We have come to a decision on *some of the j I

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objections which have been made to testimony which is proposed.,

I Our ruling is as follows:

First, we deny the objection by the i I I Staff and the licensee to the testimony proffered by Dr. Webb. I Insofar as the objection is grounded upon the theory that we I

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are entering the domain of Class 9 Accidents.

Perhaps I should!

I repeat that ruling.

We deny the objection.by the Staff and J I I

I Licensee to the testimony prof~ered by Dr. Webb insofar as the I objection is grounded upon the theory that we are entering the I I

domain of Class 9 Accidents. The Staff and Licensee objected to! I the testimony by Dr. Webb on other grounds as well, and this I I

21 ruling I am announcing at this time does not apply or address those other objections.

With regard to the question of Class 9i I I Accidents we be:i.ieve that only after receiving evidence on the 1 I I difference in consequences of the loss of water in the pool 1

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will we be able to determine whether any further inquiry may

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1 I I conflict with the Commission's policy.

We also deriy the I

Licensee's objection to the Staff's testimony on this same

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ground.

Our second ruling is to deny the motion by Lower I

I Alloways Creek Township to have the Board impose sanctions I

against the Licensee.

At this time we will entertain responses/

ii which any party or interested State (I suppose in this case it I would only apply to parties) will entertain responses which any!

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party cares to make to the objections which have been filed, other than th~ objections upon which we have just ruled.

MR. WETTERHAHN:

With regard to the rulings wh~ch you/

have just made, particularly that permitting consideration of I Dr. Webb's testimony and the Staff's testimony, the extent it I considers. the Licensee 1 s views Class Nine Accidents,* Iwould ask!

I the Board to certify the question, whether it may proceed at that time considering the statement of the Appeal Board in A-Lab 588 in the clear direction of the Commission against Class Nine Accidents.

I would ~sk the Board to so certify.

CHAIRMAN:

Very well, we have your request, Mr.

Wetterhahn.

MR. WETTERHAHN:

Do you intend to make a ruling on

• it now.

I have an* alternative motion.

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CHAIRMAN:

No we don't intend to rule on your requestj that we certify.

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MR. WETTERHAHN:

I would ask that the Board consider ! I vacating its ruling in referring the question if it feels that

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I is an alternative.

As a third matter, I would ask that it limit the testimony of the parties, particularly that of Dr. Webb ~nd!

I part of the testimony of the Staff to consider whether they arel I

looking at the Class Nine Accident and its consequences and one~

5 it has made a decision o-h that it should again look at the 7

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ti i9 ll question of whether the consequences can be examined or whether.

I it has to refer this matter directly to the Appeal Board or to I I

I the Comrriission.

CHAIRMAN:

Mr. Wetterhahn, perhaps you should restatel l

that last motion.

I MR. WETTERHAHN:

I would ask that the Board limit.the!

I testimony and the examination by the parties and.itself to the j extent necessary.to determine the initiating sequences of events postulated by the parties are Class Nine Accidents.

. it makes the determination after this limited.testimony that they are Class Nine Accidents, I think it is clear that the Board must refer this matter to the Commission or the Appeal Board and it cannot go any further.

CHAIRMAN:

So your motion is that we limit our inquiry to the question of whether the initiating events are Class ~ine.events?

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i MR. WETTERHAHN:

That's.correct.

And without regard i I

i to their consequences.

It is our theory as stated in our varidus pleadings.that once a determination is made that an event is Class Nine Accident as that event has been defined by the f~nc......

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Appeal Board, by the Commission and various licensing boards,

z a licensing board may go no farther.

It must stop there and at most refer the matter to the Commission.

MR. TAUSNER:

I would like to comment on the motion that the Licensee made, if it is appropriate at this time.

CHAIRMAN:

Okay.

Can you wait just a minute?

7 MR. TAUSNER:

Sure.

CHAIRMAN:

Mr. Tausner, were you intending to speak I

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in favor of the motion?

10 i r 12 I.L 11 ts 19 21 MR. TAUSNER:

No.

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CHAIRMAN:

Well in that event, perhaps your comments I We have decided to deny the third of your I motions Mr. Wetterhahn.

1 won't be necessary.

MR. WETTERHAHN:

I would again ask that that motion be certified with the other two or the other one.

CHAIRMAN:

We are ready now for responses to objections.

MS. MOORE:

Mr. Chairman.

CHAIRMAN:

Yes.

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MS. MOORE:

In light of your ruling on the first I

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i i* ground of the Staff and Licensee's objections, the Staff would I ask for a 10-minute recess to reformulate its responses.

CHAIRMAN:

Very well.

We will now take a recess until five minutes after ten.

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CHAIRMAN:

The hearing will come to order.

MS. MOORE:

Before we go any further the staff wou~d like to raise two preliminary matters.

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At is point, irst I the staff would like to ask the court for some clarificationi I of its prior ruling that staff and licensees objections are ! I I i denied insofar as they are premised on the theory that the Board is entering into the domain of a Class 9 accident.

The questions that the staff has is, has the Board ruled that this gross loss of water accident is not a Class 9 accident or has the Board simply not yet ruled on whether it is a Class 9 accident or has the Board simply not yet ruled on whether it is a Class 9 accident or has the Board.

simply not yet ruled on whether it is a Class 9 accident or not?

CHAIRMAN:

The Board has taken no position in re-sepct to the question whether gross loss of water is a Class 9 accident or not.

MS. MOORE:

Mr. Chairman, in that case the staff would like to move for reconsideration of the third part of licensees motion to reach that decision in this pro-ceeding before we continue with the other portion of the i

proceeding, namely the difference in consequences.

It could.

make a difference in terms of what consequences we are speaking of.

Whether we are speaking of the difference in consequences or the consequences IHnJ'tHATIOf<A\\. v~nM RIO'OOT'!:l't:!. !i.e.

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we are speaking of.

Whether we are speaking of the difference in consequences of the particular accident.

MR. VALORE:

Mr. Chairman.*

CHAIRMAN:

Excuse me could I ask you to clarify that last statement.

MS. MOORE:.Yes, Mr. Chairman.

The Staffs position is that this accident is a Class 9 accident and therefore its i

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I consequences may not be considered in this proceeding.

However !

under the Appeal Board ruling the difference in* consequences, 'I I

namely, whether or* not there is a difference in consequences of j i' such an accident, that question may be considered.

MR. MOORE:

Yes, we are only concerned with the difference in con~equences.

MS. MOORE:

I think the staffs problem in that in as much as some of the testimony which will be proffered mentions particular consequences.

We feel that in our position this is a Class

• 9 -. accident, those specific consequences may not be CHAIRMAN:

So your position is that the specific consequences of accidents, which you consider to be Class 9 may not be considered but that the difference in consequences may be.

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! i MS. MOORE:

Whether there is a difference in consequences l

may be, Yes. Sir.

CHAIRMAN:

Yes.

The question whether there is a

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difference in consequences may be considered, that is in effect what the Appeal-Board said.

MS. MOORE:

That is correct, Mr. Chairman.

7 CHAIRMAN:

Excuse me a second.

CHAIRMAN:

Yes, to respond to your question we are 9

concerned with whether there is a difference in consequences.

• TO And if so, what that difference is.

t T MS. MOORE:

Mr. Chairman, if this accident that we are I

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!2 considering is determined to be a Class 9 accident by I

the Board,j l.S 17 1a i9 20 21 the question of what that difference is in terms of numerical consequences of this accident we would say is impermissible question for this Board to address. *And therefore that is I

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why the staff is asking for reconsideration of licensees third I i

part of the motion since that seems to be* a necessary part whether or not this is a Class 9 accident, it seems to be a necessary part for further ruling on objectioni to certain portions of Drs. Webb and Fanhauser's testimony~

CHAIRMAN:

Well, by denying the licensees motion I think I

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you can assume we have taken the position that we disagree

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with that proposition.

MS. MOORE:

Thank you, Mr. Chairamn. The *second matter I I I

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is the order in which this proceeding will continue in terms of [

who will respond first and who will present testimony first.

We would propose that we adopt the order that was. followed in the hearings that took place in May, that in that the licens.ee presents his witnesses first, the interveners, and the staff goes last.

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CHAIRMAN:

It was our intention to invite the parties to I discuss this matter during an adjournment which we anticipate. i I having this morning.

We also planned, I gues we can do it now, to suggest to you that since Dr. Webb's testimony seems to be directed to materials generated by the staff it might be more orderly for the staff to go first.

We simply suggest that to you for your own consideration.

MS. MOORE:

Thank you, Mr. Chairman.

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MR. CHAIRMAN:

Otherwise, If Dr. Webb goes first (I guess I I should say this), if Dr. Webb precedes the staff, then we probably would be forced to recall Dr. Webb.

MS. MOORE:

Is this ori the assumption, Mr. Chairman, licensee would go first of all, or that the staff would go of all.

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CHAIRMAN:

I was going to suggest to you that it might be I more orderly as I said for the staff to go first, perhaps the licensee could follow, and then Dr. Webb. But if there is some reason which the Board does not appreciate which the parties I I i

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i can agree upon for changing this sequence then we invite you to 1*

confer among yourselves and ~o inform us.

MS. MOORE:

Thank you, Mr. Chairman.

CHAIRMAN:

I guess we should let you know that our intention also is to ask our question of the witnesses first, and then allow the parties to cross-examine after that.

This I

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has the advantage of allowing the parties to explore matters wh~ch we.might raise in our questions.

MS. MAC ARTQR:

Mr. Chairman, if the staff were to go I I i

I first, would the proffered testimony be considered to be alread~

t.S in the record so that the staff might be asked questions about ta testimony offered from the other parties? It had been the ti 18 19 20 11 intention* of the State of Delaware to ask the staff to comment I i.

i on certain po.rtions of other testimony, both licensee and I

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Lower Alloway's and it would be necessary in order for that to be done that the proffered* testimony be in the record.

MR.* WETTERHAHN:

Mr. Chairman, as a procedural point, I I I I.

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don't think that is necessary - all parties have a copy and at /

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point I'm sure all of the testimony will be offered at I I I I I I

i i least for identification.

i So I don't think there is a problemi I

!on ~dentification.

I don't see where it has to go in and be I

I

' I sworn to before it's used as far as cross-examination.

CHAIRMAN:

It seems to me that you can cross-examine ion any document you wish.

i j

i I

I I

MS.. MAC ARTOR:

All right, that would be fine.

CHAIRMAN:

Without taking a position on whether it is I

1 admissible on evidence, we have followed such a procedure,:

i I

! before with respect to the famous Crocket Letter.

I believe I

! in this preceding.

It was used extensively in cross-examination but was never, I think, introduced or accepted into evidence.

Are there any other matters which we should consider now?

Are you ready to make responses to objections.

Does any part have a response to objections which have been made to testimony?

Shall we allow the licensee to go first with the licensees responses and then after that we can move to the intervener and then to the staff.

MR. WETTERHAHN:

That's fine.

The only objections in the record as far as the licensees tes.timony is that of Lower Alloway's Creek Township, so I intend to respond *to that one only.

Any other objections will be made in writing.

,.. ~

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!The licensee believes that Lower Alloway's Creek Township i

I I I

I

!has stated no grounds for the exclusion of licensees testimonyj ion Question 5.

i Question 5 is that which was identified by

!the Board at the beginning of the hearing and the part~es i

I !have been referring to that one as Question 5 for purposes I

i :of clarification.

i The most that can be said, and this is I giving every benefit of the doubt to Lower Alloway's Creek's I

I I

I i I

a 9

10 11 12 1:3 14 1.S 16 17 18 19 20 21 22 2:3 14 25

. l I (position is that it raises matters appropriate for cross-i ! !

I*

I I

i examination or possibly arguing their proposed findings.

But I there is nothing stated which would exclude licensees I

I t~s~imony~ Licensee submits that its testimony is completely I I

responsible to Board's Question 5.

We believe that counsel for LACT, if I may use that acronym, has emphasized the wrong part of the Board's question. In its objections, it notes the first part of the Board's ques-tion in the event of a loss of-water accident.

We believe that emphasis should be placed on 'the words "gross loss of water" and try to define that term, while Lower Alloway's Creek Township has chosen its own method of interpre_ting that, we will get to that later, and that method is a non-mechanistic definition of "gross loss of water".

An in~tantaneous total, or almost total loss of water as caused by what is in the licensees l"'"""""°""I. V~nM RiJ"OHrCle. l..c:.

SCUT)4 <:.&~.sntter.'. S. -11. SUITT 107 I

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iew as Class 9 or series of Class 9 accidents.

But this, i I y far, is not the only possible interpretation for the ords "gross loss of water" and the fact that Lower Alloway's I

I f I

/creek i

I has stated that substantial.sum~ of monies and man-hours/

I

. ! preparing this case, surely enough does not prove that its

' I

!expenditure of money by any party will not sway the Board's I.

id h'

! ec1s1on in t is matter.

I I

We belive the Licensees testimony

!is directly responsive to the Board's question as that

!question was construed and allowed by the Appeal Board in i

j its decis:ions ~roceed A Lab 588.

We believe our answer is i responsive while avoiding any clash with the Commission's i

1 prohibition on consideration of Class Nine accidents and I since this is already discussed our objection would just I

I 'incorporate our view on the Commission's decisions and point I

i : of view by reference here without going irito it in much i

i detail.

I.would only summarize our position that the "*

i I

I i

I !

I I I

I I

I I I i I I

I. i I i I I I

. I Commission has clearly set forth that its existing policy against consideration of either the initiating or any i I I I

I 18 19 20 I I I

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ii

. I

. i i

i consequences of A Clas.s Nine accident whether they would be I absolute consequences relative, comparative, or *any type of.

consequences are surely and. completely prohibitive*.

I would just like to hear discussed the Licensees approach in its I

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testimony to show that it is responsive to the Board's I

I i questions.

Really, after reviewing the design of the spent fuel pool of the Salem facility in the te_stimony as that 1

• design was approved by the Commission at both the construction/

I permit and operating stage, the Licensee found that a I

"gross loss of water" was precluded by that design and by adherence with that design basis.

However, in order to be

! I

!responsive to the Board, the Licensee looked at several I

events including a compl~te loss of integrity of a weld seem i

i Ion the I

spent fuel pool and the extent.of a possible leak i

\\due to such a failure to see if a gross loss of water could i

I

!occur and what would be its consequence.

The results are I analyzed in the testimony and the conclusion. rea'~hed that i

I the spent fuel pool is fully protected.

Beyond that to I

j :test the conservatism in the i

I design of the* spent fuel pool it

!was assume4 that all the welds in the line are failed *

!However, the analysis showed the fuel in the spent fuel pool I

I j

i I

I I

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f !

• I I

I i

I i i I I I was still protected" even though this is well beyond the desig~

jbasis of the facility.

Lower Alloway's Creek Township asked I l the question, who is to say what is incredible?

The Licensee I or _the Atomic Safety and Licensing Board? And the Licensee i believes that the Board intended to allow the parties the l

I

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i !

/greatest liberty in fashioning their own responses.to the

!question with the proviso that the Commission's prohibition I

I jagainst consideration of Class Nine accidents was not r

j

!violated.

As the Licensee reads the Commission and the Appeal!

!Board precedents however, it is really neither the Licensee

/

I (nor the Board which determines whether Class Nine accidents I*

I

/should be considered in this case or any other case.

I J

I I

!think that's emphasized by the determination of Mr. Denton J

I Ii'

!which was proffered to the parties today.

I believe it l

' I stands for the absolute conclusion that the staff has stated I II I that Class Nine accidents should not be considered in the I

case of Salem and has made no recommendation to the Commissio~

i I

to that effect.

Therefore there be no affirmative recommend-i I ation.

Again this* Board.is precluded from considering Class Nine accidents as defined by the Commission.

Again we disagree with the statement by Lower Alloway's Creek Township which seems to have been adopted by the Board that one may look at the consequences or difference in consequences.and by some sort of circular reasoning arrive I

I i

I :

I

! l I

I 20 whether the question of whether you may consider Class Nine 21 accident by its consequences.

We believe that the 22 Commiss.1on and the Appeal Board have set forth the INT~*.. *n°""" VO'SATIM R~T'!105. IHC.

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jenvironmental factors associated with each facility which I

I

are to be examined.

These were examined in Mr. Denton's reply to the Colemans and we believe that consequences may not be examined.

But coming to the point here, we submit i

I : that Lower Alloway's Creek Township has submitted nothing

' I iwhich would preclude consideration of Licensees testimonies i i i nonresponsive to the Board's question and that testimony I

I I i should be admitted.

CHAIRMAN:

Mr. Valore, would you care to respond to objections which have been made to Dr. Webb's testimony?

i I You s.hould be aware that we are not insisting that you I

i i make responses, we are simply asking you whether you might I

l j have any.

I MR. VALORE:

My response will be rather short, but am I to be permitted a response to the response that the Licensee has made to the objections that I have made.

l i

CHAIRMAN:

No, I don't think we require further

• l argument on that subject.

I I

I I l I

i

• 1 i I I MR. VALORE:

The objections that have been raised I (and I'm trying to talk loudly because my microphone doesn't I work* - *are *you getting me?)

The objections that have been I

made are basically competency, irrelevancy and immateriality. j l~HATIO..AL '/E"SA"TIM R!C!"O't~ Ji+c.

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I i 7

10 11 t :z l:l 14 t..S I !They are the only objections left standing based on the I

I Board's ruling. It was announced at the start of the proceeding.

I submit that those objections are really objections that are properly raised after cross-examination l on qualifications* or after testimony h,as been.cons.idered.

I think certainly the testimony we have slibmitted is relevant and it is material and should not be disposed of on preliminary motion.

I might just say one other thing,

! Mr. Chairman.

When the NRC staff was speaking I did ask I

l J to be recognized and I had second thoughts about it.

I I

I ' 1 should stay on the record, and this probably may be

! i appropriate that I do object to the fact that both the

• I I Licensee and the staff have referred to the fac't the j

j Board.has asked the fifth question about Class Nine i

accident.

Now, the Board's question doesn't even mentio'n 16 the word accident.

That has been gratuitously supplied by 17 the Licensee and the staff.

And I also request that the ts staff to object to what I deem to be a flagrant nonresponse 19 by the Licensee to the Board's question because the 20 directions from the Atomic Licensing Appeal Board were 11 very clear, upheld the course of conduct that this licensing 12 Bo.:trd has *taken and said. it falls t"ar short of consideration 25 IHT'IJl!HAnaui. V°'SAnM ~~

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of any Class Nine accident.

I think we all understand what is going on in these proceedings.

At least I.am certainly sure that the Board does and I think I do..

And I think that any reference by staff and the Licensee using the Class Nine accident and equating it with the fifth question I'll have my objection clearly noted that I in no way succome to that kind of reference.

CHAIRMAN:

Mr. Moore.

MS. MOORE:

Mr. Chairman, the only objection left

' i I to the staff's testimony is that of Lower Alloway' s Creek I

I i Township and that objection is that the testimony does not i ! j contain an analysis of the consequences of the gross loss i

I of water from the spent fuel pool.

I would say that that I

i an objection to testimony but rather an argument that I should take place in findings and therefore is not a valid objection to our testimony, and the testimony should be admitted.

In addition, I would respond to Mr. Valore's last comment that it our case that this in fact, this I

I I

I I

i I

I I

I I

I I I I I

I i

I

! i I

I i i

I I gross loss of water from the spent fuel pool is a Class Nine I accident, and therefore he may disagree with our opinion I

but it is not in any way irrelevant to be bring up Class l

ZZ Nine accidents in this proceeding

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CHAIRMAN:

.we now have the responses by the parties to the objections have been made to testimony proffered by the parties.

In order for us to consider the remaining objections, we plan to adjourn this morning.

During the time wben we will be adjourned we request that j

I I

I I I

the parties get together to agree upon an order of presentatiop of witnesses.

We have already indicated perhaps that I

l I

I I

i :we encourage you to come up with a certain conclusion.

So i

I unless there are further matters which should be discussed now, we will adjourn until 1:30 p.m. today.

I would like to add a question, after I said that, and that is whether everyone has received the most recent addition to the testimony of Dr. Webb.

MR. VALORE:

I gave a copy to everyone.

MR. WETTERHAHN:

Mr. Chairman, In my objections to the testimony of Lower Alloway' s Creek: :Township, I had i I I

1 I

I I i I

I j

I objected to any a.ttempt to supplement the testimony at a i

I later time, that was a hint of that in the testimony.

I think I it is completely goes beyond the Board's order that the I

very day of the hearing we are handed some more pages of testimony with the indication there's more to come.

There was a deadline set forth, and as I said before, this

~---0*---

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I I l testimony is quite complicated, has a number of refererences.

I don't know what is in the further testimony.

The Board provided for exchange of testimony in advance in writing and I would object to any attempt by Lower Alloway's Creek to supplement its testimony.

CHAIRMAN:

Very well.

MS. MAC ARTOR:

I have not received the action by Mr. Denton that the Chair referred to earlier and during adjournment I would like to receive that if possible.

MS. MOORE:

Mr. Chairman, the* staff will present Ms. MacArtor with a copy during the adjournment.

CHAIRMAN:

Very well.

We shall.now adjourn until 1:30 p.m. today.

(WHEREUPON, the meeting was recessed until 1:30 p.m.)

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CHAIRMAN MILHOLLIN:

The hearing will now resume.

We have conferred on the motions which we have pending befOre us and we have the f.ollowing rulings.

First:

The motions by the licensee for certification of our denial of the licensee's motions this morning are denied.

Second:

The testimony proposed by the licensee is rejected as not I I 7

responsive to our question.

Third:

I Dr. Fanhauser's testimony 1

I is rejected as not sufficiently connected with the difference 9

between the present and proposed storage configuration.

IO Our ruling on the objections to Dr. Webb's testimony are ti fairly complicated. I'll state them now.

First, as to his 12 tJ.

13 19 1T testimony which is -- dated -- Mr. Valore can you help us

\\

. i I

with the date of.the testimony which was proposed in 1979

' i.by Dr. Webb?

I I

MR. SHON:

Among other things*he ha-s them dated February 27.

, MR. VALORE:

Excuse me.

You're speaking about the fourth board question as opposed to the fifth board question DR. LAMB:

Number three.

MR. VALORE:

The fourth board question dated July 23, 1979.

The third board question -- was dated, I believe CHAIRMAN MILHOLLIN:

Board question number three was dated I believe April MR. VALORE:

February 27, 1979.

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I CHAIRMAN MILHOLLIN:

No, I think it was April 18,

. I 1979.

This is only important for purposes of identification.

MR. VALORE:

Yes.

Let me make this point if I may.

At the top of.the page is says.testimony of Richard E. Webb I

I I I I

I I is respect to board question of order dated April 18, 1979.

Then it follows the accident hazards of spent fuel of the I I Salem Nuclear Power Plant by Richard E. "Webb, February 27, CHAIRMAN MILHOLLIN:

Very well.

At least all of us know which testimony we are referring to at this time.

Whatever the date of the testimony may be.

Our rulling on I

1979J I

I I i I

the objections to this testimony is as follows:

The material I on page 8 beginning w~th the word nor in the fifth line is rejected as irrel~vent.

The material runs down to the end of the paragraph.

The following paragraph, paragraph M is rejected as irrelevent.

MR. MACARTOR:

M?

CHAIRMAN MILHOLLIN:

M as in Mary.

On Page 15 of the testimony, paragraph F is rejected as irrelevent.

On i I I

I I I i '

i I

! i I

I Page 16, Line 4, the material beginning with the words The I

I I

1

'.I I

i most likely is rejected as irrelevent.

That material runs down to the next section, Section 5.

Section 5 on Page 16 I

is rejected as irrelevent,*,nd as having already been 1.

i i tiga ted

• 1 I

i Section 5 runs over to Page 18.

Section 6 beginning I

on Page 181 is also rejected is also rejected as irrelevent.

Section as irrelevent except

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subparagraph D, which!

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begins on Page 22.

Perhaps I should restate that to make it more specific.

Section 7 beginning on Page 20 is rejected as I I I I i ! I I

I I irrelevent with respect to the following I

subparagraphs or shall[

we say paragraphs is a section.

Section paragraph A on Page 20 is rejected, Paragraph B on Page 21 is rejected,

!1 paragraph C on Page 21 is rejected and in paragraph D, Line 5 the word since is deleted and the word since is deleted in Line 9.

In Line 13 the words 'it is imperitive' and all the following material is rejected as irrelevent down to the word

• 1 I

I investigated which appears on the fourth line from the bottom. j I

Paragraph E on Page 23 is iejected.

Paragraph F on Page 25 is rejected all as irrelevent I might add and everything else to the end of the section is rejected as irrelevent.

Section 8 on Page 33 is rejected as beyond the scope of the preceeding.

That's Section 8 on Page 33.

Sections 9 and Section 10 on Page 35 are rejected as irrelevent.

Now with respect to the testimony proposed by Dr. Webb in 1980 dated March 19, 1980.

This is Part 1 of a 3 part presentation, is that right?

MR. 'VALORE:

That's correct.*

CHAIRMAN MILHOLLIN:

Beginning with Page 5.

The materials following the heading Sight Radiation Levels Following a Reactor Accident is rejected as irrelevent.

That material runs over to Page 8.

With respect to the material beginning on Page 8 entitled Time For The Storage Pool To.

Loose It's Water By Boiling, on. Line 5, the material which I-~

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begins with the words For A Reactor Accident and ending with the word Cycle is rejected as irrelevent and in Line 8 the material beginning with the word If and ending with the word De.curred is rejected as irrelevent.

In* the next to last line on Page 8 the material beginning with the word If and ending ending with the word Occurs is rejected as irrelevent and on the last line of Page 8, the sentence beginning with word Since and. ending on Page 9 with the word Pool ii rejected as irrelevent and on Page 9 Line 8 the material beginning with the word Removing and running to the end of that paragraph is.

rejected as irrelevent.

On Line 11, first line, excuse me on Page 11, first line beginning with the word At, that word in the material foll?wing it is rejected.as irrelevent ending with the word Occurs in the next line.

On Page 14, on the ninth line up from the bottom, the sentence beginning with words It is important and ending with the word Analyze is rejected as irrelevent.

On Page 20, fourth line up from the I

I I I l

I I

I I I i

I i I I I I ' '

i i I bottom, the.sentence beginning with the words We might further I assume is rejected as irrelevent.

MS. FIELDS:

Mr. Chairman, was that to d_elete the entire sentence? *.

CHAIRMAN MILHOLLIN:

Yes.

MS. FIELDS:

Thank you.

CHAIRMAN MILHOLLIN:

The sentence ends with the I

I I i

I I

I I i i

I !

I i !

1!

word evacuation.

In the section of Part 1 entitled "Calculation

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:;:.'CC. 1 i 3 8 0 of R.E. Webb" or Part 1, Calculation number 3 is rejected as irrelevent.

MR. WETTERHAHN:

Could you give me

~HAIRMAN MI.LHOLLIN:. I'll repeat that.

In the material entitled "Calculation of R.E. Webb for Part l" which is a supliment to Part 1 of Dr. Webb's proposed testimony,

.Calculation number 3 is rejected as irrelevent since it I I I

I I I

i I

I I I I I

I supports material which has already been rejected.

I think that we can all ass_ume that when the board rejects a. portion of the I testimony that the calculations that support it are also rejected automatically.

This now brings us.to Part 2 of Dr.

Webb's proposed testimony.

On Page 36, that page is rejected as either repitio~s or irrelevent to our questi9n.

MR. TAUSNER:

Was that the Consequences of Sequoian Fire that was rejected?

CHAIRMAN MILHOLLIN:

Yes.

• . MR. TAUSNER I Thank you.

CHAIRMAN MILHOLLIN:

And the material beginning on Page 37 and ending on Page 4 7 down the heading "Pres.ent Pool j

I I I I I

I !

I j

1 I

I I i

I I l !

l I I Rack Design" is rejected as irre.levent since it's not directed 1

1 specifically enough to. the difference between* the pr.esent and the proposed rack design.

The petition to Congress which is attached to the testimony in Part 2 is also rejected as irrelevent to our question. together with it's Appendix number

7.

The letter which is attached from Dr. Webb to Mr. Vincent I..,......~ '(.,_..TIM ~QC!Ri m. f~

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I Johnson is rejected also as not specifically directed to the I

I I

I question we posed.

That concludes our rulings on the motions rather on the objections to testimony.

Have the parties agreed upon an order of presentation?

MS. MOORE:

Yes Mr. Chairman, we have.

MR. WETTERHAHN:

Mr. Chairman, I believe I can state that we have adopted the order suggested by the board.

CHAIRMAN MILHOLLIN:

l I

I i I I I

I I

I know I Very*well, MR. WETTERHAHN:

Mr. Chairman, one question.

that you said the calculations which support CHAIRMAN MILHOLLIN:

Yes.

MR. WETTERHAHN:

So you have not necessarily gone through and found that each of the calculations I just noted the calculation immediately following the letter to i

I i

i I i

I Mr. Johnson supported or I believe something was rejected, thati i I

! i would also be rejected.

CHAIRMAN MILHOLLIN:

Yes, in Part 2 of the testimony j I

the calculations which support the portions of the testimony which were rejected would also be rejected, but there was a portion of the testimony in Part 2 which was not rejected and we can assume that the calculations supporting that portion of the testimony would still be in the case.

MR. WETTERHAHN:

I believe the parties might need some time to go back over this extensive ruling by the board l !

I I

I i i

1.!

. in order to consider if the import of the ruling is significant!

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13 8 2 upon the examination necessary, but since the staff is proceedin'g first and.there's been no objection I think we can do that overnight.

CHAIRMAN MILHOLLIN:

I was going to ask the staff whether -- the staff would prefer a short recess in order to absorb what I've just announced before going forward.

MS. MOORE:

Yes Mr. Chairman, the staff would like I that recess.

I MR. WETTERHAHAN:

One further point.

Now that we've i seen the rulings of the board, the board might need to ration out or striking those portions of the testimony which we did and* for striking the licensee's testimony in its entirety.

CHAIRMAN MILHOLLIN:

Well, I think I announced the rational as I made the rulings.

Most of the rulings were made because we didn't think the responses were sufficiently definite in connection with *the question we asked and so we thought the relevency of the* responses was insufficient.

MR. WETTERHAHN:

For the record in an appropriate time in which is proper of the licensee's testimony.

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I CHAIRMAN MILHOLLIN:

I I don't think that's necessary. 1.

ll I think that we can assume that -- well, very well.

You want n

to preserve your rights of course.

In an appropriate time I n

think all the testimony should be marked for identification so i l the record will show which part was admitted and what part was 13

., rejected.

I think everyone understands that.

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.~C:. _1_3_8_3 MR. WETTERHAHN:

Thank you.

CHAIRMAN MILHOLLIN:

Ms. Moore, what length of time do you think would be appropriate to allow you to reflect upon I

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our rulings?

MS. MOORE:

Mr. Chairman, could we have 10 minutes?

CHAIRMAN MILHOLLIN:

Of course.

We'll a9journ for 10 minutes.

(WHEREUPON, a 10-minute recess was taken.)

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CHAIRMAN:

The hearing will now come to order.

Is the Staff ready to proceed?

MS. MOORE:

Yes, Mr. Chairman.

As a preliminary matter, to return to the order of the proceedings, all the parties agreed that the Staff would present their witnesses first.

The Staff would propose that they. be allowed to cross examine last, however.

Licensing has agreed if it is agreeable]

to the Board.

I MR. WETTERHAHN:

That is, the other witnesses.

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MS. MOORE:

Yes.

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CHAIRMAN:

Very well.

Do you mean that when witnesser I

other than your own are on the stand you would prefer to go las~

in the order of cross ex~mination?

MS. MOORE:

(

CHAIRMAN:

That's correct, Mr. Chairman.

Did you agree upon an order of cross examination for witnesses other than your own on the stand?

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. MR. WETTERHAHN:

We didn't discuss it, but the usual j order is the Licensee, other intervenors, and I guess that wou~d I

be Mr. and Mrs. Coleman, the States, and then the Staff.

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I CHAIRMAN:

Very well.

i MS. MOORE:

Shall I proceed, Mr. Chairman?

CHAIRMAN:

Yes.

MS. MOORE:

Mr. Chairman, the Staff now calls to stand Mr. Walter F. Pasadag and Dr. Allen Benjamin.

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WHEREUPON, a panel of two witnesses were sworn for testimony.

DR. AL BENJAMIN MR. WALTER F. F.?,.SEDAG DIRECT EXAMINATION BY MS. MOORE.

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Mr. Pasadag, do you have in front of you a document 1 I

Q entitled, Professional Qualifications of Walter F. Pasadag?

A Yes, I do.

Q Did you prepare these professional qualifications?

A I did.

Q Mr. Pasadag, please speak somewhat louder.

Are there any additions or corrections to your professional qualifications?.

A No there aren't.

Q Are the statements in your professional *qualifica-tions true and correct to the best of your knowledge, infor-mation and belief?

A Yes, they are.

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. I Mr. Pasadag, do you have in front of.you a document:

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Q testimony?

A I do.

Are there any additions or corrections to this I

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i Yes, there are several corrections and an addition. I I

I Q

Would you please state the corrections and addition$

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for the record.

A Okay.

On the first page, the third sentence, there is a number in the.re that says 8 feet, that is in error, it should be 6 feet rather than 8.

On page 4, the third sentence I.

on that page that starts with the words -- in order to estimati the differences.

I would like to delete that statement up to !

I II the end of the paragraph.

The paragraph ends with --

SSP modifications.

And on page 5 I would like to insert the word The line now reads, I on the last line of the second paragraph.

would not contribute to the consequences of this event.

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i would like to insert the word substantially after not, so that!

it will read would not substantially contribute to the consequences of this event.

And in order to correct my testi.- 1 many and clarify it, I have some additional testimony that is I dated -- uh, I don't have a date on that.

It is titled "Further Testimony of Walter F. Pasadag In Response to Board Question No. 5," and consists of three pages.

Q Is this document as corrected and added to your testimony in this case?

A I. didn't hear the question.

Will you repeat it please?

Q Is this document, as corrected and added to, your testimony in this case?

A Yes it is.

Q Are the statements contained in your testimony 1-~*1-n

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A Yes they are.

MS. MOORE:

Mr. Chairman, I would now move that the I

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I testimony as corrected, of Mr. Pasadag, along i

with Mr. Pasadag'f Professional Qualifications be bound into the record as if read.

CHAIRMAN:

Hearing no objection it will be so admitted and bound.

(WHEREUPON, Mr. Pasedag's testimony and Professional Qualifications are admitted into evidence.)

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In the Matter of UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD PUBLIC SERVICE ELECTRIC &

GAS COMPANY Docket No. 50-272 (Salem Nuclear Generating Station, Unit No. l)

)

)

)

)

)

)

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Proposed Issuance of Amendment

• to Facility Operating License No. DPR-70 Question:

Answer:

DIRECT TESTIMONY OF WALTER F. PASEDAG IN RESPONSE TO BOARD QUESTION NO. 5 In the event of a gross loss of water from the spent fuel storage pool at Salem l, what would be the difference in consequences between those occasioned by the pool with th:

expanded storage proposed by the Licensee and those occasioned by the present pool?

The Staff has reviewed the potential for a gross loss of water from the present and expanded spent fuel pool.at Salem.

Our review has identified no credible mechanism.for a loss of water from the pool which would result in any sµbstantial off-site dose consequences. The spent fuel pocil consists of a reinforced concrete basin of wall thickness exceeding 8 feet on all sides and 24 feet at the bottom.

The entire pool is lined by a 1/4 inch steel liner.

The poo1 integrity under all postulated accident conditions was reviewed at I

\\

the time of licensing. The additional structural loading resulting from the pool expansion *is' well under 1% of the total lumped mass in the fuel handling building analytical model, and, therefore, do.es not appreciably change the structural response of the spent fuel pool.

The walls have been investigated for the seismic effect of the heavier racks and stored fuel.

The ~igh density racks have no appreciable effect on the structural stability and seismic

• response of the spent fuel handling buildfog. Therefore, the leaktightness of the expanded pool under all post~lated accident conditions is. assured, and no appreciable change in the margin of protection arises from the pool modification.

The pool design includes a weld channel leak collection system which is intended to collect any leakage of the liner welds.

After collection in the weld channels this leakage is piped to the radwaste system via ten (10) one inch diameter leak-off tubes which discharge to a radwaste drain.

The largest credible leakage from the spent fuel pool would occur if all 10 leak-off tubes were to discharge at their maximum capacity. This scenario requires multiple punctures of the spent fuel pool liner, and therefore, is considered highly unlikely.

A maximum leak rate of no more than 710 gpm could occur in this case, resulting in a rate of decrease in the pool water level of l. l inches per minute. This leakage would be detected by the indication and alarm of the leak collection sump in the control room and result.in the automatic operation of the sump pump.

In addition, prolonged leakage would result in a low spent fuel pool water level alarm.

Following detection of this leakage the tubes could readily be capped to withstand the maximum back pressure of 19 psig.

The potential radiological consequences from ~ny accidental release of water from the spent fuel pool would be directly proportional to the fission and activation produ~t concentrations in the water.

In our Environmental Impact Appraisal of the Salem spent fuel pool modification (Staff Exhibit 6C, Section 5.3.1) we concluded that the additional release of radioactive material to the spent fuel pool water resulting from the additional stored fuel is insignificant.

Consequently, the difference in radiological consequences of a spill of this water would also be insignificant.

- 3.-

We also have evaluated the differences in the liquid pathway between the Salem site and the typical site evaluated in detail. in the Staff's Liquid Pathway Generic Study (NUREG-0440). in order to determine whether special site-specific factors might be present at the Salem site.

We examined the groundwater transport, surface water transport, and usage of the water bodies surrounding the Salem site and found that the Salem site compares favorably with the typical estuary site of the Generic Liquid Pathway Study.

Our evaluation indicates slower dispersion of postulated releases via the liquid pathway compared to the typical estuary site of NUREG-0440.

We conclude, therefore, that there are no site-specific peculiarities with respect to the Salem site which would invalidate our conclusions concerning liquid releases stated in the Environmental Impact Appraisal.

In our attempt to define the meaning of a 11gross loss of water 11 we have also considered a hypothetical, non-mechanistic, instantaneous. loss of all cooling water in the present and expanded spent fuel pool combined with an inability, for unspecified reasons, of refilling the pool, or providing any ct.her mode of cooling other than natural (convective) air cooling.

In view of the thorough review oy the integrity of the spent fuel pool, even under design basis earthquake conditions, such an event is considered incredible, and clearly exceeds ~ll design bases. Accordingly, such an event should be classified as a 11class 9 accident.

• For fresh spent fuel, continued denial of water cooling capability m*ay eventually lead to oxidation and failure of the clad, and to overheating of the U02 fuel, with the potential for the release of the fission products in the U02 fuel in either the present or the expanded pool.

The doses at the site boundary resulting from this postulated release would depend heavily on the postulated scenarios for the mechanism of the water loss, subsequent cooling attempts, building integrity, etc.

In order to estimate the differences in' the potential consequences of this hypothetical event arising from the pool modification, the onset of self-sustaining clad oxidation may be used as a conservative criterion for the release of the fission products from the fuel.

A detailed calculation of the heat-up of spent fuel in various configurations is given in a report by Sandia Laboratories (Spent Fuel Heat-Up Following Loss of Water During Storage, NUREG/CR-0649).

From this report it is apparent that PWR fuel in the configuration of the modified Salem storage racks cannot reach temperatures for self-sustaining clad oxidation if its age (since removal from the reactor) exceeds 280 days.

Since the additional fuel stored in the expanded pool would be at least four years old, as described in section 5.3.l of the Staff's Environmental Impact Appraisal, no additional clad. failures, and hence no additional releases beyond those expected from newly discharged fuel would occur as a result cff the SFP modification.

Based on the for~going considerations we reach the following conclusions concerning the relative effects of the Salem spent fuel pool modification:

(1) The worst credible loss of water from the fuel pool would occur if the spent fuel pool liner were punctured simultaneously in ten locations such that a 11 ten leak-off tubes would discharge* water at their maximum capacity*.

Because of the multiple failures which would have to occur to

• realize this scenario, this event is considered highly unlikely.

Our evaluation of this event indicates that there are no substantial differences

• in the radiological consequences arising from the modification of the pool.

(2) A loss of all water from the pool is not considered credible, and would exceed all design requirements for the present and expanded spent fuel pool. If no mitigation of this hypothesized event is assumed, the radiological consequences could be large, as a result of possible overheating and clad failure of any newly discharged fuel in the pool.

These consequences could occur either with the present, or with the expanded pool.

A detailed comparison would require specification of a scenario for the loss of water and make-up capacity. However, we conclude that any additional fuel in the pool as a result of the pool modification would not contribute to the consequences of this event.

(3)

The expansion of the spent fuel pool at the Salem site does not constitute an exceptional case with respect to the liquid pathway or design features of the spent fuel pool resulting in risks substantially greater than for an average plant. Therefore, we conclude that the environmental consequences of Class 9 accidents need not be evaluated.

PROFESSIONAL QUALIFICATIONS WALTER F. PASEDAG Environmental Evaluation Branch Division of Operating Reactors I am employed as a Section Leader in the Environmental Evaluation Branch, Division of Operating Reactors, U. S. Nuclear Regulatory Commission, Washington, D. C.

My duties are to provide technical supervision and review the work of personnel assigned to n\\Y section.

My responsibilities include planning, coord-inating, and reviewing the safety and environmental evaluations of modifications to reactor facilities in the areas of external hazards, radiological accident analyses, radiatton protection, and overall environmental assessments and analyses.

I am also responsible for providing guidance for and technical review of various documents including Safety Evaluations, Environmental Assessments, and Environ-*

mental Statements and for providing guidance for the development of technical positions for reactor and site standards, codes, and criteria associated with programs assigned to the-section.

I recei.ved a BS degree. in Engineering Science from the State University of New York at Stony Brook in 1966.

The samr;! year, I joined the Graduate Student Training* Program at the Westinghouse Educational Center in Pittsburg, Pennsylvania.

My professio~al experience in the nuclear power industry i.ncludes six years of activity in the nuclear safety field at the Atomic Power and Nuclear Energy Systems Divisions of Westinghouse, and, under a technical exchange agreement, at the Reactor Development Department of Siemens A. G., Germany.

During this period,

~I

/ from 1966 to 1972t I have held positions of increasing technical responsibilities in the areas of radiati.on shielding and personnel safety. emergency core cooling systems design and evaluationt including the development of thermal-hydraulic models of the primary system during the reflood phase of the loss-of-coolant accident, development of design criteria for ventilation and filtration systemst

• and the design and analysis of post-accident fission product removal and control systems inc.luding containment spray and dual containment systems.

I joined the Atmoic Energy Conmission as a Nuclear Engineer in the.

Accident Analysis Branch in l972t where I was responsible for the development of analytical models for the evaluation of engineered safety features relating to radiological safety and the review and evaluation of power reactor plants in the area of radiological and site safety.

I am the author of several reports and articles concerning the effective-ness of various engineered safety features for LHR.and HTGR reactors which are published in the technical literature.

I am a member of the American Nuclear Societyt and.the Standards Cormiittee of the ANS.

I am a licensed Professional

• Engineer registered in the Commanwealth of Pennsylvania.

.* -1.._:

In the Matter of UNITED STATES OF AMERICA NUCLEAR REGULATORY COt+1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket No. 50-272 PUBLIC SERVICE ELECTRIC &

GAS COMPANY (Salem Nuclear Generating Station, Unit No. l)

)

)

)

)

)

)

)

Proposed Issuance of P.rnendment to Facility Operating License No. DPR-70 Question:

Answer:

FURTHER TESTIMONY OF WALTER F. PASEDAG IN RESPONSE TO BOARD QUESTION-NO. 5 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 occasioned by the pool with the expanded storage proposeq by the Licensee and those occasioned by the present pool?

I have performed additional investigations of the phenomena associated with the postulated gross loss of wate~ The following additional testimony is offered to correct and clarify my testimony dated April 10, 1980.

r Our original estimates of fuel heatup in a dry fuel pool were based on the results reported in NUREG/CR-0649 for a well ventilated fuel pool.

I have subsequently asked Dr. Benjamin of Sandia to provide me with additional caJculations for ventilation rates equal to those at Salem.

His calculations indicate that the decay time required to assure that the fuel's decay heat genera.tion will not result in oxidation temperatures above 900°C is about one year *

• In addition to the work by_Dr. Benjamin mentioned above, the Staff has also looked at whether a "zirconium fire" could propagate. The Staff recognizes that the new storage configuration results in less natural convection, and hence a higher likelihood of reaching oxidation temperatures and possible clad melting for recently discharged fuel. Although heating of fuel assemblies stored adjacent to the most recently discharged assemblies would occur, the Staff has not identified any credible mechanism for the propagation of a "zirconium fi_re 11 to the four year old or older fuel stored in* the pool as a result of its expansion. It is possible to postulate radiant heat transfer from the recently discharged elements to adjacent bundles causing clad oxidation temperatures. For this reason the heatup of older fuel assemblies stored irrmediately next to the most recently discharged assemblies, resulti~g-=

in the creation of a substantial layer of zirconium oxide on the outside of these rods, cannot be ruled out. The modeling and computation of such effect would be extremely complex.

However, the Staff believes that this would not result in more than limited oxidation of four year old (or older} fuel.

Such limited oxidation of four year old (or older.) fuel would not lead to a substantial release of fission products beyond those released from the freshly discharged 1/3 core. This is'a result of several factors, including the decay of volatile fission products (other than Cs-137), the fact that the primary ~ource of energy is external to the rods, the thermal insulating property of the zirconium oxide layer which would reduce heat conduction to the interior of the rod, and the formation of temperature gradients opposed to the direction of diffusion.

Although some eutectic formation would occur after heating the rod to the zirconium melting temperature, the uo2 matrix cannot be expected to reach its melting point *

• Although it is difficult to quantify these parameters we conclude that the I

fission products released by this process would be a small fraction of those resulting from the meltdown of the recently discharged 1/3 core which would have to be postulated in order to achieve the heating (to temperatures above 9oo0c) of the older fuel. The total release of fission products, therefore, would not exceed the releases calculated for reactor.accidents in WASH-1400.

The consequences of this postulated Class 9 accident in the spent fuel pool, therefore, would be bounded by those calculated in WASH-1400, so that there would not be any additional risk to the health and safety of the public beyond that identified in WASH-1400.

Although additional postulations concerning possible scenarios for a gross

• ~.-

loss of water worse than the 710 gpm leakage described in the Staff's testimony were investigated, no possible mechanisms which would cause a total Joss of water, as well as a prevention of make-up watel'j could be found.

The reactor accident scenario postulated by Dr. Webb was considered, and it was concluded that, based on.the WASH-1400 estimates of the consequences of such accidents, that there is no reason to expect that the make-up water sources would not be available, or that access to the spent fuel pool would.*not be readily available with routine radiation protection and shielding provisions.

Even if a total

- loss of water is postulated. {although no mechanism for such a loss was identified},

the spent fuel pool could be re-filled with the existing make-up water capacity.

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MRS. MOORE:

The.Staff is preparing the copies to

. I give to the reporter.

CHAIRMAN MILHOLLIN:

Very well.

BY MS. MOORE :

Q Dr. Benjamin, do you have in front of you entitled The Statement of Qualifications of Dr. Allen F~ Benjamin?

A Yes, I do.

Q Did you prepare these professional qualifications?

A Yes, I did.

Q Are there any additions or corrections to your

• professional qualifications?

I f

. A I am looking at the professional qualifications -thatj I have in front of me right now.

One of the pages. is missing. I I have a copy of this in my own brief case which is complete.

I only have Page 1 of my qualifications.

Q Oh, there should be another page.

MS. MacARTOR:

Mr. Chairman, I believe that the parties have two pages.

CHAIRMAN MILHOLLIN:

• The Board has two pages.

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i I I MS. MOORE':

Mr. Chairman, it has been note.d that the!

court reporter Only has Page 1 ~f Di::. Benjamin's qualification~

i I and the Staff will see that she receives Page 2.

I CHAIRMAN MILHOLLIN:

Have you not provided all the I I

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other required documents, you have referred to, to the reporte~?

j MS. MOORE:

Yes.

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• MOORE :

I

• I Q

Dr. Benjamin, are the statements in your p:rofes.sional!

qualification, true and correct to the best of your knowledge and belief?

t I

. A. ::~ *M:::' ar:. Chairman, I would move that the I

professional qualifications of Dr. Benjamin be bound into the I i

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record as if read.

CHAIRMAN MILHOLLIN:

Hearing no objections, they j

I will be so bound and admitted.

(WHEREUPON, the Professional I Qualifications of Dr. Allen Benjamin are admittedi into evidence.)

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Statem*nt of Qualification*

Dr. Allan s. Benjamin April 2, 1980 6urincJ th* paat ~** years, *z have been employed ** ~PhD M.mber of th* Technical Staff in th* Nuclear Fuel Cycl*

Saf *tY b11aarch Depar'1:m*nt at Sandia N~tional Lat>ora't.Ori**

in Albuqu*rque, New Mexico.

My r**ponaibiliti** include project aanaq.zient and lead technical accountability ~or two r****reh proj*et* cf high priority regarding improva4

• afety in light water r*mctora.

~h* tirat project axam.ines th* deaiqn and *Y*tem implication*

and phenomenological a*pecta of filtGred-vented contairunent

• Y*tems aa a maan* for mitigatin9 th* conaequenee* of core meltin9 accidents.

During the past thr** StOnth*, l have alao been ***iqned the technical lead in ******in9 th* fea*ibil~ty of retrofitting *uch *Y*tem*.into th* :ion and Indian Point reactor*.

I have been th* author or two Sandi* report* on the *ubject, a principal author of ar~icl** publi*h*4 in the Journal of th* Xn*titute of Electrical and Electronics Enqineera (IEEE Spectrmn) and th* Tranmaction* of th* AJneriean Nuclear Soci*t:.y, and pre**nter of an invited paper at th* Atomic

?ndus~ial Porum Workshop on Licenaing and Technical Iaau**-

Poat TM.I *

'l'he a.cone:! project that I am currently involved vith investi-9ate* experimentally the chemical forms and t.ranaport behavior of f i*sion products in reactor primary ayatema during core melting accidents, ** a means for deterznininq the amount*

and forms of radioactive material that **c*p* t.o the containment.

In conjunction with thi* activity, X recently aerved on a planning cocmnittee of industry representativ** to recommend data gathering pr1oriti** for th* Thr** Mil* ?*land reactor.

At Sandia, I have also been principal inveatigator for a nwrsb9r of other reactor-related aafaty studies, includinq (1) an a****mnent of apent fuel heatup following lo** of water during *torage, (2) th* mod*lin9 of heat tzan*f*r ph*n0111*na during core-concrete intera~ticn* t.hat.. y occur durinq.core m*ltdown accident*, and (3) a *urvey of contain-ment analy*i* proc9dure* for liquid metal fast ~r*eder r*actor*.

My analysi* ot t.h* apent fuel problem spanned 1-l/2 years resultinq in **veral p\\lblication* (a Sandia report, a paper in Nuclear T*chnol~, and two paper* in th* ANS Traneac~iona).

'l'h* work on cor*-concrete heat tranafer int*ractlon* i* also beinq publiahed and preaented at aeveral forum* apon*ored by the a&erican Nuclear Soci*ty/European Rucl.. r 8ociety.

Prior ~o San4ia, % v** employed for *1*v*n year* *~ 'tllW ly*tem9, Redondo Beach, Cali~ornia, wh*r* l pertoJ:m*d analy*** related

~ re-entry vehicle technoloqy in th* following area*i

i I

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f (1) a~rodynrlltic h~t trnnsfor to bodi~s of revolution, (2) non~/

ioothon:ml wall affectn on haat tri-.nc:fer, (3) rr.uit~nt boat tr~ofor, (4) boundnry layer tran~ition, (5) conduction

• in ono, two, nnd throa di.ccna*iono, inclurS!ng uoe of ttiorr..al nnnly2or t:!othods., * ( 6) cb1ation and phono chanqo phcmo:nona

• ~1.m.tin9 to heat chielda, (7) change of shtipa durinq ~a-ontry,

• (8) rain end duot croaion, (9) viccoua and inv!cc!d cuporcon!a

.flova, * (10) drn9 datanninntion, (11) trajectory cnulyoirs, J

(12) lcaar effcctu on haat ahieldn, (llJ i:ranapirotion cooling, (l.4) evaluation ot oxparimcntol facilitic~, (15) c.nnlyai'.

ot exparimontal data, ~nd (16) oomputar ~cthods for lurge-ocolo dat:a handling.

From 1972 to 1975, X wos projt!.!ct t:l.nnc901: of' thca.Erosion O.Ota Annlynis Proqrnm for t:.ho Air Foree Hntcr!nl*

• Laboratory nnd th* Space nnd Mimsilo Syatcnno Orgonization" 1,ln 1977, culminatinq a six-year vork-atudy program in which

• I Vaa-aidQd.by a Cooparntive Fellowship from TRW Syst~.ms,

~ I vaa awarded a PhD degroe from UCLA with a major in heat and mass transfer ond minors in fluid mechanics and problem aolving/deciuion makinq.

Ky overall grade point cvoroge was

~ 3.86 out of a possible 4.00, the only B baing in an elGetiv*

• .*

• courm* in physioloqy.

My di1111cartation consisted ot a dotailcd

~- ntudy of numerical methoda for r:iolving ineompremmiblo, rccir-

..,:-culatinq flow problems at high Reynolds numbcars.

Tho rcacults*

'hav* boan published in th* Journal of Computational Phymics

~,-(Deoa~ar 1979) *

. ' Prior t.o UCLA, ? obtn!ned th* Bachelor of Saionco do9re20 in

• • 1964 nnd the Kaster of Science deqraa in 1966 tram Dr~

Univeroity, ProvidQnca, Rhode Island.

At Brown, I main~inod grade point nveraqoa of 3.53 as an under9raduate and 3.62 as a

9raduat~ student, nnd I roceivi&d ~y diploma with the dictinction *:m.tlqna cum laude.*

I was o1ected to Sigr.1& Xi and Tau 'Sota Pi Notional Honor Soclation, wa11 aw-ardcd a ocholarah!p from Alcoa 'a.nd a fellowship from NASA, vas

• daai9nntod a Francia Wayland Scholar, ~nd waa a rocipiont o~ tha Brown Enqin11orin9.Allsocia-eion Prize.

My snaotora thocis vos on tho cubjoct ot heat trana~ar acroaa turbulent, incom-praaaible boundDry loyera ~var both ctt.ooth and rough curfncos *

~.**

I am currently a Hcmber of the J\\r!loric:an Socioty of r:c'.chcnical En9inaera (ASHEJ *

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BY MS. MOORE :

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Q Dr. Benjamin, what was your role in the preparation of Mr. Pasedag's testimony?

A I acted as a consultant to Mr. Pasedag in answering questions having to due with the heatup of spent fuel in the grain spent fuel pool and I also discussed with him aspects of such issues as Zirconium oxidation.

The basis of my being I

I I

I I

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I I I asked to provide consulting advice was the report, which I wrote with several colleagues at Sandia Laboratories on subject of spent fuel heatup following a loss of water accidents.

Q Dr. Benjamin, do you agree with Mr. Pasedag's conclusions conc~rning spent fuel heatup and minimum decay

times?

A Yes, I agree with those conclusions.

i Q

Now, Dr. Benjamin, Mr. Pasedag has also testified

)

I concerning whether.as as zirconium fire would propagate in thel spent fuel pool without; do you agree with the conclµsions set forth in that portion of Mr. Pasedag's testimony?

MR. VALORE:

Excuse mr. Mr. Chairman.

Could I have that question again?

I just missed one phrase of that.

Could the reporter please read it back?

BY MS. MOORE :

A Mr. Pasedag made the statement that the Staff has not identified any credible mechanism before the propagation I I I

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I have a -- some difference of opinion with Mr. Pasedag and the interpretation of that sentence.

First, I would like to -- the question was asked as to whether I agree about is a zirconium fire.

First, I would like to say that I do not believe that a fire would occur in a spent fuel pool in the manner that has been mentioned in previous testimony by Dr. Webb.

. However, I believe that it is possible -- or let

me say that I have done some analysis over the past week.

The oxiadation of zirconium propagating from fuel element I.

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to fuel element from.the newer fuel elements to the older.

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And I want to first make the point that this I analysis is outside the scope of ;the report I did and therefoJe, i l i is not nearly as detailed nor has received a review that the

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report has received.

However, I will state that I consider on!

I 13

19.

I I I i I i

i the basis of current knowledge that it is that that possi-bility _cannot be ruled out that the oxidation of Zirconium might propagate to older fuel elements, even older than four years old.

I do not believe that a Zirconium fire would 11 occur, that I do not believe that there would be a deflagra-

!2 tion (?) that would lead to a rapid consumption of ;the Zl zirconium in the pool, but I believe that at the current time what cannot ;be ruled out is the possibility that by th~

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I I assembly, it may be possible to propagate a zirconium reaction I I to the older fuel elements.

I believe that this process would I take hours, at least.

So basically, my area of disagreement with MR. Pasedag is that his statement that there is no credible mechanism for this propagation to occur.

Now, I would also like to state that this is not I

I i !

I a conclusion of what will necessarily happen.

I That there are I I I l mitigating factors such as, for example, the change of geometry that occurs when zirconium reaches its melting I i !

temperature and melts, but mainly, what I wanted to state at the present time, I do not think the possibility of a prop-I agation of an oxidation of thermal oxidation can be ruled out. I I

Q Dr. Be~jamin, Mr. Pasedag concluded in his further testimony that consequences -- Page 4, consequences that the I I I I I

loss of water accident in the spent fuel pool would be bounded!

I !

i by those in WASH ~400, do you agree with Mr. Pasedag's conclusion?

l A

I can neither agree or disagree with that conclusion!

because it is beyond the scope of any analysis that I have*

done; therefore, I have no opinion on that conclusion.

Q To clarify the record, it was Page 3.

Thank you, Dr. Benjamin.

MS. MOORE:

Mr. Chairman, these witnesses are now available for cross examination and questioning by the Board.

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I QUESTIONS BY THE BOARD:

CHAIRMAN MILHOLLIN:

Dr. Benjamin, I would like to I

I I I

address a-question to-you.

You said in your opinion that therl I

would be no fire.

Well, perhaps, I should distinguish between I fire and oxidation.

I take it *that you ~elieve that there I

could be an oxidation without what is properly thought of as al l I fire.

DR. BENJAMIN:

Yes.

The term fire, as Dr.. Webb has I used it, implies a situation which involves flames that involve a great deal of convection and spreading of *flames I

of fuel assembly to fuel assembly and in Dr. Webb's testimony I he states that there is a presitent for this type of fire, namely the accid~nt.that occurred at Betus (?) Faciliity, where there were storage bins of zirconium scrap metal in which the scrap metal caught on fire.

Now, first I should say that I am not an expert on the subject of zirconium fires, but that I have consulted with several people where I work at Sandia Laboratories, who I would consider to be more of an expert than myself on that subject.

I have also consulted *with Dr. Lou Baker, at ARGON I

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I I who I would consider to be an expert on that subject and. the j conclusions that I have obtained from these discussions is. thab I

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in a situation where we have a lot of zirconium metal; in the I i

form of cladding around fuel wells, it would not be possible for a flame of this type to develop.

That any burning of l~ncl!MW. '/aimaTIM ~U*UQI 'm I~

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t oxidation that occurred might result in a brightness or a kind of white illuminonisty about the fuel cans in the immediate vacinity of where this reaction is occurring but that it would not result in flames.

• The difference is because where the powders -- the zirconium powders, first of itself.

So, on the basis of this I believe that it is possible to have a hotness in the vicinity of where the oxydation is occurring, and I believe it is possible to transfer heat from fuel assembly to fuel assembly by the process of thermal radiation, but I don't believe that a

deflagration and the occurrence of a fire with flames and rapidly spreading fire is possible in the spent fuel pool.*

MR. VALORE:

I don't think I'm permitte.d to move to strike the answer when it is the Board's question.

I would like to protect my rights* on record*.

The witness has I

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He has testified as to the!

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I just want to be sure that I will be permitted some cross examination, even thoughc I would obviously get into hearsay.

CHAIRMAN MILHOLLIN:

Of course, so the Board recognizes that his testimony is based on the opinion of others.

MS. MOORE:

Mr. -Chairman, was that an objection to this testimony or, CHAIRMAN MILHOLLIN:

No, I don't interpret it as an objection.

MR. VALORE:

No objection.

I just wanted to be sure my rights were protected.

QUESTIONS BY THE BOARD:

MR. SHON:

Dr. Benjamin, I am a little concerned I

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I with the way in which you have made the comparison between thel i

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Clearly this material is not powdered or very small frangible bits of Zirconium and does not have an extremely large surface area, but the surf ace area is well supported with small passages in between it (the pieces of I

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This is just the kind of thing that you construct!

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when you are trying to make logs catch fire, for example, long strips with lots of space for oxidizing medium to move between them, and there is an additional source of heat even in the old fuel there is an ad~itional source of heat to warm it up and bring it closer to its ignition temperature."

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.hot quite certain how you 'could be so sure that this and the I I r situation in the bins at Mills Atomic Power Laboratory or wherever it was (Westinghouse's installation) are so different I I

in the kinetics of the reaction between oxygen and zirconium I I

in the way it works physically.

Do you see what I mean?

DR. BENJAMIN:

The kinetics of the zirconium I

7 I

I reaction, whether it's scrap metal, powder, or fuel rods is I

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the same, of course.

MR. SHON:

I'm sorry, I mis-spoke, used the wrong TO i

word.

What I meant was the physics of the situation in which i i

the material was being in one case, driven toward its ignition j 12 point only from other burning material, and the second case ll while not as fin'?lY divided perhaps, is being driven toward its ignition point at two sources of heat; that is other IJ burning material plus radioactive decay and the physical lo*

situation exposes it to the burning, that is the way in which 17 air can pass through the dispersed zirconium.

I did not mean ta the kinetics of reaction.

19 DR. BENJAMIN:

Well, again I have to refer to other 20 people's opinions on this, since as I say I am not an expert 21 on the subject.

I do consider myself qualified to answer

~

questions of heat transfer.

Now, Dr. Baker said that he per-1:1 formed experiments with scrap metals, or zirconium similar to what was in Betas, except that without the contaminants that were present in Betas and he heated them up, he said, to 1-~

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i temperatures that produced ignition, but he said that the

' i I ignition was altered in the kind of burning that I described, a kind of luminosity without flames propagating into the air. I Now the question of ignition is a little different than the I

question of a fire, as we commonly think of fire, I think.

l l !

I I interpret the word ignition to mean a burning that is initiated and which sustains itself because of the inability to remove heat fast enough in order to be able to put it out.

I I I

I Now our calculations for spent fuel pools say that this will I

j happen in the newest or hottest spent fuel elements, once they *1 f

reach a temperature of approximately 900 degrees centigrade. I

)'

We have continued our calculations beyond the 900 degree centi-1 I I grade temperature up to and beyond the temperatures of zirconium melting for those fuel elements we have not done any I !

r calculations that would then determine what happens to the rest:

I I

! i of the elements in the pool after that.

We terminated our calculations after the newest spent fuel reached and exceeded I melting tem~erature of zirconium; so I would agree that ignitidn I

could occur, but I still feel, on the basis of my limited

! i i knowledge on this subject, that fires with spreading of flames 1 I woulq not occur.

I i

l I CHAIRMAN MILHOLLIN:

Perhaps I should pursue that a I

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second.

You said that zirconium, in effect I guess I interpretj what you say to mean that zirconium can melt and oxidizes without flame.

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I DR. BENJAMIN:

Yes.

CHAIRMAN MILHOLLIN:

And that you believe that.

oxidation can be propagated.

DR. BENJAMIN:

I believe that oxidation can be I

I I

I I

I I

propagated if the temperature reaches what I referred to as self-sustaining oxidation temperature.

It is a function of I I the heat.transfer and of the kinetics of the zircoloy class.

I CHAIRMAN MILHOLLIN:

I So as a product of heat transfer!

from the hotter to the cooler rods, it is your opinion that oxidation would be propagated could be propagated.

DR. BENJAMIN:

It's my opinion that that could not be ruled oue~* It is my opinion that were the geometrical I

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configuration to.remain static, that is were there to be no I

change in geometry at all in the pool, no melting of zirconium,!

no dispersal of fuel, anything of that sort, that the heat I I I i transfer would be such that a propagation would be a distinct I I

possibility, but when the Zircoloy starts to melt in the hotteslt elements of tHe spent fuel pool, the geometry changes.

First j f

of all it is predicted that Zircoloy melting will occur he*fore 1 I

all the oxidation is completed.

Now it is possible CHAIRMAN MILHOLLIN:

Excuse me, when.. : you say all the oxidation, you are referring to the rod which is melting?

DR. BENJAMIN:

YES.

Before all the zircoloy oxida-tion is completed, the zircoloy temperatures predicted to reach melting temperature and to melt.

Then what happens

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,'{Q. 1, 399 after that is really a matter of conjecture, more than a matter of scientific certitude.

The state of the art involved i I in melting of zircoloy and possible melting of U02 fuel is not well enough advanced to be able to determine a specific scenario by which the geometry changes.

I think at this point all that's possible is to perform bounding calculations on what my happen by taking bounds on the possible events that might occur during the melting of zircoloy and dispersal or possible melting of U02.

Now this is well beyond any analysis that I've done and I can't address what would happen in *that circumstance.

All I wish to point out is that the propagation of zirconium oxidation I don't think can be ruled out at this time and that I qon't think that zirconium oxidation propaga-tion can be taken either as any way certain.

CHAIRMAN MILHOLLIN:

Have you investigated the matter sufficiently to be able to say whether the ventilation of the particular p.ool would be crucial in determining the likelihood of propagation?

DR. BENJAMIN:

Yes.

The ventilation of the pool at Salem involves roughly 20,000 cubic foot per minute ventila-tion source, which is considerably higher than what for example Dr. Webb used in his calculations.

CHAIRMAN MILHOLLIN:

Excuse me.

In your report, and I guess we should identify what we mean when we say your I

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It is entitled "Spent I I I

I Fuel Heat Up Following the Loss of Water.During Storage."

Iri the report there is a mention of the typical ventilation system of, I think it is two exchanges per hour -- is that right?

DR. BENJAMIN:

Yes.

I CHAIRMAN MILHOLLIN:

I was just going to ask you if I

you could compare what.you are going to say about Salern to that.

DR. BENJAMIN:

Yes certainly.

When we were doing our analysis generically, first of all, we were not applying I

I f !

it to a specific facility,* and ther.e was an A&S standard that said that there should be at least two air changes per hour I

I of air in the building where the spent fuel pool is.

In the I case of Salem there is more than that. First*of all, the room I I

.in which the spent fuel pool is, and the amount of air avail-j able in that room i's significantly higher than* at some other I

.I PWR spent fuei facilities.

In the report* it said a typical PWR building would have the equivalent of about 36,000 cubic I feet of air.

In the case of Salem there is almost ten times I

,that much volume in the building; there is about 321,000 cubic!

I i i i

feet of open space.

r CHAIRMAN MILHOLLIN:

Would you repeat that number?

l I

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i PR.. BENJAMIN :

About 321,000 cubic feet of open

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Now the ventilation system at 20,000 cubic feet per minute I

involves on the order of about 4 air changes in that large

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CHAIRMAN MILHOLLIN:

Could you say whether in your 5

opinion the propagation of oxidation would occur at the Salem 7

. pool?

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DR. BENJAMIN:

May I finish answering your former question first of all.

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CHAIRMAN MILHOLLIN:

Excuse me, I thought you ha~

finished.

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DR. BENJAMIN:

I was thinking for a moment.

Your I

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burning, or the oxidation; and my assessment that tne ventila-1 I

tion would be sufficient to provide oxygen to the zircoloy I

I clad in order to sustain a propagation of zirconium. oxidation; I presuming that the. ventilation syst.em. is operating as designed! -

of course.

Now, would you repeat your other question.

I I CHAIRMAN MILHOLLIN:

Perhaps you've answered it.

1 My question was whether you had an opinion as to whether with I the ventilation at Salem propagation of oxidation would occur* I-i I think you just said Yes.

Perhaps I should let you verify I

n that?

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'.I DR. BENJAMIN:

I said it wotild not be*limited by the unavailability of oxygen.

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That' s rather a dif.ferent answer though, I since in your report you suggested one of the negative features!

of low bound ventilation was the fact tha the decrease in heat transfer made the material heat up more seeking a higher I

equilibrium temperature and that a shor.tening time to ignition./

DR. BENJAMIN:

Yes, well it is a double-edged sword. I If you are going to try to light a charcoal fire, for example, I we know that if charcoal hasn't reached its ignition tempera-. *II ture, blowirig on it will tend to cool it down and make it less likely to burn.

If it has reached its igrtition tempera-ture blowing on it will increase the fire, or increase the burning; so the availability of sufficient ventilation is a good way to try to prevent any of the fuel elements from I I f I I l

reaching this self-sustaining oxidation temperature. *Once it I has reached that temperature the availability of oxygen can work against you.

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Dr. Benjamin, I wonder if you could clarify--something of the difference that you see and the distinction which you are drawing.between ignition oxidation flame for burriing, from the point of view of what impact this would have on distributing radioactive materi~ls through the environment.

I believe you used the teim ignition I I 1 propagation. You also distinguished between those and flame.

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. I And what I am wondering here, is that I am not ciear on the distinction that you see between these from the point of view of the impact on distributing radioactive materials, if any.

DR. BENJAMIN:

Well, 'Dr. Webb has postulated a possible scenario in which a rapid deprivation or fire would essentialiy blow ~he roof off the buildlng because of the rapid pressure transient that would occur as a.result of that.

Basically what I am saying is that the fire, or what I term the burning, since*r*don't it's a fire as we.normally think.

of fire, would not be an*instantaneous pressure pulse but one j

i i that is spr.ead out over a long period of time and would not I

I provide nearly.enough impetus to grossly rupture the building.

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! I believe that the building, typical buildings for spent fuel I

I j storage are such that the tend to leak wh.eri pressure exceeds*

j a certain level, somewhat less than a PSI.

They don't tend

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• 1 1 to rupture unless there is a rapid pressure excursion as i ! might i

l I sort.

occur *from some kind of explosion or something of that The burning of Zi,rconium does not present that kind i of condition and I don't be'lieve that it would result in a I

' I ! failure of the building that way, that would have an effect

! l on the availability of oxygen if the ventilation system were I

I not working.

I If ventilation system were not working, then the 1

I I oxygen would not be there.

And it would have an effect on

! the possible disbursal of radioactive materials.

i I DR. LAMB:

What type of effect?

DR. BENJAMIN:

That I can't hypothesize.because that is clearly beyond any analysis I have done.

DR. LAMB:

You are saying then that this could be a longer slower process than the one which perhaps was

• suggested by Mr. Webb in his testimony.

. I I

1 I

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' i DR. BENJAMIN:

Yes, much longer.

MR. SHON:"**. In particular I think there was a figure 132 pounds per square inch or some.such that*Mr. Webb got by adding al 1 the zirconium b'-urning energy to the air in the building and you feel that it wouldn't get in fast enough to really reach that pressure.

Is that right?.

• nR. BENJAMIN:

Yes, that' s correct.

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~-3 DR. LAMB:

In pursuing the differences as in modifying, I gather from the statement that we received today from Mr. Pasedag that you have reworked your figures

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in the Sandia Report, to take into consideration closer 7

9 TO l T t2 13

to the actual situation in the Salem pool.

Is that correct?

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.DR. BENJAMIN:

I have done some addi.tional calculations very recently to account for the actual ventilation system and the actual size of the room at the Salem facility.

Here's numbers giving the minimum,decay time necessary to preclude the possibility fission product releases due to overheating is based on these revised calculations

• DR *. LAMB.:

Right now, with your revised* figures, did those figures take into* consideration differences in the i I I

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!J geometry of the pool and the arrangement of the fuel elements

• t I in the.pool-under the proposed system.

17 J;>R. BENJAMIN:

Well, I have a limited amount of ta information about the specific design details of the pool 19 or of the spent fuel racks in that pool.

I understand that it is s~milar to a spent fuel rac~ design that we used in our ll previo~s an.alysis, a high density PWR spent fuel rack design*

zz and I use that as being close enough to what-is being proposed

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! in Salem in order to make conclusions about it.

The specific i

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l I I information at all about how the spent fuel will be loaded

' I in the pool, so I assumed what would be the worst loading scenario from the point of view of heat up of the spent fuel and that it to put all the new spent fuel elements together 7

in a group and then to put the next aged ones, one year*

a greater decay time next to it and to then load the 9

successive spent fuel portions of the core into successive lO

• groupings like that.

There *could obviously be a difference in results if there was a different loading pattern than was 12 assumed.*

DR. LAMB:

As I recall in your report there was a substantial difference in the effect in arrangements in which tJ the elements were arranged wall-to-wall as opposed* to tcS arrangements in which there clear space between the elements 17 and the wall for air circulation.

TS DR. BENJAMIN:

That's correct.

19.

• DR~ LAMB:

What did you assume in your.*

calculations relative to the Salem pool?

Or do you know ll what the arrangements would be?

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I was told that there is something on IN1V1NA'l'lCl'OMo 'I_".. ~I ues. IMC.

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~-5 the order of about a foot open space betwE;:en the edge of the 2

pool and the,first row of spent fuel racks.

A foot would be more than adequate to provide down-comer space for air to

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get into the spent fuel assemblies.

That is* what I assumed.

7 10 I

I DR. BENJAMIN:

How about openings in the fuel

• racks themselves, circulation of air.

i DR. LAMB:

Recirculation?

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I l DR. BENJAMIN:

Recirculation of air up through I the racks.

DR. LAMB:

Well, I assumed similar to the previous TT analyses we did for this type of racks that there was a 12 five inch hole in the platform to allow air to come into the l~

spent fuel assemblies.*

DR. BENJAMIN:. That was the largest of the holes l.S

, that you saw in ym;i.r calculations, I believe.

I to 17 18 19 I !

20 in Salem?

21 DR. LAMB:

In the report?

DR. BENJAMIN:

Yes.

DR. LAMB:

Yes.

DR. BENJAMIN:

Is that the actual size there is MR. PASEDAG:

I believe the actual size exceeds n

the opening equivalent to a* five inch diameter *

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With respect to the change in the f amount of fuel, stored in the pool, the question which has been of sunstantial amount of concern is. the change or potential change in impact which the could have on the environment.

In*that event it becomes very important to try to determine the difference between,. *let's say the i statement that Mr. Pasadag has here and the statement of I i I

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i Mr. Webb.

From the point of view of whether or not conditions could arise in case of loss of water; which would involve fuel beyond that which would be available in the pool before i.this enlargement.

In other words the*

original configuration.

I am not sure which of you gentlemen*.to addr~ss this question to and what I would like to do is to receive some information from you if you think I you can give it to me about the difference of opinion.

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i Clearly, Mr. Webb feels that some* of the older fuel will I

! i catch and will become involved in this and Mr. Pasedag does i I L not *. I gather you are somewhere between these two positions.

Is that* cor*rect?

i ii I I i DR. BENJAMIN:.I* believe that'? an accurate assessment, I am somewhere between the two positions.

DR. LAMB:

Perhaps I* should ask Mr. Pasedag whether

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"""c:.:.'fo. _1_, _4_o_9 he could help draw the line a *little bit with what -- with why your views are let's say different from your point of.

view, what you perceive about this which is different and why you feel this would not be a problem.

MR. PASEDAG:. Okay, I'll try.

Actually the difference in opinion that we have is very narrow or a very smal.l d*if ference.

And that is concerning DR. LAMB:

Excuse me that's-:- between *your opinion 1

and Dr. Benjamin?

Not between yours and Mr. Webb?

MR. PASEDAG:

Oh, I'm sorry I misunderstood the question..Would you repeat the question you would like me to address.

DR *. LAMB:

I just wanted to make sure that you said the differences were* small and I just wanted to make certain that I understood that you were referring to differences between you and Dr. Benjamin.

MR. PASEDAG:

Correct, right.

And the only thing that I would add to what I agree with everything the Dr. Benjamin has said -

the only thing I would add to it is there a number of mitigating circumstances which Dr. Benjamin alluded to there are s.ome additional ones which believe would make a difference as well.

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from the idealistic case that we analyzed because it is simpler to analyze.

Dr. Benjamin has addressed, well he has acted as a good *consultant. He has given exact for exact questions.

We don't* expect him as a consultant to us to speculate.

So therefore he says that well as far as his exact calculations go, he has gone so far and he cannot prove by exact calculations that heat-up of the older fuel can be --.would be prevented.

He cannot prove theoretically that this would be the case.

Without the current ~tate of knowledge and the current assumptions and current models.

My statement is simply that real life is not always as you idealize it in order to do a calculation and so my statement ii based on consi~eration of people's experience in handling Zirconium* on experiments done on heating up Zirconium fuel rods, and behavior observed.there. It is based on the fact I

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would start to oxidize, that melting would occur which would draw away a good bit of the heat and so that heat would not be available for spreading to the old~r fuel elements it is based on the fact that the loading pattern is not necessarily the case all the time.

It is based on the fact that Zirconium oxide, once it does *start to oxidize, changes from a metal

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to a very refractory type substance which tends to be a good insulator and the heating of the older elements would be done primarily from the radiation from the newer elements and

.therefore the ~eating is external to the rods for the older ones and the insulatin air would reduce the amount of heat transferred.

The.oxidation may ver~.well be limited by the fusion of oxidation through Zirconium layer and so forth.

When you take all these things into account all of the things I have mentioned would tend to reduce the amount of heat transferred to the older assemblies.

When I put that together with people's experience in *handling Zirconium I conclude that chances are veryminima1*that there would be a spreading of oxidation to the old elements.

DR. LAMB:

In looking back at your statement you as were saying that--and listening to what' you said-- you I think summarized.this by saying staff was not identified incredible mechanism for propagation of Zirconium fire to four year old or older fuel.

Is 'it fair to paraphrase what you said as indicating that perhaps this. could happen but it is not credibl$ that it would happen?

MR.

~ASEDAG - That's *pretty close.

• I would add one word to the statement..And that would be that it cannot be

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I theoretically ruled out.

Based on heat transfer calculations that have been done to date alone.

But I believe I could be ruled out if we took a very careful look at all the phenomena involved which would be quite an elaborate and lengthy process.

DR. LAMB:

Di. Benjamin, do you meet with that distinction between the two positions or is there more to it than that'?

DR. BENJAMIN:

No, I think Mr. Pasedag expressed the distinction verY well.

DR. LAMB:

In other words you feel that it would be something which is possible but not credible?

DR. BENJAMIN:

That it is possible but not credible? No *r wouldn't go.so far as to say that based on again the limited number of analysis that has been done.

I what Mr. Pasedag said first of all is that there are mitigating factors that need further exploration and he believes that if these mitigating factors are explored it would prove that propogation of Zirconium oxidation would not occur beyond the first four years of elements.

I can't I. I at this time state that what he postulates is true and I I

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.l DR. LAMB:

Mr. Pasedag, one thing you had here that i I am not clear on, and I wonder if you would qualify for me.

Here at the bottom of page two of your statement 7

beginning in the.fifth line from the bot_tom, you state the thermal insulating property of the Zirconium oxide layer which would reduce heat conduction to the interior of the rocks.

Is this a matter of reducing heat conduction to the interior of the rod.that would create the problem or is it 9

a matter of decreasing the heat conduction out of the rod.

. 10 MR. PASEDAG:

Well, what I meant by that is the fact that the oxidation of Zirconium in this particular 12 environment with this geometry of the rod or tube would occur in the interior of the *rod as soon as you have an lJ.

oxide layer on the outside *. The burning would not take place t.S outside the oxide but. it would.take place on the inside of I

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oxide at the interface with the metal itself.

This is another I ti 18 19 20 ll 1 reason I believe Dr~* Benjamin has elaborated on the difference

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between a.fire and what we are lOoking at here. It is not in a fire a good bit of coIDbustion takes place external to the material itself in the flame.

This does not happen here.

The Zirconium does not vaporize.and burn outside of the rod.

It burns at the interface with the metal.

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therefore if you have a* substantial oxide layer which would be formed on the outside it would be more difficult the heat to the location of the oxidation as well as the oxygen necessary.

DR. LAMB:

You mean that there would no longer i,, be at that.stage in the fuel of that age no longer be any I

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fuel in heat being generated from within the rod..

MR. PASEDAG:

Oh, yes, There is still some heat being generated within the rod but that heat is no where near adequate t9 heat the rod to the oxidation temperatures which we are talking about.

DR. LAMB:

Is that even if the heat transfer were interrupted J:?ecause of high temperatures outside?

MR. PASEDAG:

It would have an effect the fact that you would no longer have a reduced heat sink on the outside of the rod.

The heat generation rate in the older rods I believe is lciw enough that this* would take some time before you would see that effect. **I'm afraid I can~ t put a number ori that time, but it would be ~ slow process.

DR. LAMB:

Yes.

The point I was raising of course l was the question in my mind as *to whether under the i i ' I

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t heat to initiate this reaction or whether with the heat transfer to the outside being interrupted whether the internal heat generated within the rod would accomplish the same thing without the necessity for being able to transfer to the oxide layer.

MR. PASEDAG:

It would not be able to accomplish the same thing until quite some time later because the temperature would have to be gradually raised from the inside if you took away the outside heat sink~

I guess my point is that if you were to wait fo;r that then the oxidation*

would essentially have ceased by that point if you -- during the time when we postulate the oxidation of.this rod the major heat source.is from the outside.

If you-were to take that away it would immediately start to cool down.

If you continue that, then you would continue to heat up the rod and the internal heat generated by decay would of course contribute to that.'

But I am saying that it is a small contributor.

DR. LAMB:

Do you have any troubie with that Dr. Benjamin?

DR. BENJAMIN:

I don't believe so.

DR. LAMB:

You indicate on Page 3, Mr. Pasedag

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that there would not be any additional risks to the health and safety of the public beyond i;hat identified in WASH 1400.

Looking at the risk to the public with the enlargement to pool and without the enlargement of the pool would there be and significant differenc~ under this series of circumstances.

Would there be any difference in the risk to the public.

MR. PASEDAG:

I don't believe so.

DR. LAMB:

Can you justify that position.

MR. PASEDAG:

Sure, I don't believe there would be a substantial difference for several reasons.

First of all fu.el pool accidents per se tend to be a very small contributor to the.total risk as identified in WASH 1400, negligible in fact.

By comparison with reactor accidents that is, DR. LAMB:

Excuse me, just a second please *. *rs*

that built on a foundation which assumes a very low level of *likelihood of occurrence.

MR. PASEDAG:

Yes, the likelihood of occurrence is included in the risk~ The risk-is the way I use it is i

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defined as the product of the probability and the consequences.j I

DR. LAMB' Okay,,But beginning from the point of the I Board's question* that says1 whatever that likelihood is f~~

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assuming that we are at the position where we have lost the water, at that point what, if any,. is the difference* in your view of the risk to the public.

MR. PASEDAG:

Well, you posed a question which I don't think has an answer.

If we fix the probability as one -

that is it has already occurred, then we can no longer estimate the risk because then the only thi~g that is left in the risk equation is th~ consequences.

So I assume that you are really addressing the consequences.

DR. LAMB:

That's right, I'm using the wrong word.

MR. PASEDAG:

In terms of the consequences again~

the.consequences 9f. pool accidents as analyzed in WASH 1400 would be small by comparison with the consequences of reactor accidents.

This does not include the* additional stored fuel that we are addressing here.

So if I add the

• additional stored fuel. to the equation the consequences would possibly inc"rease somewhat but.would certainly be no worse

• than a full core reactor accident as postulated in WASH 1400.

The consequences would still be within WASH 1400.

DR. LAMB:

I'm not sure that I have heard what I was looking for which is an answer to the question of 1~1'CllU&- 'IOMA"ftM RU*!Mi ua. IMC.

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I the extent to which this pool enlargement given more the Board's question was the extent to which this pool enlargement would increase those consequences.

I MR. PASEDAG:

Well, the reason that I did not r

' I l give you a very specific answer for that is that we just i

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do not have a specific answer for the consequences.of this kind of accident.

It is a Class Nine accident that the staff does not routinely analyze hence I _cannot give you a good answer based on these analyses.

I can estimate some-what what the consequences would be and based on my.

estimates I would conclude that the consequences would not exceed WASH 1400.

That is based on the fact that you would have only one-third *of a core in the spent fuel.to begin with.If you damage that one-third of a core and produce*

the release of fission products therein you would have consequences that would be let's say roughly one-third I

i.. those from a full. co"re obviously.

So the question is would I i j t he additional fuel the.older fuel, woulq it contribute to I the consequences,'and I am saying that yes it would, perhaps.

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I i 1 been clarified.

It depends. on a lot of factors that have not J

The major factor, by the way, is how did I I the water disappear.

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disappears, it may very well cool down the pool in the 2

process rather than heati~g it up as we postulated.

So l

because there is no specific question therefore there will

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be no specific answer.

But the -additional damage of older fuel I believe based oh the factors that we have discussed in the propogation of clad damage will be small. It will.not 7

be on the same order of magnitude as that produced by one-third of the core.

So therefore if I add the additional y

factors which would be less than a third-of a core to the TO first one-third whic:h we believe probably would result in ti" damage cladding, I still get less than two-thirds and t:2.

WASH 1400 is a full core.

So based on that simple comparison t.S t7 TS 19 20 21 I say that the co~sequences would not exceed WASH 1400.

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1 CHAIRMAN MILHOLLIN:

Dr. Benjamin, I would like to I

ask you a few more questions.

Probably more than a few more.

I j

In your opinion to just clarify what you said before, the I

propagation would occur by heat transfer.

By generally heating I.

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up the environment in which the oil fuel finds itself.

Is that right?

7 MR. BENJAMIN:

The propagation would occur as a

as follows:

Basically there's a potential for producing 9

more heat by zirconium reaction then that needed in order to 10 raise the temperature of the zirconium to its selfsustaining lt oxidation temperature.

For each assembly you would require 360 megajoules. to raise the temperature of the entire assembly 1~

up to 900°C which. calculations show for this particular 14 geometry would produce a self sustaining oxidation leading to l.S a temperature transient in that assembly if all the zirconium I I I

! i burns in the assembly it would produce about 1200 megajoules

18.

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which is a little more than 3 times the amount that went in.

MR. SHON:

One moment.

Was that 360 megajoules on 19 I I a adiabatic basis or was it cbunting also for all heat transfe~s 20 ll

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that occurs during that time?

situation.

I MR. BENJAMIN:

Purely an adiabatic basis.

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MR. SHON:

But that really wouldn't be the situation.i I

i MR. BENJAMIN:

No, that's right.

It wouldn't be the! I CHAIRMAN MILHOLLIN:

Go ahead.

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6-2 MR. BENJAMIN:

Okay.

So, essentially then, the only way to prevent the heat from oxidation overtaking --

that is propagating is to remove the heat by convection 7

10 12 lJ 1.S natural convection primarily from the fuel assemblies.

Now I

I I

I my assessment is that, if the zirconium oxidation were to initiate in the.,newest fuel el*ements which were not able to remove the heat fast enough that the amount of thermal I

I i

radiation that were to cause it to propagate to other fuel assemblies would be larger than that that could be removed I

I by the natural convection due to air.

CHAIRMAN MILHOLLIN:

Excuse me.

When you say that i

I are you referring to the Salem Pool.

The possibilities of I

~o:::: :::i::a: :~:::: :::::::::: at the Salem Pool or are* I I

I MR. BENJAMIN:

Well I been thinking primarily in I

lo terms of the Salem Pool.

Whether that applies to other pools 17 TS 19 21 or not, I don't know.

I can't say.

I think that in.order to prevent this from happening you have to have the zirconium melt before the reaction proceeds very far, which in fact, would occur.

The molten zirconium would have to then drip or i

I I I I otherwise transport itself down into the bottom of the pool an1 i

t I

you would have to have the U02 fuel also dislodge itself and I

I become--* and collect itself at the bottom of the pool so that I.

the heat could be transferred to the concrete at the bottom of !

,. the pool rather then to be transferred to fuel assemblies J _ --

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But I'm getting into a speculative area right now which is really beyond the analysis that I've done so far.

You i I have to bear in mind that what I'm talking about is the product I 1 of thinking that has been going on for about a week or less and/

! that the report which I wrote was a product of thinking that I

had gone on for a year and a half.

Thi~ whole areaof discussiol 1

I I ! of course is outside the domain of the report I wrote.

I I.

I I

CHAIRMAN MILHOLLIN:

The assumptions your making then!

1 are that the fuel rods would stay in the same place would a I

I I_!

lj propagation occur.

MR. BENJAMIN:

Yes.

i CHAIRMAN MILHOLLIN:

Do you think the propagation I

which you think would occur would cause the rods which are more!

than 4 years old or more to oxidize?

MR. BENJAMIN:

Do I think that it would cause it to I I I l To oxidize?

17 CHAIRMAN MILHOLLIN:

Yes.

ta MR. BENJAMIN:

well, if your asking for an opinion 19 just based on speculation still?

11 CHAIRMAN MILHOLLIN:

No, I'm asking -- You said you are confident to predict what will happen -- at least as so far as it can be predicted with the knowledge we have.

You said that you can predict relationships which are dominated the phenomenon of heat transfer and we postulated that this i *

• propagation, if it happens, will be a heat transfer reaction

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I 1 or shall I say phenomenon.

I I guess what I'm asking you is, i I I given this phenomenon a heat transfer, do you think the four year old rods would reach a temperature sufficient to oxidize?

MR. BENJAMIN:

My feeling, based on what I've done so far is that there is a great possibility for that to happen then for it not to happen.

CHAIRMAN MILHOLLIN:

If it should happen, would the I I I cladding melt.

i I I The cladding would melt, ~t least a MR. BENJAMIN:

! I portion of the cladding on the fuel assemblies would melt.

CHAIRMAN MILHOLLIN:

Would it then follow that fission products within the cladding would be released?

MR. BENJAMIN:

Within the cladding?

CHAIRMAN MILHOLLIN:

Yes.

I'm sorry, the fission products which have been heretofore shielded by the cladding I I I

I I

I I

I I

I I I

would be released?

i MR. BENJAMIN:

The fission products in*the gap betwee1 the fuel currents and the cladding would be released.

t I

CHAIRMAN MILHOLLIN:

Do you think that fuel more than!

! four years old would ignite or o~idize because of the heat it I

11' 1'

I I

contains itself?

MR. BENJAMIN:

No.. No it would not happen because i of the decay heat within the fuel element itself.

I ri CHAIRMAN MILHOLLIN:

When you.say it would in your

*response to my question, you said you thought it was more "l--- --

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l.s to 17 ta 19 21 probable that it would oxidize then that it would not.

You must be making some assumptions about convection when you answered that question.

Could you perhaps enlighten us to I I I I I what assumptions your making.

l MR. BENJAMIN:

Yes.

There's assumptions.

We find I I I l due to the cladd oxidation the efficiency for removal of heat.

1 that when the *temperature of a fuel elements gets very high I

I I ny convection within that fuel element is impaired by the high I

! temperature.

Mainly because the fact that the hi~h temperature!

I increases the viscosity of the air going through it and I

i decreases. its density.

Therefore, I've assumed that if a particular fuel element reaches a cladd oxidation temperature and then goes thr.ough a temperature excursion that brings it up to zirconium melting temperature that the effectivness of removal of heat by natural convection in that fuel element will not be there.

In that case the only ways for the fuel I I I i

I I

I I

l I I I element to have heat removed would be e,:i.ghter to radiate it to i adjacent fuel elements or to transmit it off the. top of the fuel assembly out into the open space by radiation or convection and I believe based ~n previous calculations.that I I i

I I I aren't directly applicable to this situation because -- based j i

on the calculations I did for the report that the amount of heat that can be removed by the mechanism of radiation or convection from the top of the fuel assemblies is not large I I

.

• enought to counteract the amount of heat that would be

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_.1 radiated from fuel assemble to fuel assemble down in the body 2

of the fuel element.

Again, the -- normally of course if I 6-6 were doing a technical analysis of this problem I would do

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the analysis exploring all these things for the particular case in question before writing the report about it and I'm

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being asked now to state conclusions based on incomplete 7

analysis and-I think this should be recognized.

a CHAIRMAN MILHOLLIN:

The report on Page 69 has a 9

figure of 24.

Do you have it before you?

TO MR. BENJAMIN:

Yes.

tT CHAIRMAN MILHOLLIN:

The figure has to do with 3 T'.2 year old fuel.

I assume I'm reading it correctly.

Is that 1~

right.

• I l.L MR. BENJAMIN:

Yes.

t.S CHAIRMAN MILHOLLIN:

And the dottted line represents ta the high density storage racks.

Can we assume that those are Ti reasonably simular to the ones that are proposed at Salem.

13 MR. BENJAMIN:

Yes.

!9' CHAIRMAN MILHOLLIN:

And that the whole size which lO is greater or equal to 5 is reasonably similar also?

21 MR. BENJAMIN:

Yes.

z:z MR.\\ SHON:

What about the gap at the edge of the

i*

Zl 2.!

MR.* BENJAMIN:

Yes.

CHAIRMAN MILHOLLIN:

Does this indicate that 3 year

~

. old fuel would oxidize after about 2 -- almost 3 days?

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?Q.~,"iQ. --- I MR. BENJAMIN:

This case was the case of no building I I

I ventilation whatsoever and the heat up in these curves are I

based on a complete failure of any ventilation system.

What f

happens in these cases is that oxidation begins and is snuffed I out because of the unavailability of oxygen so that it is not I a major factor in the ultimate result.

I CHAIRMAN MILHOLLIN:

What effect do think Salem

. I would!

have on this figure?

Do you think it would prevent the high density storage -- the fuel in the high density storage racks from igniting 3 year old fuel?

MR. BENJAMIN:

Yes I do.

CHAIRMAN MILHOLLIN:

So in the Salem -- with the Salem ventilation. system we would not have igni i;:ion of the 3 year old fuel~

MR. BENJAMIN:

That's correct.

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I CHAIRMAN MILHOLLIN:

Barring the heat transfer eff ectj.

MR. BENJAMIN:.

Barring the heat transfer effect?

CHAIRMAN MILHOLLIN: Yes.

MR. BENJAMIN: Which heat transfer effect are you talking about?

CHAIRMAN MILHOLLIN:

Well I assume this chart is not I

I I

I I

I 2:2 concerned with the heat transfer phenomenon that you've just described caused by the burning of the fresh fuel.

Or is that not correct?

MR.

BENJAMIN~ The -- What I'm saying is that there l~ncou<. '/-TUol.~EF:Mi Dd. 1....:,

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6-8 I I I would be no burning of fuel at all for 3 year old fuel in the Salem facility and a loss of water accident with tlb:e new high density rack configuration.

CHAIRMAN MILHOLLIN:

If all the fuel in the pool were I

! 3 years old or oider there would be no ignition.

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1 the Salem Pool no ignition would occur.

MR. BENJAMIN:

Yes.

MR. SHON:

But you did.not say that the fuel in the Salem Pool consisted of younger than 3 year old elements, some I ranging down to freshly withdrawn and material older than 3 years there would be any assurance that the older material that is older than 3 years could not ignite by propagation from ignition in the younger fuel.

Is that right?

MR. BENJAMIN:

Yes.

MR. SHON:

Thank you.

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CHAIRMAN MILHOLLIN:

Mr. Pasedag, I have a question for you.

I I i

In your further testdimony on Page 1 you refer in the j last sentence -- you say that his calculations and his refers to Dr. Benjamin MR. PASEDAG:

Correct.

CHAIRMAN MILHOLLIN:

Indicate that the decay time required to assure that the fuels decay heat generation will not result in oxidation temperatures above 900° is about 1 year.

According to what Dr. Benjamin has just to~d us he believes that fuel 4 years old or older may ignite if it is stored with fresh fuel.

Could you explain your statement here in the context of his statement?

MR. PASEDAG:

Well, I'm saying that in the absence*

of fuel any younger than i*year there is no chance that the temperatures in that pool anywhere will go above 900°C.

This is in absence of the additional energy generated by oxidation of freshly discharged fuel CHAIRMAN MILHOLLIN:

Does this conclusion assume I

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total absence of water in the pool so that the convection couldi I

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occur by air coming under the bottom of the racks?

MR. PASEDAG: Yes.

I i

CHAIRMAN MILHOLLIN:

If you assume that some water i

I I may be left in the bottom of the pool so that the air could no1 reach that area, would you still make the statement?

MR. PASEDAG:

I have to say I don't know about that 1~1"!CIU'- '1-nw RJ:IS>!AI au. IMC.

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This is a new scenario now thats postulating and I have not investigated it very carefully.

CHAIRMAN MILHOLLIN:

I didn't invent this scenario I

I I I

I took it from figure 26 I think in the report which is on Page I

77.

I MR. PASEDAG*

I didn't mean to imply that you invente, it, but I'm saying that I'm having difficulty in defining what i gross loss of water means and I think we have done given it r

a whack, so to speak, and tried to define what we thought was gross loss of water that is credible.

• 1n addition, that we have I i

considered what we think is an incredible situation, namely tha~

instantaneously there is no water in the pool whatsoever.

If those are the only two scenarios that I have examined to any*

degree of detail and I really can't speculate about other I I l I I

I I

U scenarios.

To 17 ts 19 11 CHAIRMAN MILHOLLIN:

Well, perhaps I should ask Dr. Benjamin then to respond since he's familar with the report and perhaps he could tell us whether perhaps I'm missreading figure 26.

It seems to indicate that there would be an oxidation effect for 1 year old ~uel if there were water at the bottom of the racks.

Is that correct or* is that in-

.j correct?

I I

l J I DR. BENJAMIN:

What the figure attempts to show is I

i that it's possible to block off the air inlets at the bottom i

of the pool simply by having the water covering the base

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1 1,430 and or else very close enough to them so that there is not enough space to have air come in to the bottom of the spent fuel racks and up through the fuel assembly.

If thi.s event occurs, this requires a specific water level which according to estimates implies that less than somewhere between ten to twenty percent of the fuel elements is still covered by water I

I and the water has not drained down below a small distance I

below the bottom of the fuel racks where the air inlet all.is. I I

I In that circumstance air convection is in effect because the air cannot get into the fuel assembly and has to get in through1 the top and has to go back out through the top wh~ch is in-j effective for this geometry since geometry is in one of long channels with very narrow spacings, so the fuel will tend to over-heat more readily in situation like that than it will I

i I I I

I i

in a situation wh*ere air* convection can be sustained, however, I oxidation of the client is likely--is much less -~ikely to occur because there is no way for air to get to the cladding so there is no ignition possibility in an' arrangement like this, but there is the possibility for heat up of fuel occurring and not being relieved by convection of air through the fuel assembly.

I l I

MR. LAMB:

Does that suggest that the material would I melt.

I MR. BENJAMIN:

I would presume that you are talking i i

about the Zirconiums.

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Yes.

MR. BENJAMIN:

Well, I would presume th<:Lt you would get Zirconium melting.

MR. LAMB:

Well, what would happen with Zirconium melting passing down the tube into the water at the bottom?

MR. BENJAMIN:

Well, Zirconium _interactions with water can be rather severe under some circumstances.

Now, this again is getting into an area where I have to rely on other work that is going on at Sandia Laboratories than the work that I have done myself, but I have been exp~sed.to that work in the course of my other dutires there.

Interactions I

I i I between molten material and water can under some circumstances I lead to what is called the steam explosion, but for a steam explosion to be coherent the molten material has to contact I

the water in large quantity at one time and has, to be I

seentially a situation where all the material is molten and I

stays in its geometry until such time when the whole amount of 1 I

molten material can drop in one time down into the water at the bottom of the pool that is the first consideration.

The second consideration i's that there has to be enough water there to produce a large steam transient which is called steam explosion.

I don't think that this situation is conducive to the former occurrence that is having large

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masses of molten material drop down all at one time into I believe that it would happen gradually by running down water-i INnNu.,,__ '1--nN.=lo=:Al OtS. Ii<.

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I don't think know about the amount of water down there and whether it is sufficient to have a large enough explosion to occur to make a diffe.rence.

I just haven't looked into the amount of water so I can't comment on that.

I would make one comment about Dr. Webb's testimony in this regard that I noticed and I didn't concentrate on this area as much as on some of the other areas that he postulated a twenty percent conversion factor for the efficiency of the steam explosion, twenty percent of the thermal energy of fuel--assuming fuel melts and Zirconium is converted into energy and steam explosion experiments at Sandia Laboratories indicate a maximum from the experiments that had been done there of a l~ percent conversion efficiency.

MR. SHON:

Before you leave the subject, Dr.

Benjamin, earlier site explosions with Zirconium reacting to water and there is not enough Hydrogen.

DR. BENJAMIN:

I don't believe that it can react with water that way.

It can react with steam to produce Hydrogen, of course it can't do that if it has already been oxidized by air.

In fact, the water would quench the Zirconium and if it not at the temperature where oxidation can occur then you couldn't get.that occurrence.

CHAIRMAN MILOHOLLIN:

I have one more question concerning this figure.

Could you say whether a 4 year-old fuel or older would melt if the inlets were blocked by.water l"""""'l'IQIM. 'l11111Anw.~iP!AI J:PtS. INC.

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DR. BENJAMIN:

I don't believe I can say whether it. I i

would or not.

I don't think I* performed the analysis to indi-1 I

cate whether that would occur.

CHAIRMAN MILOHOLLIN:

At this time I think it would

• I be well to end this particular day's hearings and continue with/

these witnesses tomorrow.

>.Each member of the Board has at least a few more questions for the Panel.

Are there any matters we should discuss at this time before adjourning.

MR. MACARTOR:

What time tomorrow?

I I I I

I CHAIRMAN MILOHOLLIN:

9 o'clock a convenient time.

i I

. Mr.

• Va lore.

MR. VALORE:

I was going to ask if Dr. Benjamin has available any of the calculations that he referred and if we could look at the. them overnight.

DR. BENJAMIN:

Calculations on Zirconium bU~ning specifically.

MR. VALORE:

He said their experiments indicate l~ percent.

CHAiffiJl..AN MILOHOLLIN:

Are you referring to the calculations on Page 1 of the testimony by any chance.

MR. VALORE:

Yes, any calculations would be fine.

MR. SHON:

It was my understanding that the l~

percent verses 20 figure for the conversion of E energy to mechanical energy was not a calculation but a experimental result.

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Yes.

CHAIRMAN MILOHOLLIN:

Well, any case your question is whether any calculations are available.

MR. VALORE:

That's right.

DR. BENJAMIN:

No.

MR. VALOHE:

Is the experiment that you referred to available.

I mean typed up and do you have an extra copy of this in your possession.

DR. BENJAMIN:

Well--

MR. VALORE:

It might save me some time.is why I am asking you know if I could look it over.

DR. BENJAMIN:

Well, I don't have any results of steam explosions with me.

MR. VALORE:

I don't--

CHAIRMAN MILOHOLLIN:

Very well, at this time we will adjourn until 9 o'clock tomorrow morning.

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