ML19029A753
| ML19029A753 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/01/1979 |
| From: | Onsdorff K, Van Ness S The Public Advocate |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML19029A753 (27) | |
Text
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.e UNITED STATES OF Al'1ERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Llcensing Board L"'i. the :Matter of PUBLIC SERVICE ELECTRIC
& GAS CO.
(Salem Nuclear Generating Station, Unit #1)
MOTION FOR RECDNSIDERATION OF DISMISSAL OF
- COcket No. 50-272 Proposed Issuance of Amendment to Facility Operating License No. DPR-70
- COLEMANS' CONTENTION NO. 1HIR1EEN KEI'IH A. ONSIDRFF ASSISTANT DEPlITY PUBLIC ADVQGATE Cb the Brief STANLEY C.
VAJ.~ NESS PUBLIC ADVOQ\\TE OF NEW. JERSEY DEPAR'IHENT OF TIIE PUBLIC.ADVOCA'IE DIVISION OF PUBLIC Th"TEREST /illVOCAC":i.
POST OFFICE BOX 141 520 FAST STATE STREET TBENTON, NEW JERSEY
MOTION Pursuant to 10 CFR S 2. 730, Intervenors, Colemans, hereby m::>ve for an Order reopening consideration of their Contention Number 'Thirteen in order to compel the licensee, Public Service Electric and Gas Company, to irnplem::nt a viable alternative to reracldng the Salem Unit One spent fuel pool i;;vhich may well result in radiation exposures being kept ':'as low as is reasonable achievable,"
10 CFR S 20.1.
This alternative to reracking the Salem Che pool entails transshiprrent to spent fuel from Salem One to the expanded pool at Salem Unit ']1X) until off-site, AFR storage becomes available in the 1983-1988 period.
In support of this IDJtion, :intervenors shall rely upon the attached brief, exhibits and test:i.m:Jny of the parties hereto at the hearing held on July 11, 197
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- /
l KEITH A. ONSOORFF
.ASSISTANT DEPU'IY PUBLIC.ADVOCA'IE i
STATEMENT IN SUPPORT OF MOTION By Order dated April 30, 1979, this Atomic Safety and Licensing Board dismissed the Colerr.an 's Contention Number 1hirteen, which reads as follows :
"The licensee has failed to give adequate consideration to the cumulative impacts of expanding spent fuel storage at Salem Nuclear Generating Station "Lhlt 1 in association with the recently filed proposed amendrrent to the application for an operating license at the sister unit, Salem Unit 2.
(See.Airendment No. 42, Docket No. 50-311, filed April 12, 1978 which proposes n:odifications of spent fuel storage which.the intervenor believes are similar in scope to the Salem Unit 1 application. ).
For example, the license assumes an increase in releases of Kr-85 by
. a factor of 4. 5--due to the factor of 4. 5 increase in spent fuel (licensee's application, at 10). A similar increase, absent exceptional controls, can be expected at Salem No. 2, resulting in a cumulative increase in Kr-85 emissions by a factor of 9--aln:ost a full order of magnitude increase.
(If similar spent fuel increases are postulated for the companion uni ts, Hope Creek 1 and 2, now under construction, the Cl.J!IIl.llative increase could rise by a factor of 18, or aJ.rrost two full orders of magnitude.)"
In support of its rootion for surrnary disposition of this contention, the licensee arguE:d:
1hus, even _considering the curnW.ative radioactive released from Salem Units 1 and 2, the offsite doses attributable to fuel pool
- expansion are insignificant... lJltima.tely, compliance with each facility's technical specifications i;vhich :implements the require-ments of 10 CFR Part 50, Appendix 1 assures that the total releases from that facility, including those associated *with the increased storage in the spent fuel pool, are in the "as low as reasonable achievable range (Douglas, Par. 13). " PSE.&G Co. Br26-l to 22.
The Colemans sought to dispute PSF.&G' s narrow view of its obligations under 10 CFR PART 50, Appendix 1, and 10 CFR S 20.1 by asserting that the actions taken at each plant (Salem Cne and Two) had to be considered together for their cumulative :impact.
At page eight of their brief in opposition to Public Services IDJtion for surnnary disposition, intervenors stated:
11'This rule, (10 CFR S 20.1) then, clearly obligates the licensee to make every reasonable effort to maintain radiation exposures as low as is reasonably achievable in making all decisions on plant operational m::xies and not rr.erely reliance upon the existing containm=nt mechani&nS once it has drastically increased the radiation load in the spent fuel pool.
Having made a decision to increase the lic's sure to radiation, Public Service is under an firma.tive du to estab ish the reasonableness o this action in li t o ternatives that would not entail such increased exposure.
not y implementing additional containment rr.easures, the licensee Im.lSt seek to achieve this standard b ado tin alternatives to the ro osed action which do not re t in increase radiatibn sure.
Fmp is a ded, ootnote omitte Co ernans Br -3 to Br9-l to 6.
The Board's.April 1979 Order dismissing this Contention. while concurring in the licensee's view that "compliance with the existing technical specifications at each qalem unit will assure that the total release from the spent fuel pools *will be 'as low as reasonably achievable' 11 did not address the issue of alternatives to these two pool expansions which would result in less overall radiation exposure.
Board Order;.April 30, 1979~ p. 13.
Despite this unfavorable ruling, it became quite apparent during the July 11, 1979 hearing that the Board was in substantial agreement *with the Colernans' interpretation of the licensee's obligations under 10 CFR Part 50.
Appendix 1 and 10 CFR 20.1.
See Transcript ps. 1136 to 1152. Unfortunately, the fact that this issue was aired in what arrounted to an unannounced Board inquiry resulted in responses by the NRC sta£f typified by their imprecision and generally speculative nature:
WITNESS ZECH:
'The actual exposures, I believe, that you would expect near a shipping cask are on the order of a very few millirem.
"Now, the actual rrovernent of the fuel in getting it into the cask and then getting it from the cask back into the fuel pool are little bit nnre, perhaps than what you would get in the actual rrovement.
I think -- just my estimate -- it would nnre than likely be less than "What the exposures are that we refer to here for actual doing a m::>d-
---~-----
ification with fuel in the pool.-"~'"' Tr. 1141-21 to Tr. 1142.,-5.
Not surprisingly, the rrost definitive testi.mJny proffered on this point was provided by Mc. Wetterhahn, counsel for PSE&G Co., in describing the maxim.Im number of fuel transfers that could be anticipated from Unit One to Unit Two, if an AFR does not becorre available during the entire decade of the 1980s.
TR.1151-21 to 22. --!d:- Therefore, a ID:Jre accurate comparision of these alternatives, in order to determine which will maintain lower radiation. exposures, requires an analysis of the manrem exposure from transshipments from Unit One to Unit Two terminating approximately 1985 or 1986, to allow several years of slippage in the present IX)E schedule for AFR imple:rrentatiort.
- Significantly, Mc. Zech' s unrehearsed testim:my while not a definite exposition actually confirms Colernans' position that utilization of the reracked pool as Unit 'IWo for both Salem plants will comply with the NRC requirements for maintaining radiation levels as low as reasonably achieveable.
Consideration of these factual matters may only be accomplished :in a meaningful fashion which will have legal significance.
in the context of the Colemans' Contention Thirteen, :in conjunction with the Lower Alloways Creek Contention pertaining to alternatives. Unless PSE&G Co. is mandated to evaluate whether use of reracked Unit 'IWo exclusively mai:itains radiation exposures as low as is reasonably achievable, the consideration of alternatives to reracking Unit One is deemed by the NRC staff as completely unnecessary.
Tr. 1136-12; Tr. 1139-15; Tr. 1147-9. This posture renders the alternatives section of the staff EIA a veritable sham.
Of course, in this regard the uncontroverted test:im:Jny in the instant proceeding asserts that such a DOE sponsored facility will be available in the time frame of 1983-1984.
Tr.1009-25 to Tr. 1010-5; Tr. 1040-15 to 24.
Additionally, the necessity for reopening Colernans' Contention Number
'Thirteen is reinforced by the new infoTillation of major significance first brought to the attention of the parties and Board by letter of ColIDSel for PSE.&G Co. dated July 5, 1979.* (Copy attached hereto as Exhibit A)
In this missive, Counsel represented that the revised projection for spent fuel generation at both Salem Units *would be 56 assemblies per year. Earlier estimates were for 64 assemblies to be rerroved annually.
Tr.
1108-11 to 16. After some small difficulty in ascertaining the reason for PSE&G's*downward estimate for fuel consumption, it became apparent that the original figure was premised upon a capacity factor of 80% for plant useage, estimated before Salem 1 opened, and the new one is based upon a lower estimated factor of 71%, given the operating experience since June of 1977.
Tr. 1114-9 to 16.
V.rr. Krishna's testim:my indicated that while lower capacity factor results in extending the life of the fuel, PSF.&G Co. had decid!;:d to reduce the fuel's enrichment, apparently to maintain an armual refueling outage schedule. Tr.
1108-21 to Tr. 1111-20.
Intervenors Coleman believe, however, even with this uranium enrichrrent a still lower
- reduction, a substantial probablility exists that/the rate of fuel burn.up will significantly extend the i1.:el cycle at Salem One, due to ach:i..evem2Ilts oi capacity factor Tin..lch lower than 71%.
To date this nuclear generating facility has achieved a capacity factor of only 51.4% as reported in NUREG 0020, Vol. 3, No. 4 April 1979,
/Salem Operating Units(One's rrost recent status report attached hereto as Exhibit B.).
Also, noteworthy is the projected shutdown schedule reported in this April 1979 Gray
'This correspondence was received by Intervenors on July 9, 1979, one day prior to the resumption of the hearings, thereby severely limiting the opportunity for preparation of relevant evidence raised by this major adjustment in the licensee's fuel useage plans. Ho:vever, now having had sufficient time to adequately review and consider this development, intervenors believe that a further revision of PSE.&G Co. fuel useage plans may well extend the life of the Salem One sfp. for several rrore years thereby completely obviating the need for transshiprnents to Unit Two.
This alternative unquestionally would rraintain exposures as low as reasonable achievable by eliminating both the need for reracking the contaminated Salem Che spf. and shiprrents of fuel to Unit Two.
Book for Salem One: 4/3/79-6/27/79. While the outage began as planned, startup has been delayed indefinitely due to a series of equipment problems.
Any suggestion that this 51.4% capacity factor resulted entirely from the plant's initial shakedown period is also.refuted by the Gray Book data pertaining to very similar pressurized water reactors having TinJch longer operating experiences:
DATA AS OF 3-31-79-i' ClJlvllJLATIVE REA.CIDR DATE OF DA'IE OF PLANT YEARS OF PlAl\\lT PWR CRITICALI'IT CCM1. OP.
CAPACI'IY DER EXPERirnCE Surry :/}l 822 Mgwt 7-1-72 12-22-72 58.l 6.74 Surry :/}2 822 Mgwt 3-7-73 5-1-73 57.6 6.06 Trojan 1130 Hgwt 12-15-75 5-20-76 47.0 3.27 Beaver 852 Mgwt 5-10-76 9-1-76 39.1 2.79 Valley Unit :/fl Salem :/}l 1090 Mgwt 12-11-76 6-30-77 51.4 2.26 Farley 829 Mgwt 9-9-79 12-1-77 76.4 1.62
(',ook :/}2 1100 }boWt 3-10-78 7-1-78 73.3 1.02 402.9 23.76 57.6%
3.39 Av.
Av.
All data excepted directly from NUREG-0020, Vol. 3, No. 4, April 1979.
As can be readily seen from this Gray Book data, PWR' s having an average of 3.39 years of operating experience have averaged only 57.6% capacity factor.
Thus, it may be anticipated that eve.."'! if Salem One improved its capacity factor up to industry average, it will still fall about 12% short of the 71% needed to burn.up sufficient fuel to allow for annual refueling. This leads to the conclusion that the Salem One spent fuel pool may not be filled until 1984 or 1985, allowing the next off-load to be shipped to an A.FR in 1986 or 1987.
This no rerack alternative should be explored nnre fully, however, in the context of Colernans' Contention Thirteen, especially in view of the new information raised for the first tine by PSE&G Co. by its letter to the Board members on July 5, 1979.
Consequently, we believe that a complete record on this issue can only be made, consonant with due process, on notice to all parties and opportunity for fuller.
preparation of all relevant data ~vhich bears upon this crucial health question.
It should be noted that as the record now stands the NRC staff *will be providing the following data to the parties and Board, not as direct test:im::my but rather as written corrrnunications with no opportunity proviced either for rebuttal or cross-examination:
(1)
"How much exposure is involved for a single unit of a fuel cask being trans£ erred, Tr. 1141-13 to 15.
(2)
Total occupational exposure for transferring fuel from Unit 1 to Unit 2 until it is full from serving needs of both plants.
Tr.1149-11 to Tr.1150-12.
(3)
Total man.rem exposure recorded at the recent reracking of the contaminated SFP at the Peach Bottom Nuclear Generating Station.
Tr.1157-19 to Tr.1158-5.
If, however, the Board determines that no additional hearings will be scheduled on this issue, than the record should not be expanded in an e~ parte manner by further NRC staff subrnittals. Rather it should be closed with Mr. Zech's testim:my standing alone that the transshiprrent to Salem Two "Will result in less radiation exposure than reracking Salem One.
If no opportunity "Will be provided for Intervenors to test the credibility of new evidence brought to bear on this issue, the record should remain as produced during the hearing July 11, 1979, wherein all evidential procedures were applied to the parties on an equal basis.
e e
CONCLUSION For all the foregoing reasons, it is respectfully urged that the Board should Order the reopening of Colema:ns' Contention l\\turnber 1hirteen.
Respectfully su.brnitted,
. -. '.* /.
1--
- KEI'IH A. ONSOORFF ASSISTANT DEPlJI'Y PUBLIC ADVOCATE L.~W OFFICES CoxxER. ~ooRE & CoREER 7ROY B. cox~* Es. JR.
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~OBEn'r J. CORBE~
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'\\\\-_-\\.S HIXGTOX. D. C. 20006 July 5, 1979 DO'S'A.LD J. BAL~LEY. JR.
ROBZilT :-<. :!l..'CDZR KEITH H. EL"-IS
~OT _a.D:-f:ITT.:!::> :s 0* C.
Gary L. Milhollin, Esq.
Chairman, Atomic Safety and Licensing Board.
1815 Jefferson Street Madison, Wisconsin 53711
~r. James C. Lamb, III l*1ember, Atomic Safety and Licensing Board Panel 313 Woodhaven Road Chapel Hill, N. C.
27514 Mr. Frederick J. Shon Member, Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Corrnnission Washington, D. C.
20555 In the Matter of Public Service Electric and Gas Company, et al.
(Salem Nuclear Generating Station, Unit 1)
Docket No. 50-272 Gentlemen:
To update information previously given the Board a~d parties, the Licensee has revised its schedule for discharge of fuel from the Salem reactors.
As discuss~d during the last session of the hearing,
~ne nu~ber of asserilblies discharged from Unit 1 during the first cycle was 40.
It is planned to discharge a total of 52 assemblies during the second cycle, with 56 to be dis-charged during subsequent cycles.
Based upon this schedule, the Salem Unit 1 spent fuel pool will be essentially =ull after the refueling in 1983 i~stead of 1982.
For Unit 2, the planned number of asse2~lies to be discharsed during the first cycle will be 52, with 56 being discharged in subse-quent cycles.
The first discharge will occur in 1981.
The Licensee would ex?ect to provide this information for the record during the course of the upcoming hearins.
Sincerely,
$foi}tf!JJjj~,-
Mark J. Wetterhahn Counsel for Licensee EXHIBIT A
Gary L. Milhollin, Esq.
Dr. James C. Lamb, III Mr. Frederick J. Shon July 5, 1979 Page 2 cc:
Chairman, Atomic Safety and Licensing Appeal Board Panel Chairman, Atomic Safety and Licensing Board Panel Barry Smith, Esq.
Richard Hluchan, Esq.
Richard Fryling, Jr., Esq.
Keith Onsdorff, Esq.
Sandra T. Ayres, Esq.
Mr. Alfred C. Coleman, Jr.
Mrs. Eleanor G. Coleman Carl Valore, Jr., Esq.
Off ice of the Secretary June D. MacArtor, Esq.
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UNITED STATES OF.Ai\\fERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of PUBLIC SERVICE ELECTRIC & GAS CO.
(Salem Nuclear Generating Station, Unit #1)
Docket No. 50-272 Proposed Issuance of.Amendment to Facility Operating License No. DPR-70
~ION TO REOP.Ei'l COLEMAN' S CONTENTIQ'lS TWO AND SIX FOR RECEIPT OF NEWLY DISCOVERED EVIDENCE KEITH A. ONSOORFF ASSISTAi'iT DEPUTY PUBLIC ADVOCATE On the Brief STANLEY c. vm NESS PUBLIC ADVOCATE OF NEN JERSEY DEPARTME:t\\ff OF THE PUBLIC.i\\.DVOCATE DIVISION OF PUBLIC INTERESf ADVOC.A..CT POST OFFICE BOX 141 520 EAST STATE STREET TRINI'ON, NB\\f JERSEY 08625
MOTION Pursuant to 10 CFR §2. 730, Intervenors, Coleman, hereby move for an Order reopening consideration of their Contentions Numbers Two and Six for the limited purpose of including in the instant record the NRC inspection report dated April 10, 1979, pertaining to the partially un-satisfactory results of venting of the Monticello Nuclear Generating Station spent fuel pool racks, attached hereto as Exhibit A.
In support of the within motion, Intervenors shall rely upon the attached brief, exhibit and testimony of the parties hereto at the hearing held on May 3, 1979.
/'.-
KEITII A. ONSDORFF
-~
ASSISTANT DEPUTY PUBLIC ADVOCATE
STATB18{T IN SUPPORT OF f.illION Considerable time and attention in these proceedings has been devoted to the high density spent fuel pool racks recently installed at the Monticello Nuclear Generating Station, owned and operated by the No~thern States Power Company in Minneapolis, Minnesota.
Due to the numerous similarities between the new racks at :Monticello and those proposed for use at Salem, the experiences at this Northern States' plant.are understandably deemed pertinent to what can be reasonably anticipated at this Public Service plant, if reracked. Tr.544-1 to 547-9 to 16. Of particular :importance is the continued serviceability of vented cells for storage of fuel since the sole reason for installation of new racks is to increase the pool's storage capacity. Any substantial loss in cell availability will likewise substantially undenn.ine the justification for this license amendment.
It therefore becomes highly relevant to obtain the fullest record possib2.e on this issue which is crucial to the very efficacy of applicant's proposal.
This is especially so in light of the apparently incorrect assertion by Exxon's nuclear expert, Mr. Eckhart, that the Monticello cells were used to store spent fuel after venting. Tr.708-20 to 21.
The document which Intervenors are submitting herewith indicates that the Nuclear Regulatory Commission has recently inspected this Northern State's plant and determined that several vented cells did not successfully accept a test gauge for installa-tion of fuel assemblies. 1his loss of serviceability of vented cells may not in and of itself present a safety concern, if the cells are eliminated_
from use.
It does, however, present one more unknown factor undercutting the confidence with which it can be concluded that reracking Salem One's spent fuel pool is the most prudent course of action to extend this facility's life span until away from reactor storage becomes available in the mid 1980's.
CONCLUSION For all the foregoing reasons, it is respectfully submitted that Exhibit A, attached hereto, should be admitted as direct evidence on behalf of Colemans' Contentions Two and Six.
DATED:
August 1, 1979 Respectfully submitted,
/:
-.. ". /
/ - :. ___.. _.. 1,~.1:*,_.*: >*1 -:
KEITII A. ONSDORFF ASSISTAi~'T DEPUTY PUBLIC ADVOCATE Docket No. 50-263 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION Ill 799.ROOSE v E 1.. T RO-'.D CLEI'; ELLYN ILL*NO*S 601)7 A?R 1 0 197~
Northern States Power Company ATTI\\:
Mr. Leo ~achter
\\'ice President Power Production and System Operation 414 Nicollet Hall Minneapolis, M}:
55401
- entle::-,en:
This refers to the inspection conducted by ~essrs. T. L. Ear;s::~~.
J. L
~:e:::-:ing anc G. C. \\\\right of this office on ~~arch 19-:3, is.:-;,
of acti~i:ies at ~=~:icello ~uclear Generating Pla~t aut~~r~ze~ ~?
NRC Operatin~ License ~o. DPR-22 an~ to the discussio~ c! C~7 !~~~~~~s
~ith ~r~ Eliason an~ others o! your sta!f at the conclus!o~ =! :~e inspectio:-:.
The enclosed CO?Y of our inspectio~ re?~rt identifies areas exa~ined during the inspection.
~ithin these areas, the inspE**ion ~onsisted of a selective exa:ination of proce~~re~
anc r~;resentative records, observations, an~ intervie~s ~it~
personnel.
No ite~s of nonco~pl:ance ~ith ~RC require~ents ~ere ice~tifie~
during the course of this inspection.
In accordance -.dth Section 2. 790 of the ?-~RC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of ct~~ letter a~c the enclosed inspection report ~il!
be placec in the ~RC's Pu~lic D0cunent Roo~, except as fcllo~s.
If this report contains inf on::ation that you or yo~r cor.tractc7s belie*,:~ to be proprietary, you must apply in wri tin!; to t:iis office, ~ithin twenty days of your receipt of this letter> tc withhold such information from public disclosure.
The application must include a full statement of the reasons fo~
which the information is considered proprietary, and shoulc be prepared so that proprietary inf orrnation identified in the application is contained in an enclosure to the application.
EXHIBIT A
Northern States Power Company 2 -
APR l 0 1979 We will gladly discuss any questions you have concerning this inspection.
Enclosure:
IE Inspectio~
Report No: 50-263/79-02 cc '-'/e:l.:l:
Mr. L. R. Eliason, Plant Manager Joh~ ~. Ferna~, Ph.D.
!\\uc lear Engineer,. ~:PCA Cer.!ral Files Re?rocuction rnit ~RC*20~
PD?;
Local PDi\\.
!IC Anthony Roisman, Esq.,_
Attorney Sincerely, Heishl:ian, Chief Reactor Operations anc Nuclear Support Branch
- ~::::
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U.S. NUCLEAR REGlTLATORY CO~C1ISSIO~~
OFFICE O? H~SPECTION AXD EX?O:<.C~NT REGION III Report No. 50-263/79-02 Docket No. 50-263 Licensee:
Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 License No. DPR-22 Facility Name:
Monticello Nuclear Generating Plant Inspection At:
Monticello site, Monticello, ~
Inspection Conducted:
~23, 1979
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Inspectors:
T. L. Harp ter
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G. Wright
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Approved By:.. R. F. ~favnick, ~hief r+*Reactor Projects Section 2 Inspection Summarv Tl.*
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I Inspection on March 19-23, 1979 (Report No. 50-263/79-02)
Areas Insoected:
Routine, unannounced ins?ection of design changes and modifications; design change and modification progran; review of plant operations; cleanliness; follow*up on license 2.!!l.endment conditions; and followup of Bulletins, Circulars ancl LER's.
This inspection involved approxbately 85 inspect.or ::..anhours on site by three NRC inspectors.
Results:
No items of noncompliance or deviations were identified in any of the areas inspected.
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- 1.
DETAILS Personnel Contacted
- L. Eliason, Plant Manager M. Clarity, Plant Superintendent, Engineering and Radiation Protection
- W. Anderson, Plant Superintendent, O?erations and Maintenance D. Anthony, Superintendent, Operations Engineering
- W. Shamla, Superintendent, Technical Engineering R. Fey, Superintendent, Radiation Protection R. Scheinost, Senior Quality Engineer E.* Earney, Training Supervisor D. Nevinski, Senior Nuclear Engineer A. Myrabo, Assistant Nuclear Engineer L. Nolan, Chemical Engineer
- 0. Iverson, Associate Production Engineer R. Goranson, Assitant Production En~ineer G. Smith, Assistant Production Engineer S. Shurts, Engineer P. Tobin, Engineer S. Hammer, Engineer T. Overlid, Engineer D. Pedersen, Engineer R. Nelson, Quality Engineer, Corpo~ate
- Denotes those attending the exit inte~vie~.
- 2.
Inoffice Review of Licensee Event Renorts The inspector conducted a review within the regional office of selected licensee event reports to ascertain whether additional reactive inspection effort or other response was warranted;
~hether corrective action discussed in the event reports ap?eared appropriate; and whether reporting require.!!lents ~ere satisfied.
The following events are considered closed as a result of the review:
M-R0-78-18 H-R0-78-21 M-R0-78-22 M-R0-78-27 M-R0-78-28 M-R0-79-01 No items of noncompliance or deviations were identified.
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- 3.
Onsite Licens~e Event F:~ ~-} c:.,~.~2
- 4.
The insp;:;c tor con::h.:c ted 2 f c ~-~-~-,;;_:'.)
- _:-,s~:<:-:c tion of s2lected e:Vents to ascertai~ ~hcthcr th2 ~~c~~s~e's revlew, corrective action and reports of the ident~~i2d events and associated conditions are adequa.te and in conf ::-:-~a::ice ;d :h regulatory requirements, technical specifications, a~d licensee procedures and controls.
The following events are considered closed as a result of this inspection:
M-R0-78-15 M-R0-78-19 M-R0-78-20 M-R0-78-23 H-R0-78-24 M-R0-78-25 M-R0-78-26 M-RO-7 3_,29 M-R0-78-30 No items of noncompliance or deviations ~ere identified.
IE Bulletin Follow"UO The inspector verified that *for the following IE Bulletins~
the bulletins and responses were reviewed by appropriate onsite management representatives; information discussed in the replies was accurate; any corrective actions taken were effected as described in the replies; and the replies were prompt and -within
~he time periods requested.
I The following Bulletins are considered closed as a result of this inspectio~:
IEB 78-09 IEB 78-14 No items of *~oncompliance or deviations ~ere identified.
- 5.
IE Circular Follow-UP The inspector-verified that the following IE Circulars were re~
ceived by licensee management; a review for applicability was performed; and for circulars applicable to the facility~ action taken or planned is appropriate.
- The following Circular is considered closed as a result of this inspection:
IEC 78-16
.Nq items of noncompliance or deviations were identifiedo 3 -
- 6.
Desi£::1. Changes and ~-fodifications Progra.n.
Tne inspector revie*,.,'ed the licensee-' s design change and modi-fication progra~ to ascertain whether the progr~~ is in con-_
f orrnance with regulatory requirements, cou:::iicments in t:he application and industry guides or standards.
As part of this review, the.inspector reviewed the following procedures:
1 ACD 3.3 (Rev. 3, 10/12/~7)
Design Change Control 3 ACD 4.1 (Rev. 5, 12/8/78)
Design Change Control 3 ACD 4.2 (Rev 3, 11/4/77)
Design Change Installation Procedure 3 ACD 4.3 (Rev. 3, 11/4/77)
Design Change Preoperational/
Operational Testing 3 ACD 5.3 (Rev. 4, 11/6/78)
Drawing Control 3 AWI 4.1.l (Rev. 1, '3/25/75)
Safety Evaluations 3 AWI 5.3.4 (Rev. 3, 11/6/78)
Drawing Revisions I
3 AWI 5.3.4 (Rev. 2, 11/6/78)
Ne~ Dra'Wings 3 }J.f.[ 5.3.6 (Rev.
l~ 11/6/78)
Drawing Deletions 4 ACD 3.11 (Rev. 4> 8/12/78)_
Procedure Review and Approval 4 ACD 3.10 (Rev. 2, 3/8/77)
Document Control 4 ACD q.8 (Rev. 5, 3/18/l7)
Bypass Control Docui!lent Control Procedu=e IX-I (Rev. 0, 12/30/77) 1 Plant Controlled Dra~ing :iles Docuaent Co~trol Procedure I-3 (Rev. l 11/10/76) Blank Forrr.s and Procedures Prir.ting>
Distribution and Control No items of noncompliance or deviations '"1ere identified.
- 7.
Design, Design Changes, and Modifications The inspector reviewed the documentation for selected design changes to ascertain ~hether the changes were oade in accordance with the Technical Specifications and 10 CFR 50.59.
The inspector initially reviewed the licensee's annu~l report of changes, tests, and experiments which ~ere carried out pursuant to 10 CFR 50.59 in 1978.
The following three activities..,.ere then selected for detailed review:.
- a.
ATWS Hod if ica tion.
Design Change lfo. 772024.
- b.
Core Spray Isolation Valve Bypass Switch.
Design Change No. 78 H075.
- c.
Increase Allowable Number of Reactor Vessel Startup/Shutdown Cycles to 208.
Safety Review Item No. 181.
In conducting the design change reviews, the inspector noted that design change packages for the f ollovri.ng four cor::ipleted activities were not closed out and available in the plant files:
- a.
Lo~d Mitigating Spargers.
Design Change No. 78 H012.
- b.
Shorten Torus Vent Header Downcomers.
Design Change No.
78 M014.
- c.
Installation of Torus Vent Header Deflector.
Design Change No. 78 H015.
- d.
Design Change No. 782028.
Investigation revealed that these design changes were under the cognizance of the licensee's Plant Engineering and Construction Department and that related installation ~ork was ?erf orned during the most recent refueling outage.
Failure to have these four desig4 packages closed out at the ti~e of this inspection appeared to be in violation of the licensee's procedure 3 ACD 4.1 (Rev. 5, 12/8/78)~
Design Change Control, ~hich requires that design changes be closed out three months after installation.
This inconsistency i;;as sub-sequently discussed with the Plant Superintendent Engineeri~g and Radiation Protection ~ho related that a significant back log of open design change packages existed.
Since the.revision to 3 ACD 41. ~hich established the three-'Clonth close out requirement was fairly recent (12/78), the inspector <lid not consider the failure to have these four design packages closed out to be an item of noncompliance.
However, the inspector did encourage the licensee representative to institute the controls ~ecessary to ensure the tiJ;?ely close out of design change packages.
The inspec-tors' s concerns in this area ~ere reiterated during the exit interview.
No items of noncompliance or deviations were identified.
- 8.
License Amend!!lents Nos. 34, 35 and 36 The inspector revie~ed the impleoentation of license a!:lendments 34, 35 and 36 to verify compliance with cor:::mitments oade therein.
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Amendment 34; High Densitv Fuel Storage System (HD?SS)
The inspector reviewed procurement documents, receiving ins?ection reports, installation procedures, special test procedure anc modi-fication procedure for the four High Density Fuel Storage RacY.~
now installed to. verify compliance with cotl'lmi tments made in.thE-license amendment.
The revie\\.' of the procurement documents verified that; a??ropriate-product quality certification documents frorr. the designer /vendor were available; analysis of the boral sheets used in the fuel racks were available; and that certificates of compliance fro:
tqe assembler were available.
Receiving inpsection reports including; inspection for clea~liness, dimensional checks and confirmation of poison plate instal~atio~ :?
neutron source/detection were revie~ec for co~pleteness ar.=
conformity with cormnitments.
The follo~ing procedures were reviewed for.each of the !o~r modules installed.
- a.
HDFSS
- b.
HDFSS
- c.
HDFSS
- d.
HDFSS
- e.
HDFSS
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Hn::ss
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HDFSS Module Inspeccio~ a~~ Preparatio~ Proce~~re Boral !est Equipment Setup Procedure Module Boral verif icacicn Proce~ure Drilling and Re-sizing Procedure Module Installation Procedure Xodule Re-installation Procedure Module tnloading Procedure Dimensional checks, ~ith a 5.960" go/no-g~ gauge, afte:- ir:!::ic::
installation revealed that 11 of the 676 fuel stora~e loca:ic~~
would not accept the gauge and that tv~ of th~ 11 locatio~~ -w~~:=
not accept a dum;:-\\" fuel element.
After removal of the modules, drilling of 3/lf"' holes i:. t~c? t::-;-
adjacent corners of each boral tube, re-sizing of eact tube ~y vacuum and mechanical means, and re-installation of the mo~~le~
into the fuel pool, six of the original 11 tube location~ v~~:~
still not accept the S. 690" gauge ho-weve!', all locations n:-.....
- accepted the dut:r.\\" fuel element.
The. licensee instituted a special test prograr.: to test each bora:
tube, in each module, after 60 days and again after 90 days prior to storing fuel iD the modules.
The results of the 60 da\\" tes:
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revealed that ~e~en of the original 11 locations would not acce~t the go/no-go gauge and the results of the 90 dav test reveale::
that eigh_~£.!:_:...!_h~ orig}nal_J_!__~-o~ions would not.eccep~_p*.c go/no-go gauge.
In all cases the dumr.iy fuel element could h(*
inserted with no proble~.
The license ~-U.I_~~~~tjy Eori~g_fue_l in both boral tubes a:-.::
~~_j~-c~~-a_c::~s_"'!~.!J:_t_b~-e~~~...£~ion. o_f the_ ~_i_gh~-.!~-~~~~.?.!\\.? _
_j._~e~
tified during the 90 daY test.
These eight locations ha\\'e t~(*:
"Red-f l~gged-a~dt~i~~-~s-ee stated they would not be use.:
unless absolutely necessary.
At the time of the inspection the test specimens, both stainless steel boral and boral alone configurations, had not been installec~
The material certifications had just been received and pla~F tc install the specimens are in progress.
In addition the inspector reviewed the Safety Evaluatio:: Re?~:-:
pertainin~ to the Hig~ Density Fuel Storage Syste:.
Ko ite=s of noncornplia:-:.ce or deviations \\.:ere ide~:ifie~.
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Re\\'ie~ of Plane Ope~a:ic:is The inspector concuctec a re\\*ie.... - of pla::t ope'!"atio:is tC' as.:e::-:a:-.
whether facility opera-::io:: \\.:as i:-:. con:orr..a:ice 1.."itJ-:.
tec~:;ica~ s?e.:i-fiactions, res~latorv req~:-e~e~:s, ad=iniscracive proced~res. c::-
ocher co~~it~encs.
The inspector revie~ed selecte~ opera:ing reccrds for the peri~~
January l - March 21, 1979.
These included:
Central ~~o= 0perat~r~
Daily L0gs,
~r.ift Su:Jerviscrs !:Jai!*: lq;, Ju:::pe:- anc Bypass Log, Nigh: Order Book, Held and Secure Card log.
The inspector conducted a tour of the control roo~ and other a:ces-sible plant areas to observe ins:rurnentation; radiation, fire pre-vention, and equip~enc tagging controls; and status of selected plane syste~s and equi?~enc; In addition, housekeeping ~as observed on t~o separate tours throug~ the reactor buildi~~ an~
found to be co~plecel> accepta~le at this ti~e.
No items of nonco~pliance or deviations vere ide~tified.
- 10.
Exit lnten*ie\\.:
At the conclusion of the inspection on ~arch 23. 1979, the inspectors met with Station Management personnel (Denoted in Paragrapt 1) and summarized the scope and findings of the inspection.
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UNITED STA1ES OF AMERICA NUCLEAR REGUIA10RY CCl-'lMISSION Before the Atomic Sa:f ety and licensing Board In the Matter of PUBLIC SERVICE ELECTRIC
& GAS CO.
(Salem Generating Station Unit ifol)
DCCKET NO. 50-272 CERTIFICA1E OF SERVICE I hereby certify that copies of Intervenors' Colernans, Motions to :
Reopen. Contentions 1\\vo, Six and 'Thirteen in the above captioned matter have been served upon the--parties hereto by deposit in the United States mail at the post office in Trenton, N.J., with proper postage thereon, this 2nd day of August, 1979.
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'/~c-ln KEI'lli A. ONSOORFF ASSISTA!.'IT DEPUTY PUBLIC