ML19029A856

04/25/1979 Outline of Intervenors, Colemans, Cross-Examination; Contentions Two and Six

ML19029A856
Person / Time
Site:	Salem
Issue date:	04/25/1979
From:	Onsdorff K The Public Advocate
To:	Office of Nuclear Reactor Regulation
References
Download: ML19029A856 (4)

Text

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OUTLINE OF INI'ERVENJRS, COLEMANS I CROSS-EXA.MINATION CONI'ENTIONS 'IW) A.1\ill SIX

2. The licensee has given inadequate consideration to the occurrence of accidental criticality due to the increased density or canpaction of the spent fuel assemblies. Additional consideration of criticality is required due to the following:

A. deterioration of the neutron absorption material provided by the Boral plates located between the spent fuel bundles; B. deterioration of the rack structure leading to failure of the rack and consequent dislodging of spent fuel bundles.

6. The licensee has given inadequate consideration~ to qualif icatio~ and testing of Baral material in the environment of protracted association with spent nuclear fuel, in order to validate its continued properties for reactivity control and integrity.

I. The Potential for the Occurrence of Accidental Criticality in the Spent Fuel Pool and failure of the reactivity and structural support fixtures in the spent fuel pcol to meet design specifications.

A. Deterioration of the neutron absorption material in the fuel racks.

1. Cross-examination of NRC staff _and PSE&G Co. *witnesses shall address the computational analysis :perfonned on the compact rack configuration to verify ccmpliance with the criticality Keff. of 0.95 (estini.ated time of cross-examination: 3 hrs.)

forthwith to resolve the problem without vitiating the integrity of the reactivity control and structural support fixtures in the spent fuel p:::>Ol (estimated time of cross-examination: 3 hrs.}

LOWER ALLOWAYS CREEK 'IOWNSH.IP

.CONTENTION NUMBER ONE

1. 'Ihe Licensee has not considered in sufficient detail possible alternatives to the proposed expansion of the spent fuel pool. Specifically, the Licensee has not establis..hed that spe..Tlt fuel cannot be stored at anotho,_r reactor site. Also while the *GESM'.) proceedings have been terminated, it is not clear that the soent fuel could not by sane arrangement with Allied ChemicEtl Corp. be stored at the AGNS Plan in Barnwell, South Carolina. Furtherrrore, the Licensee has not explored nor exhausted the possibilities for disp:)sing of the spent fuel outside of the U.S.A.

I. Inadequate Consideration by the NRC Staff and Utility of Viable Alternatives to the proposed High Density Reracking of the Salem One Nuclear G2nerating StatiorL Spent Fuel Pool.

• A. Use of storage capacity available at existing Away From Reactor (AFR) reprocessing plants (30 minutes).

B. Construction of ne.w AFR storage capacity at isolated, unpopulated areas of the United States (30 minutes) .

c. Storage of spent fuel generated at Salem One Nuclear Generating Station at other active or decommissioned nuclear reactor sites (30 minutes).

D. Slow down or cessation of spent fuel generation until AFR storage capacity can be implemented (30 minutes) .

2. Cross-examination of these witnesses will also address the criticality hazards presented by cell venting to dissipate hydrcg-en gas build up, in addition to the explosive potential associated *with such venting and hydrogen gas releases into the spent fuel pool building (esti.IP.ated time of cross-examination:

2 hrs.)

B. Deterioration of the spent fuel pool rack structure

• i. Cross-examination of the NRC staff and utility witnesses will address the unresolved safety proble:ns associated with :fuel design changes, inability to maintain proper boric acid concentration in the spent fuel p:Dl ~d venting procedures which se.rxrrately or.

in canbination could result in total or partial rac..lc failure (estimated time of cross-examination: 3 hrs.)

C. Qualification and testing of the boral material over a protracted period of tirre in a spent fuel pool environment.

1. Cross-examination of the NRC staff and utility witnesses will address the insufficient and inadequate surveillance and fuel storage manage.~ent procedures to assure that no significant deterioration in the boral material occurs without pranpt reccgnition of the hazard p:JSed thereby and appropriate steps are implemented

In addition to the above areas of cross-examination, the intervenors intend to explore,:possibly both through direct testim::my and cross-examination, the matters of ASLB interest pertaining to the Three Mile Island-2 accident and raised by the several limited appearance statements specified by the :Board for consideration at these hearings.

Inasmuch as we are not in receipt of any prq;::osed direct testimony pertaining to these issues filed by any other party to this proceedin;r, I am unable to prepare an outline of pro:posed cross-examination. N:metheless, I anticipate that in light of the absence of such pre-filed direct test.irnoqi; none is required under these circumstances.

Respectfully sul:mitted,

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KEITH A. ONSOORFF Assistant :ceputy Public Advocate CERTIFICATION OF SERVICE I hereby certify that oopies of this outline of cross-examination have been served U:pon all parties to this action by de:posi t in the United States nail this 25th day of April, 1979.

KEITH A. ONSOORFF ___. /