ML19209C481
| ML19209C481 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 07/30/1979 |
| From: | Woodhead C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19209C479 | List: |
| References | |
| NUDOCS 7910150634 | |
| Download: ML19209C481 (11) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of DAIRYLAND POWER COOPERATIVE Docket No. 50-409 (SPFLicenseAmendment)
(La Crosse Boiling Water Reactor)
MATERIAL FACTS AS TO WHICH THERE IS N0 GENUINE ISSUE TO BE HEARD Contention 1 The Contention It is CREC's contention that the application to amend submitted by Dairyland Power is incomplete, as it does not address the following issues:
Applicant has not discussed the long-tem integrity of the various components of and in the spent fuel storage pool in light of the proposed compaction and increased amount of spent fuel at LACBWR.
The health, safety, environ-mental and economic impact of the loss of integrity of these components due to more dense and increased storage of spent fuel must be evaluated.
(b) Applicant should examine the effects of accelerated corrosion, microstructural changes, alterations in mechanical properties, stress corro-sion, cracking, intergranular corrosion, and hydrogen absorption and precipi-tation by the stainless steel alloys due to the proposed compaction and long-tem storage of spent fuel at LACBWR.
(c) Because of the possibility of leakage and disintegration of spent fuel and its cladding over the long-tem, Applicant must discuss the desir-7910150 7(
1134 7'T
ability of and methods for sensitivity monitoring to identify defective fuel elements. Applicant must also analyze the desirability of monitoring e ch individual spent fuel assembly.
(d) Applicant should discuss the desirability of and various methods and effectiveness r; encapsulating defective spent fuel elements upon dis-covering leakage or disintegration due to loss of cladding integrity.
This discussion is essential when considering longer-tenn storage and increased density of spent fuel at LACBWR. Applicant should delineate anticipated thicknesses of crud layers and crud tendency to influence corrosion of spent fuel and its cladding in light of increased spent fuel storage as proposed for LACBWR.
(f) Applicai.. should analyze problems in handling spent fuel (e.g.,
including but not limited to transfer from one pool to another or within one pool during reracking, repositioning upon removal from the nuclear core and placement in spent fuel pools, encapsulation of defective spent fuel elements, placement in or removal frcm shipping casks), resulting from loss of integrity of spent fuel and its cladding as well as other components of and in the spent fuel storage pool due to more dense and increased storage of spent fuel as proposed by Applicant.
A.
Accelerated corrosion has not occurred in stainless steel at spent fuel pools.
(Weeks' Affidavit, p. 3) 1134 264 g
4e eg
B.
Accelerated corrosion is not likely to occur.at spent fuel pool tempera tures.
(Weeks' Affidavit, p. 3)
C.
Microstructural changes as a result of corrosion do not occur in stainless steel so as to affect long-term integrity of the structure.
(Weeks' Affidavit, p. 3)
D.
Microstructural changes from solid state diffusion processes do not occur in the low temperature of spent fuel pool ccclant.-
(Weeks' Aff'davi t, p. 3)
E.
Mechnical alterations of stainless steels occur due to micro-structural changes or radiation damage from high energy neutrons.
(Weeks' Affidavit, p. 4)
F.
Effects on the mechanical properties of the components of the
. pent fuel pool by fast neutron fluxes will be negligible.
(Weeks' Affidavit, p. 4)
G.
Intergranular stress corrosion cracking of the LAC.'.WR spent fuel pool components is unlikely to occur.
(Weeks' Affidavit, p. 4)
!!34 265 9
e,
=. =.
G M -
g
H.
(Intergranular) stress corrosion cracking of SFP components at LACBWR would be of insignificant safety concern because it would be highly localized.
(Weeks' Affidavit, pp. 4-5)
I.
Hydrogen absorption and precipitation do not occur on stainless steel at low SFP temperatures.
(Weeks' Affidavit, p. 5)
K.
The proposed LACBWR spent fuel pool will use only stainless steel components.
(Weeks' Affidavit, p. 2)
L.
All spent fuel presently stored and to be discharged from the reactor in the near future at LACBWR has stainless steel cladding.
(Weeks' Affidavit, p. 2)
M.
Presently used spent fuel pool monitoring procedures at LACBWR are adequate to detect spent fuel leakage and/or disintegration.
(Weeks' Affidavit, p. 7)
N.
No additional spent fuel failure has occurred after storage in spent fuel pools.
(Weeks' Affidavit, pp. 67)
I134 206
O.
Damaged spent fuel can be safely stored witho.ut encapsulation.
(Weeks' Affidavit, pp. 8-9)
P.
Crud does not fom on fuel stored in spent fuel pools.
(Weeks' Affidavit, p. 9)
Q.
Crud from freshly discharged spent fuel is removed by the spent fuel pool purification system.
(Weeks' Affidavit, p. 9)
R.
Crud does not affect the long-tem integrity of spent fuel pool components.
(Weeks' Affidavit, p. 9)
S.
Damaged fuel can be safely transferred from the reactor into the spent fuel pool and into the shipping cask.
(Wohl's Affidavit, p. 2, 4)
T.
No fuel handling problems will occur due to the effect of water pressure on the canal gate.
Isohl's Affidavit, p. 3)
U.
No fuel handling problems will arise due to corrosion of the spent fuel pool components or contents.
(Weeks' Affidavit, pp. 5-6; Wohl's Affidavit, p. 4)
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1134 267
8 Contention 5 The Contention It is CREC's contention that an increase in the number of spent fuel locations from 134 to 448 would present a threat to the safety of the public and the raintenance workers that would be completely unacceptable for the following reasons:
(a) The design calls for an even smaller cask drop area.
(b)(1) The two-tier design greatly increases the chances for, and potential magnitude of, accidents in fuel handling and storage.
(b)(2) The two-tier and higher density design makes detection of problems in the ?ower tier difficult if not impossible.
(c) The two-tier design reduces the level of water over the assemblies from ten feet to thirty inches, and thus reduces the margin of safety so far as loss-of-coolant accidents in the SFP are concerned to an unacceptable level.
(d)
Increased fuel would increase maintenance exposures because of an increase in the number of filter changes and resin volumes and intensities.
A.
Analysis of a cask drop accident in the expanded spent fuel pool shows no increase in releases and that the limits of 10 CFR 5100 will be met.
(Donohew's Affidavit, p. 3) 1134 268
==
=
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- - Ope pe g
B.
The Applicant does not plan and there is no requirement to place newly discharged spent fuel exclusively in the lowe tier of the rack.
(Applicants' Response to CREC Interrogatories, Oct. 5,1978, p.16; Donohew's Affidavit, p. 5)
C.
Fuel handling movements for the two-tier rack will be the same as nonnal practice for the present pool.
(Donohew's Affidavit, pp. 4-5)
D.
Bi-monthly water chemistry monitoring; area radiation monitors; and an undentater television camera will detect problems which might arise in the lower tier racks or in the stored fuel.
(LaGrange's Affidavit, pp.12)
E.
The water coverage for the two-t'er racks will be. sixteen feet.
This is an increase of the present coverage of spent fuel at LACBWR.
(LaGrange's Affidavit, p. 2)
F.
Filter changes necessary for the expanded amount of stored fuel will double in number.
(Donohew's Affidavit, p. 7)
G.
The increase in filter changes, resin volumes and intensities will result in a 1.5 man rem increase annually for the plant's worker exposures, which is 1% of the total plant personnel annual exposure.
(Donohew's Affidavit
- p. 7) 1134 269
H.
The increase in required filter changes can be performed without exceeding 10 CFR 9 20 safety limits.
(Donohew's Affidavit, p. 7)
These material racts are supported by the Affidavits of Jack N. Donohew and Robert G. LaGrange.
Contention 6 The Contention CREC contends that a significant increase in the SFP capacity ang the resultant increase in spent fuel handling necessitated by Applicant's pro-posed amendment increases the risk of accidental releases to employees and the public in the event of a cask drop accident to an unacceptable level.
A.
A cask drop analysis performed for the expanded capacity of the proposed spent fuel pool modification shows no increase in possible radio-nuclide releases to workers or the public and shows canpliance with 10 CFR
$ 100 limits.
(Donohew's Affidavit, pp. 7-8)
B.
Ne increase in spent fuel handling will be necessary or performed because of the proposed SFP modification.
(Donohew's Affidavit, p. 8) i134 270
C.
The most significant releases from a cask drop accident come froa freshly discharged spent fuel.
(Donohew's Affidavit, p. 8)
D.
Expanded SFP capacity does_ not alter the amount of spent fuel discharged fra: the reactor.
(Donohew's Affidavit, pp. 7-8)
E.
Spent fuel continually decays during storage so that possible radioactive releases continually decrease.
(Donohew's Affidavit, p. 8)
These material facts are supported by the Affidavit of Jack N. Donohew, attached.
Contention 7 The Contention CREC further contends that Applicant's proposed amendment to its pro-visional operating license should be denied due to the increased threat to the envi.ronment generally, and to maintenance personnel specifically.
The increased threat to which we refer is that of the storage of failed fuel rods, including several grossly failed rods, which results in a more danger-ous and shortened storage life and increased storage costs. As stated in
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NUREG-0032, fuel failures " compound the problems of storage, waste reproc-essing, and disposal." As fuel failures are predicted for the future, ACRS, January 26,1978, p.173, and expansion of SFP capacity would serve to produce even more unacceptable hazards and increase maintenance exposures at LACBWR, which is already above the average for the nucleer industry in that regard.
f A.
Industry experience indicates no increased risks in storage of failed fuel beyond that of undamaged fuel.
(Donohew's Affidavit, p.10)
B.
The grossly failed fuel stored at the LACBWR spent fuel pool for a year has posed no risk to public or workers.
(Donohew's Affidavit, p.10)
C.
Failed fuel leakage decreases to insignificant amounts after several months storaSe.
(Donohew's Affidavit, p.10)
D.
Damaged fuel stored in spent fuel pools has shown no additional failure.
(Donohew's Affidavit, p. 9) 1134 272
E.
Failed fuel storage life has not been shorter than undamaged fuel.
(Donohew's Affidavit, p.10)
F.
Failed fuel storage cost is not more expensive.
(Donohew's Affidavit, p.10)
These material facts i.e supported by Affidavit of Jack N. Donohew.
Respectfully submitted,
/
_sL't
' V Colleen P. Woodhead Counsel for NRC Staff 1134 273
.