ML19209B256
| ML19209B256 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 09/07/1979 |
| From: | Bechhoefer C Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| OROR-790907, NUDOCS 7910090386 | |
| Download: ML19209B256 (10) | |
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7 g\\Nc5 UNITED STATES OF AMERICA 2-
[d NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD D
59 In the Matter of
)
)
DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409
)
(SFP License Amendment)
(La Crosse Boiling Water Reactor)
)
MEMORANDUM AND ORDER (September 7, 1979)
Pending before us are motions for summary disposition (see 10 CFR 52.749), filed, respectively by the NRC Staff on July 30, 1979 and the Applicant on July 31, 1979.
Each of the motions seeks summary disposition with respect to all contentions of the Coulee Region Energy Coalition (CREC).
Grant of either of these motions in its entirety would result in dismissal of this pro-ceeding, inasmuch as those of CREC's contentions which were ad-mitted are the only issues presently in controversy in this spent fuel pool expansion proceeding.
CREC has not responded to either motion.
As a result of CREC's failure to respond to the motions, we might be well justified in finding (as the Staff and Applicant urge) that there are no outstanding material factual issues and in granting summary disposition of all of the outstanding conten-tions.
See 10 CFR 52.749(d).
We need not do so, however, where we believe there are or may be significant unresolved questions 1114 116 79100 90 J g6
^
. concerning any of those contentions.
Cleveland Electric Illu-minating Co. (Perry Nuclear Power Plant, Units 1 and 2), ALAB-443, 6 NRC 741, 753-56 (1977).
That is the situation here.
We request the Applicant and Staff (and CREC if it wishes) to answer the questions appearing in the attachment to this Memorandum.and Order.
Such answers should be provided to the Board at the commencement of the forthcoming prehearing conference.
Pending our receipt of such information, we take no action with respect to the outstanding motions.1/
Some of the questions may require factual answers.
To the extent they do so, the answers should be submitted in affidavit form.
See 10 CFR 52.749(b); Perry, ALAB-443, supra, 6 NRC at 757.
Although CREC appears to have abandoned its contentions in the spent fuel proceeding, we will nevertheless permit it to respond to the Board's questions at the same time as the Applicant and Staff.
Furthermore, we will permit CREC to respcnd at the U' der the schedule established in our Notice of Prehearing 1/
n datad August 21, 1979 Conference and Evidentiary Hearingf9), direct testimony on (44 Fed. Reg. 50105, August 27,19 the contentions for which motions have been filed need not be filed by September 17, 1979.
If we determine at the pre-hearing conference that some or all issues must be litigated, direct testimony will be required to be filed by September 24, 1979.
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3-prehearing conference to the material submitted by the Applicant and Staff in response to our questions.2/
CREC's answers to our questions, to the extent they involve factual matters, should include affidavits.
But CREC's responses at the prehearing con-ference to the Applicant's and Staff's material submitted in response to our questions need not be in affidavit form (although, where factual material is involved, they must identify sources of factual material which will be presented at the evidentiary hear-ing).
CREC must present its direct testimony on the same schedule as the other parties.
FOR THE ATOMIC SAFETY AND LICENSING BOARD
/*
Y t/
Tharles Be~tnoefer,, Chairman Dated at Bethesda, Maryland this 7th day of September,1979.
Attachment 2/
We request the Applicant and Staff, if they can do so, to have their re_sponses to our questions in CREC's hands no later than September 19, 1979, the day prior to the pre-hearing conference.
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ATTACHMENT A.
With respect to Lontention 1(b), the Staff's motion (and Dr. Weeks' affidavit) seem to be ILnited only to the situa-tion where stainless steel clad spent fuel is employed.
The authority relied on by the intervenor (NUREG-0404, App. H, p. 23) is distinguished as " entirely irrelevant since it discusses only zircoloy cladding, not in use at LACBWR" and also because it deals with long-term offsite storage.
The Applicant states, however, that zircoloy-clad fuel will likely be used during the lifetime of LACBWR.
In its own motion for summary disposition, the Applicant relies primarily on the Staff's SER analysis to establish that the effect of accelerated corrosion, microstructural changes, alterations in mechanical properties, stress corrosion, cracking, intragranular corrosion, and hydrogen absorption and precipitation by the stain-less steel fuel pool components will be insignificant, even when zircoloy-clad fuel is involved.
The Staff itself does not rely on the SER for this purpose.
Dr. Weeks admits that microstruc-tural changes as a result of corrosion can occur with zircoloy-clad fuel (affidavit p. 3) and concludes only that, by the time zircoloy will be stored in the spent fuel pool at LACBWR, consid-erable experience in storing zircoloy-clad fuel at other sites will be available.
Given these considerations:
1.
Assuming storage of zircolov-clad fuel, what circumstances distinguish the long-term orfsite storage ii14 119
. situation discussed in NUREG-0404, App. H, p. 23 from the present situation to a degree necessary to make NUREG-0404 inapplicable to the present factual situation?
2.
Have stainless steel racks been used in other spent fuel pools where zircoloy-clad fuel has been stored?
If so:
a.
Where?
b.
For what periods of time?
c.
Was the water chemistry similar to that at LACBWR?
d.
Are records available indicating the corrosive effects, if any, occurring with respect to the stainless racks?
What corrosive effects occurred?
3.
On what basis can the Commission permit zircoloy-clad spent fuel to be stored in the LACBWR spent fuel pool, given the unresolved questions presented by Dr. Weeks' affidavit?
4.
Is not further review by the Staff, and a concomitant technical specification or license condition change, appropriate before storage of zircoloy-clad fuel at LACBWR may be found to be in accord with the public health and safety?
5.
Does any technical specification or license condition currently in.effect preclude the storage of zircoloy-clad fuel in the LACBWR spent fuel pool?
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. 6.
If not, would the Applicant or Staff (or CREF) have any objections to a condition or technical specification requir-ing Staff review and approval, and license amendment, prior to storage of zircoloy-clad fuel in the LACBWR. spent fuel pool?
B.
The Staff's SER indicates that the estimated potential consequences of a fuel handling accident are 162 rem to the thyroid and 2 ren to the whole body at the exclusion area boundary and smaller within the low population zone (LPZ) (SER, 53.6.1).
This analysis apparently assumes that freshly discharged fuel assemblies will not be stored in an upper rack position directly over another freshly discharged fuel assembly.
The stated consequences are within the guidelines of 10 CFR Part 100.
Even if a freshly dis-charged assembly is stored over another such assembly, the offsite consequences are said to be within the exposure guidelines of 10 CFR Part 100, although no exposures are set forth.
Given these circumstances:
1.
Will the Applicant be prohibited by a technical specification or other requirement from storing a freshly dis-charged fuel element over another freshly discharged element?
2.
If not, what are the estLnated maximum offsite consequences of an accident involving a fressly discharged ele-ment in place directly over another freshly discharged element?
3.
Even though the maximum consequences of an accident (involving either a freshly discharged element stored 1ii4 121
. over another such element, or a freshly discharged element stored over an older element) fall within the guidelines of 10 CFR Part 100, they do not appear to fall within the guidelines of EPA's Protective Action Guides (PAG).
These guides recommend evacuation or other protective action where the exposure to the
~
individual is 1-5 rem whole body and 5-25 rem thyroid.
See EPA
" Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," dated September, 1975 (EPA-520/1-75-001),
Tables 2.1 and 2.2.
a.
In the event of a maximum fuel handling acci-dent, are these EPA prescribed levels reached at any point out-side the LPZ?
b.
If so, does the Applicanc's emergency plan contemplate taking of protective actions to preclude expostres at these levels?1/
c.
In any event, does the Applicant's emergency plan provide adequate mca.1 to preclude persons in the exclusion area or LPZ from being exposed to those levels of radiation?
d.
Has either Wisconsin or Minnesota adopted or sanctioned the EPA-recommended PAGs, whether by statute, regu-lation, or other regulatory method?
1/
Assume for these purposes that EPA or State PAGs may be made applicable to LACBWR.
See 10 CFR 550.91; proposed 10 CFR Part 50, App. E, I. (43 Fed. Reg. 37473, August 23, 1978).
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. C.
It appears from Section 3.6 of the SER that offsite doses for the fuel handling accident were calculated assuming that the containment building is not isolated.
Is this the case?
If so, how much would the offsite doses be reduced if the contain-ment building were isolated (1) at the time of the accident, and (2) as soon thereafter as practically achievable.
Please discuss whether containment building isolation should be required during fuel handling.
D.
The SER discusses the cask drop accident in terms of a previous Staff analysis of the existing spent fuel pool design.
Please provide that portion o'f the October 22, 1975 SER describing that analysis and its results.
Do the consequences of this acci-dent result in exposure levels reqviring protective action under the EPA Guidelines referenced in question B?
E.
From the material provided to the Board, we have been unable to determine the surface elevation of water on the reactor side of the fuel transfer canal gate under various conditions, e.g.,
during reactor operation, during fuel transfer, and during shipping cask movements.
Please provide this information.
However, it now appears that water pressure on the fuel transfer canal gate will be higher for the new rack design and under the proposed new tech-nical specifications.
Moreover, it appears that the depth of water cc ering the new racks will be much less than for the exist-ing desiga La case of a fuel transfer canal gate failure.
If so, 1114 123
. the Board questions why a gate or pressure vessel to cavity seal failure accident was not analyzed and discussed in the SER.
F.
The Staff's SER indicates generally that ALARA princi-ples will be followed with respect to the exposure of workers (see SER, $2.7.2), but no details of inplementation are provided.
Indeed, the achievement of Part 20 levels appears to be considered as equivalent of ALARA (c% Staff's motion for summary disposition,
- p. 19).
The proposed amendment would increase occupational exposures in several ways, but information is not supplied which could be used to evaluate whether the resultant exposures are ALARA.
Specifically:
1.
If remo:e. operations are used (Applicant's Plan B),
the occupational expo.iure is said to be about 16 man-rem; but, if remote operations are not used (Plan A), the occupational exposures are said to be about 23 man-rem.
The only justification for using Plan A appears to be the lesser number of man-hours needed to com-plete the job.
See Applicant's letter dated October 26, 1978 (response to question 3).
Is this standard consistent with ALARA requirements?
What other criteria, if any, are to be used to ascertain whether remote or manual operations are to be employed?
What cost differences, if any, exist?
2.
What occupational exposure differences, if any, would result from maintaining the water level in the pou? at a 700' elevation rather than at~1evel 16' above the storage racks?
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. What cost differences, if any, attend each of these methods of operation?
3.
What criteria have been used to ascertain whether the increase of total plant maintenance exposures from increased filter changes and resin volumes and intensities occasioned by a larger amount of spent fuel storage meet ALARA (not Part 20) standards?
G.
Does the LACBWR equipment comply with NUREG-0554 " Single-failure Proof Cranes for Nuclear Power Plants" (August, 1979)?
H.
Should the integrity of the fuel pool liner, walls, drain lines, and valves somehow be lost, it appears that fuel melting could occur which could result in large fission product releases.
If so, what emergency provisions are there to either prevent or limit melting or to mitigate the consequences?
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