ML19225A285
| ML19225A285 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 06/07/1979 |
| From: | Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP |
| To: | |
| References | |
| NUDOCS 7907180762 | |
| Download: ML19225A285 (17) | |
Text
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=s ILTIED SIATES OF lJERICA s
NUCIEAR FEGUIATCEI CQCESSIGT T
coa,mo 3 \\
uu ec EEFQ1E THE ATCCC SAFEPT AND LICENSING BMRD JUN L,.979 3 ',
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UC DCCDCNT 200M d'
L In the Matter of
)
e, c%.~
d DIEE FGER CQ'. PANI Docket No. 70-2623 t,
(Anenumt to 'Iaterials License
}
SM-1773 for wonee Nuclear Station }
Spent Fuel Transportation and
)
Storage at McGuire Nuclear Station) )
INTERVEtTCR CESGt S RES?QTSE TO NRC SfAFFt S MOTIQT FOR SI2MRT I)ISPOSITICfT IN THE FE1 & THE TESIDDhY OF JESSE L. PmH NRC Staff filed a motion for the sz aly disposition of CESGt s contentiens 1, 2 and 3 May 11, 1979. This Board, by order of April 12, 1979, set June h, 1979, as the date for prefiling direct testimony. The undersigacd sulmits herewith CISit s reply to Staff's motion in the form of the testi= cay cf a CESG witness. We regret that this fm'ig.is out of time due to Nss.
Staff relies on two statments of material facts as the suppoding basis far its motion. One :tatened is in reW to contediens 1 and 2; the other to ecutentien 3. The fo=cr inlarge part mkes assedions with which CESG can ecacur. There are exceptics which will be nebef. There are a32:o siFim%
edssions which avoid the recognition of mtters at issue. The stntmeri of mterial' facts in regard to ecdsntion 2 at no p) int reference CESGt s response to interrogatories. This preperly comsponds to the almost total difference between CESG a=d Staff in regard to what may be asserted as facts. This filing camet in any sense be taken as an acced of agreed upon mterial facts.
In its notien for su:=.ary disposition Staff argues that CESGt s cdentions should be dismissed "for wed, of a genuine material is:rc.e of fact to be adjudicated..." (p.1)
Staff contends that it will show by t' e Er iremed a
Ir: pact Appraisal (EIA) that "Intervencrts contentions lack a s"%4ent material [ _
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ba::is to be anowed to go to hoaring in this proceecag." (p. h)
Inbervenor win show that Staff has failed to distinguish between fact and conjceture.
Staff was put on notice in the answer to interrogatories that CESG had not completcxl its case. This fi'Mng win present mtters at issue in tc=s of as nuch @ecificity at the mterial pemits. We win further show that the supposed " facts" of the EIA are conjectures based on assunphions wl-ich are both arbitrary and non-consenative.
In general and in scientific usage a fact is:
the quality of e:cisting or being real; actuality; tnIth.
scne'.bing known to exist or to have happened.
a tnrth knowa by actual experience or observation; that which is known to be true: scientists deal with facts.
Randen House College Dictionary (N. T.,1975)
When the Staff states (p. 5), unde-the Fede-J. Rules of Civil Procedure
... that there is no genuine issue of fact re:-'inine to be decided and that the uncontrovertible facts entitic [no mori.ng partg to judgnent as a mtter of law...
the " uncontrovertible facts" of their ncrtien will be shown to be largely the estir#oes mde of conceivable future ebeumstances. UnMke Staff counsel,
,:ho have constmeted the notien, staff witnesses are a. rare af the difference between actuality and infmed conjecture. For c:ccrcle, from the Dr. John 7 Nehe-ias affidavit (p. 2)
Du.ke Power has esti-doed,...
... we would expect...
It seens reasonable to assuno...
... are estinated...
Sc~.e of the language which nakes clear the difference between what is, and what the Staff expects will be, is preserved in Statements of Y.ste--ial Fact. We find these ernressions: will result, exposure ecleu22ted, e:<nos=: e estimated, (p. 3),
could be, could proceed, if, (p.h), etc. Howeve: when we a: rive at the nation we find that these esti-ates and cuniectures have been traru:nogrii5 ed to 423 008
-3 nuncontrovertible facts".
There are some aspects relating to " fact" which it will be usef al to bear in mind. It is, indeed, a fact that consideration has been gi.ven to alterndives to bhe transport of gent fuel frcn Oconee to McGuire; that estimates have been nade of the monetary and radiological costs of these alternatives.
It is also a fact that an estimate rc '4"a an estir. ate. And using factual g
information connecting source tems and shieving characteristics, it is a fact that radiation dosage can be calculated for specific assur:ptions. The fact that certain speriNc assu:::ptions have been nade does rd convert the esthated result to fact.
Alternathes have been considered one-at-a-the. Beth'.i=::n en -ing the Morage density in fac1 pool 1 and 2 and
m's additional fuel pool space either on-site or off-site have been considered as alternatives. The latter altatives have been argued at,h on the basis that they would not be ready in time to provide needed capacity. It is cbvious that ccapaction af the c:cist4 g pool would by tino for the constraction of an additional pool.
CCWECIT 1 The Staff argues (p. 6} that as the IIA and Otaff affidazits denonstrate that envi:o:nental i= pacts associstM with transport are negligibly call, and therefc e insignd" cant, that it is not eeptable viwvis the altemstives of incrwu-ing fuel pool capacity or conctr= tion of other capacity. Staff's argune=t dcpends on the demonstration of the triviality cf the i=pa.~ts of transpc-t. This is clearly a natter of speculation and cou::ter spec *datien.
One thing is certain. If :p casks conta -dm spent fuel move between Oconee d
and Mooni e it w7 not be possible to routinely expose cone part of the populace to low levul radiation; nor the dosage reulti=g fren a leak of 423 009
-h-of coolant; nor an escape of gases; nor the larger releases and expocres which could result frcn cask breach in an accided or total coolant ani gas It release by an act of sabdage or assembly exposre by accident or act.
is cicar that the risk to the populace will be least the less the prcximity of fuel assemblies to conced ations of people.
a Wat the Staff r Ms as a denenstration is/ set of calculdiens of dosages and azrticipated health effects'for a variety of assumed conditions. Idemor has reviewed these assu ptions and concludes that they do not represent c edible worst cases, although they are in part so termed.
Using Stafffs results there is a temptation to f4'vi these projected consegacres a:.e acceptable. Intervenor's results r22e the proposed action considerably less pnDtnble.
Even nore unsettling to the Stafft s p:cposed conclusion that "the:m are no sif mn-t env. c=nental i: pacts frc= the proposed transship act actic"...a d
(p.7. emphasis supplied), is the Co iscient s rece=t inglenedstion by ule:aM 3 of amend ents to 10 GR Part 73 concerning the Phy& Protection of Irradiated Fuel Shipneds (SII-79-278, April 18,1979; SECT-79-278A, May 7,1979). The ESS now believus that ce-tain interi= safeguards should be applied to sped fuel s"47~:ba. The pri.a:7 objective is the avoidance of A e ~"i Laboratories study sabotage in areas of high population densi.ty.
n (S00-77-1927) "su:; gests that the sabotage of spent fuel sM -Ms has the petent4 n' for producing sericus radiolegical consecuences in arcas of high pop:dation density." The ec= sequences of this Co :=iccion action wald seen to rcquire the amendnent of the IIA; either the findin;; of transshipment as the least acceptable alter:ntive; or the rejection of the presed roWW which.- either passes throu;;h or is in close prcri; !.ty to Greenvi"e, S.
C.,
Sprtanb=g, S. C., Gastonia, N.
C., and Charlotte, N. C.
4 Space crists at the Oconee site and engineering and architectd devices coild be usui to condret a contiguous structure (Contentions 1 (b) and 1 (c),
Staff M. F. #1).
App'4-d has availab2 :4 2arge work fo~ae which it could deploy to expedite the construction of a fuel pool cantiguous to Oconee pool 3.
Applicant has four other fuel pools in various stages of construction ab its McGuire and Catawba p22d construction sites. There should be no problen in acquiring without delay the various ca:ponents required for a fuel pool including liw plate, circulating pumps, heat exchangers, "i'74'7 electrical equipne=t, ventilating equipment, gas treating equiwa,t, hnists and the 7h.
I', is rewmble to e:tpect that such a centiguous addition to fael pool J con 2d be cagleted long before all storage soace had been uti2i::ed, ina'h,44ng new racks, n nely June 1983 (M. F. #1). This cr.bination of alternatives would minimise pablic expos =e during trans+4M and pro 1 ride a more cabstantial iderin solution to the problem of the imediate, d#terin, a=d long tem storage of Oconee spent fuel.
The citerdive of an independed :pe=t fuel storage insta32# tion by CESG ab the stipu2Mion stage of this proceeding was cencidered in the absence of infomation as to the practicability of ertending an Oconee fuel pool. Since t'zt time nate-ial discovered fron Applicad na.kes clear the feasib47dty of r
cendrmting additional on-site storage capacity. Given the practicabi2ity of this preferred alternative CESG no further pleads for the ISPSI alternative.
C 2 ZZ'TC2 L Eunan beings exist in afield of backg:ound ri ?'tien.
In the pi d ent d
Caro'i m e this e gosre amounts to about 80 =c:-/ year. Roughly M7" is frc cc:::ic rays. The effects of hig'a levcis of radiation are well doccacnted.
There is controversy in regard to low levels. The threshold dose po=ition, 4.7_3 n'1 (1
I which midcins that up to a certain level ionising rnaintion does no harm to an e ganics has been gipng my to the 2incar hypothesis. The 74mn' hypothesis ho2ds that where a large popuhtien is uni.femly cxposed, the n:rnber of health effects is proportional to the dose, starting from zero. A nore recent W cw advances a non linear hypothesis, in which the proportionate increase in health effects of a unifomly exposed population is greater at louer levels of exposure than at higher. One fact that all three hypotheses recognize is that there is a -*slation between health effect and ancud of exposure, and that at a given level of exposre the develop ent of a health effect is a rnnda:a matter. For c:ceple, in a population uniforly exposed to a 10 rcm dosa, only a fraction of those exposed would develop leuke-ia--the others watt 1d not. And it is not within the scope of presed knowlec ge to be abic to discrirrimte those more vnN able to exposure and those less vu2nerah1c.
In %% contert it is easy for a person to declare that 0.0h latent cancer fatalities mean essentic22.7 n
no health effect" (M. F. i 21). If this edi= ate is in errar by a factor of U
1000, as I sha2.1 demonstrde, we contcrp22te ho latent cancer effects. Where, between 0.0h arr! ho do we drar the line? Should the decidem =ake-be conted with these odds fc-himself? for the population to be pote /n177 exposed?
Considering the triviality of the benefit-another potentia 237 bnm-deus means of surp2 ing electrical energ', -at a tino of a 30% gld in peak generating 7
capacity, it can reasonably be afff=cxi that any unnecessary potedial for exposu e to the popt'Istion is unacceptable. It is ny testisc=7 that, as there is no benefit, there is absoldely no basis for increasing rf sk.
I do not accept the theory that there is an econce equivaled-to be reaped by society gene-al2;-for en ineversible health effect to be suffered by a :ringle in~'ividual.
Several facts cappc-t the ncMose-incremed-i::- acceptable position. Ever sime the c was an a:=reness of radiation hasard, the so-called acceptable limit has been lowered. Our knowledge of these uatters is ine:rplete and rhort tern.
A7n D')
4c0 di-Intervenor will in its testimony relating to Contention 2 prescr.t dosage calculations based on differed assu=ptions. It vill also describe 1 sir:ple method of sabotage which, if e:cecuted, would have serious health and e:rrLran=cutal conseqaences.
A pnferred altermtive to transport can be visualised in stM. stages.
The first one, increasing the capacity of fuel pools 1 and 2 by closer storage of asse:blies, has already been initiated by Applicant. Present 4M4c'tions are that a favorable response to its applicatien vm be =ade by the 13C on or about Jne 8,1979. This change, depMng on whether a full core reserve is :r.intained or not, wm provide sta:-age capacity without the need for transshipned through June,1973 (Staff. M. F. #1).
Staff does not believe that such reracking #1' cause undue risks to the hnn7th arri safety of the public or werkers and v not cause substantial adme emironmental i= ncts (H. F. #2). Operation of the Ocenee reacters without a fullwore discharge ecpability Opears acceptable to the Staff (M. F. fh). RcracH ng V'7 :cesult in somewhat higher worker ccposre than transsb4M (M. F. #5).
Ecwevc-the dosage T o workers of subsegaent additional rehn,d'%g of the spent fuel assemblies, McGrdre being but an dr~ rin resting place, mu2d affect this
- 6 h ' ~ e.
(See M. F./for the s-" worker-exposre di"erence for the two propos.) There is no regulatory regairement with respect to fh77 core resc: ve capaM'4ty (M. F. #7). Herac:dng can be ca pleted within three to ci:c n nths (1:. F. #10', #22). A statement supporting the transchip:mn:t option as preferable to rerael:ing (M. F.fik) preceded the Cc.ission action in regard to the inte:-in firAl rule in regard to protection of spent fuel shipments t==:gh populous areas against sabotage (SS::I-79-278A, May 7, 2979).
4?3 0:3 The consecue=ces of increases in exposes are general and long term.
The authors of the EIA have systa-stien"y chosen acc=ptions which result in raller rather than larger dose esti::ntes in spent fuel transchipned. The relation between dose and d' stance is related to che gecnetry of the source, the relatiomMp to the object egosal, and the coefficient of absorption for the intervening nedium. Based on an inspection of EIA data I cone to the conclusion that a point source has been assunod and that dose rate falls off with the %m of the distance. Tne closer the approach to the cask, the less true this re2dionship. However, I shall use it as the Staff apparent 27 bas.
Taking the liniting dose rate for a ged fuel assembly in a cask as 10 mrcr/h at a position 3n fron a vertical p2;:nc through the edge of the trailer, I dve at dose rates in relation to distance frcn the refere:r:e plane as shown:
Distance Doce rcte (feet)
(cren/h) 0 72 1
h6 2
32 3
23 h
18 5
2h 6
11.5 (3n) 6.7 10 In treating radiological d. pacts of roubi.e cperatica (EIA 5.1) it is dated that no kncun leaking elenent :F7' be shipped.
It wett1d be to the point if the neans for leak detection were deffaed, the efficacy of this procedure given, and the regulato:7 process by which there would be a rease able egectation thet this result could be achieved. It is clearly i. pessible to define the source tern of the coola::t given leaking elenents.
The esti-stcxl radiological 1:gast en the public (IIA 5.3.2) reflects assusions.
As with a21 ether radiolodcal estirates, it is assmed that the fuel 5F'7 be 423 014
p at 1:.ast 270 days. IIo prilisions for assuring this result are given in the EIA. There is, however, da Applicantis operating inst: etions for cask lonAiag a specification for na:cir:un perrissibic rate of tmperature rise of coolant after the assembly is loadod. The public safety at this podd depends on the accuracy of measuring a short tine iderval, and of the i"Aication and reading of a single themometer. The n:rtter of fnmng s:ithin the burn specification +47n-17 depends on the accuracy of plant reco:: tis a:x1 assemb27 identification. There is no,Mir ation of a backup for this dete=ination or of the radiological characterimtion of an asse=b2y before it is placed in the cash.
The ZIA invariably refers to the rrnber of propene shi m Ls as 300 The Applicant in discuvua states h20. It is obvious that, all dher tM"gs ecual, the radiological consequences of noving h20 casks is h0% higher than for noving 300, In routine transport the =axi=en individual (IIA 5.3.2) is defined as a person who is 30 m,.100 ft, fron the roadway. This is simply not a reaso.able ass :-tion. A=yone who has observed the passage of I-85 through Spartanburg knows there are many facilities for the pub 2ic less than this didance from the road. If, in accord with the new anti-sabcrbage regu2aticas t: ansport novas to secondary roads, there d'7 be nany habitations closer to the road than 30 m.
There V7' in all lika'%ood be me:d. nun persons as near ac 3 n to the road.
This would nake for a dose increase of 100 fold.
In calsulating integ-ated dose to people 30 m to 800 m f: c1 the road (IIA p. 31) n an ave age populatica dens
.,,y of 250 pc sens/ni' was as:r=ed. The average 2
density fo-Charlotte is about h000 pc sons /=1.
It is apparent by inspecti:n given scch densities in popu22 bien density along the re3,e that the use of an 423 015 ave age population density will greatly understate cgosre, becausa dose rate falls off with the square of the distance. Conside-ing the high populdion densities of the other cities along the proposed route it appears like27 that another understdaunt of i= pact of two or three orders of magnitude has been ::ade. Although the EIA states that "the more direct interstate route would seem to be the most advisablen it does not present any calculations in support of that view (ITA p.31).
In estimating the consequences of a traf#ic jam in an area with a population 2
den::ity of 10,000 persons /mi lasting 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> the maxi =m 4-44vidual is as==ed to be 3 a from the cask and to receive a dose of 15 aren. This is a re arinbly large scparation ffp a traffic jan. A more conservative assQion would project a fu217 loaded bus stopped along:f de the cad with a vehicle-to-vehicle separation of half a foot. Abed ten banks of seats weald be arrayed para 21e1 to the cask. Those nea ed the cask would receive a dore rate, igno:dng pos::ibla shielding effects, of h5 =e /h; those sczt fiu-thest, 25
=e/n; next farthest 17 rer/n; and the farthest Ih mre=/h. The a
=a indinduals, ten in Irrber, would receive 235 cc. in the i=ided. The total for the forty c:goced 4-d4Tiduals w:uld be 3 man ren. If e M W were involved, the potential consaquences wald be highcr. S4 -" n-17 if the fuel were aged less than 270 days, the dose would be higher.
The IIA considers the dose pe-occupant of a car fo1104 the cad for fou-hors at a distence of 100 ft. It is perhaps an overstatement, bd it is my e :perie=e that nobody follows at that g: eat a distance. Let us censider the case of a tail-gater and a two 2r.ne road. The following distance would be =re ner27 ten feet. The dose would be 100 tines that H 3 Stafft s assu.Aicns.
g3 M6
_n
.An ana27 sis of the case of exposre to traffic in the opposite direction (L F. #7) in inich the etrrdative dose for 300 shipneds is taken to be 0.0h person ren and tha individual dose abot 0.03 men reveals that abod 2333 persons pass the cask in trn"% per trip. This clearly would depc:x1 on the time of day of passage. For Chrlotte during rush hour, or for Spartanburg or Greenvi210, this seu a gross understatened. A nore conservative analysis would, in ny judgned, increase the Mmn nurber of such exposures by a fador ten.
I'ven nore strik!.ng are the ass =ptions ubich ppred27 ':nder21e the ccoured t-affic expos =e nnnlys!.s. Cunulative exposure was estinated at 0.08 person ren (L F. #3). For the 3 =c: individual dose this would cor::uspend to only 27 persons exposed per trip. Where is the 210 % stretch on $nterstate and what is the 6 her tic.c period when a truck VU only pass or be passed by 27 individuals tcau2ing the same *.q71 The EIA does not reveal passing times, side-by-side tines or praxi=itics ass =ed in this calculdion. Again it seens appared that any revision in a reasonable direction can only provide a higher result. I expect there is a=ple recn for an increase of one or two orders of magnitude (i.e.10 to 100 fold). For e=rple, an average of two persons trave'4 3 for 60 =irdes at a distance of 3 ft frca trailc side for h20 trips would total 20 man re:2 expos = e.
It is alleged that the cask can srvive a wide reage of transportation accidents without the raWe of V"icant radicactivity (L F. #21).
This a21egation appared27 relies on f"-scale f.W teds conducted by the DOS (M. F. #12). Reference to the Sandia cask i= pact ctudy chons thd is was perfo=ed on a differed type of cack.
F'd ke Applicadt c l'aC-1 cask, it in.c not equipped with a nedron shield tank. The clo:are was 423 017 flush with the cask body. In the HTTC-1 a pa:t of the lid projects beyo:x1 the cask body. 'Te result is to mke it w7namble to a nhnn-ing action which would have no effect on the type of cask actuaLy tested. F rther, to the best of I::7 knowledge, no HAC-1 cask has eur been subject to an actual 1 : pact test. The NAC-1 has been tested b3 ana2p is and by noda W. To my E
best knowledge these tests have not Ecluded the accident to dich the NAC-1 would be nost vn'hwable, a top-s%r.-ing accident such as wm:.M occur in a jack-knife skid.into an i.novable object such as an overpass abtrb,t.
The HAC-1 (US?-h) cask is quite vulnerable to the loss of its neittron shield, borated antiftee::e solution codained in a thin stainless sheet =ctal shePoh.
If Stafft s Motion is correct, loss of this shield would in= ease the dosage rate at three feet fra: the crface of the package to up to 1000 r:re:n/n (p. 22).
One of the more crious relea.ses estinated by Staff wouM occur in an over-prescri:dion accided (M. F. #17). This accident assras egosre of the cask to fire in the accident aresulting in release of 0.25 of the cavity coola It" (m 6.1.3). This scemrio apparedly assr.es tF# the di Tosition of the cask is such that only vapor W" vc:t through the pressee relief valvn.
If the en* turns ever in the accident, and the prescre ra'4 ef valve is under-nod,'there is the posdbility of dischrgis.g all of the coolant fma the cask.
In this circunstance the calculated releases would be 1000 times these put fe:th in Table 6-2, assu:ning the distance re2ations, cask to people, of the EIA.
These are remarkably nonconservative ass _ 6 iens. The mni= 2 individ- is taken to be 1C0 = I5on the accidedi Energency crews would soon ganhar at the scene cf such an accident if it were in a pcpulous region. I en umble to i cgine that the norest fire fighter ucu.Id be spraying the cask with watcr fren a distance gedcr than the length of a foctbo" field. I suh=it that it 423 018 is reasomble to conclude that the assumptions chosen are such as to mke a ven serious accided have the appearance of borderline " accept'h474t-f'.
Incrm*g the postulated accident consecuences by 1 to 20 r4 men fold results in a consequence esti:nte approaching credibility. We noir find ourselves contemp2fd.ng dose cat::itnc=t;s of the order of a mmion =m ran and rdsm.
individuals exposed to the order of 100 rem, fhst 7 ear.
An assc=b27 cxposre accided would have even graver and =are prompt consequemnes.
Given the structure of the cask, and probable irpact veloci^ des, it is not like27 that cask breach and expccre V77 ocer. However it must be held in mind as the ca c!.=un pcted,ial consequence of noting spent fuel. Although discovery fran Staff irr" cates a te:perature sancubat less ^hnn 1000 F for a 270 day aged assenb2, abse:n the coolant, this tc::pe.sh e esti::ste does 7
not appear to be corpatible with that of the In%itd Fcr Rm dorsicherheit in its Ecport #290 (HR0 trans2rtion #161). In that study 200 day aged fuel absent coolant is seen as melting. Destruction of cheath i::tegrity, which 0
occu s at a much louer te=;crature, 2000 F versus 5000 F, would be scricus enough. As a 6.i.=: this 3 card should require a co=peted, independed ed4:nte of the te=peratures attained by : ped fuel assa:blies of a range of ages unde-the condition of coo 2M, loss and cask d pressu-ination.
Si3OIAGE The catter of sabotage is touched on in the EIA (3.h). It is conWered to be "neithe an att active ner a practical target for sabotage and is specifien"y ext _J f:en the ph@al protection requi e.ents of 10 CFR Pcrt 73."
That vic:: has chcnged (E-79-278).
I do not a~;ee that n ped fuc1 cask covers s
cannet be re-oved by hand becance of tH-bulk and neig'd2 (EIA p. 17). Ihe cover weighs 2h00 pocdc. It is corred b7 an i. At limiter'sccured by for 1" bolts torqued to 60 foot pounds. Thi:: won 2d presert no problen to the 423 019
24 saboter. The Ihr lid bolts, torqued to 1000 foot pounds. This calls for a urench with a lever of five to six feet and the vigorote application of muscle.
CoMAcr.:.ng thht the pyramids were built by hand labor, it would be a mistake to say it couldn't be done. 3:t it would not be the mbotage nethod of choice.
The U:nger to the saboteurs would be great. They wou3a be p uded to drain the cask of coolant before renoving the unbolted lid with pry bars. If it we: e their object to expose the asse=b27, they would be undertaking great risk, as a fraction of a second exposure to an W47a d asse=bly s.-in e
result in a lethal dose. A g:cpple attached to a cable which in turn was connected to a stationary cbject would provide a = cans of complete 2y c posing the assembly-by driving off in the tm gort vehicle.
The ceployn= of shaped charges is not essedial to an act of sabot age, although it right operate more rapid 27 than cover rcnoval. Ct:e co=plicatica for the e:nlosive te 'r:ique is the p:esence of the liquid neutron chield between the cask crface and the substantial i=ne portion.
The probable nethod of choice for the techrien'77 ccmetent caboteur s6 be ci=ple and quick and require no special equipned. The result would not be as deinstating as assembly ecos=e, but it um:Id be quite severe. After t M g possessien of the vehicle it muld onb recuire rencving the h mi tight port to the d ain valve (Appliedts Op/0/A/1510/h, 5.25), snapping a loc 4ite fitting attached to a length cf hose to the drMn line, and ope =L.g the drain valm.
Depn~" g on i-ltini coolant p escrisc. tion and on coo 222 te=pe atre, the coolad 1F" be usder a prescre of several huni ed pai.
It sf7' tota 2ly dischrge frc= the hose reducing the hasard discussed foregoing sicre, in an accided involvi.g fire, the coolant dischr.rgcc through the prescre relief valve. Dependi g on asse=b27 age, and bu=, the assa:bly sF'7 increase in 423 020
25
- " lid bolts Vatre tmtil it reaches a steady date value. The pins in the iderior s
.c-of five to.e assmb74 p'7, of ec=se, reach the highed tagerature. Depending on I
the pyrcrids {c perature reached, defects in the sodh #77 fail, rela,
- g radioactive rt be done.
s, kr.ptons, xenons, iodines, cedt=.
As the tc=perature app:paches 1
3 sabetours wot?, sheath failure #77 becom extensive.
Unless the fuel is aged less l
12 before rc3specified, fuel neltdcun at about 5000 F is not likely to occur.
If i.
t to c:gose thes occur, an even nore e:ctensive release of vold47n radiomelides would Len of a secon. Co21cpse of the assc=b27 structure and shedh would remit in nore
.1 dose. A gaied hed renoval frcn the fuel, attended by a drop in te::perature. The tdionary objened power 74 #tation of abod 22 ka fer the assmb2y would make nelt driig off ich of the cask rather t=like27, although steel nelts at less than 28000F
. cad, the pr%' y shin 7di 3, at 621 ?.
A longit"di" ' section of the f iaped chcrg is attached. The lid, cask proper (c='~" g the neutron shield tcnk),
c=t and d-Am cFr.nnels are heavily lined in. The drawing uns provided 7 e is the pre th Staff and Applicad in discove:7 It is w ent by 'Incocction that the substdi ng the dr**" valve of the nc=a127 positic.=.d cask would result in had of choice arge of the coo 2 ant.
and require r CICU 3
.scenb27 cgost centends that because it alleges that the envirc::. ental d. pacts of :: pent brenssipment in a cask would be negligible thd an EIS is not required.
3ricus health consequcnces attn ~"".g sabotage (SECT-79-278) do net s=ncrt
. to a length c ling of neg2igible consegances. Iior does the m cress r ication sequence z = initici e
! bed foregcirg. The pctcnti 7 for :n:hstcnt4*7 hec.lth and enrire=cata2.
. be under a p1
!s c 7's for a astudy of the proposed transshi=cnt and the inccrpo = tion m hose produ:
p findings in an Envirc= ental Inpact Statene=t.
Tc fire, the :
y en assenb'J ply nyL.
U
I
-u.
Affir:ned by the riter at Charlotte, N. C. this 7th day of Jime,1979,
/W 9 I L
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Je:pe L. Faley for JSG Setd on the parties by deposit in the U. S. mil, Jime 7,1979
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