ML19241B253
| ML19241B253 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/29/1979 |
| From: | Bouton D CITIZENS ENERGY FORUM |
| To: | |
| References | |
| NUDOCS 7907130331 | |
| Download: ML19241B253 (11) | |
Text
-
4 G D CG s.' s m.vn g y y I
UNITED STATES OF A'.fERICA 1
NUCLEAR REGULATORY COM',iISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD t
In the Matter of
)
)
Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(North Anna Power Station,
)
(Proposed Amend =ent to Units 1 and 3)
)
Operating License N?F-4)
NRO PUBLIc D00mtEuv mooM je!
g(a, s
e L 58.tc
~
l
\\,
t
?
i EIS?0::FE TO NRC STAFF I'. ERRCGATORIES y
MAY 31 1379 ) 10 A::D REQUEST FOR EOCU:2:.TS c'".a d- * * *T.
- f.,.,;
ea s
Sam M11-X.,N //
g N'
4 In response to 10 CFR 2.7L0b, Citizens Energy Forun (CEF)hereby respo'nds Qf 1, s \\ ' "
" 'RC Staff Interrcgatories to, and Request for the Production of Docunents Fron, Intervencr Citicens Energy Forun," dated May 8,1979.
The answer to each of the questions is followed by the nanc, in parentheses, of the person (s) who prepared o'r substantially centributed to the ir eparatien of the response.
In researching its contentiens, CEF relied heavily en naterials maintained in tne :.O.; Pialic Cocu.ent Rcen. Ecol:s, papers and cther documents cited in this response cre, ri-i fe exceptiens, availab' o i- *e !?.O Pi;1ic Eccr. ant Eccn and are not in tne imediate pcssession of CEF.
5so 37 7 % 71 s on\\ C, Contertion 1: Thernal Ef fects 1-1 a.
CEF intends to call no '.:itnesses in support of contention 1.
b.
Not applicabic.
(Ir.cin Kroot) 1-2 Not applicable.
(Ir,rin Kroot) 1-3 (1)
"Su = ary cf Proposed Modifications to the Spent Fuel Sterage Pool Accocicted Eitn Increasing Storage Capacity for North Anna Power Statien Unit Nos.1 and 2,"
Virginia Electric and Po eer Co., April,1970 (2) " Safety Evaluation by the Cffice of Nuclear Reactor Regulation Relatin;; to Podification of the Spent Fuel Stora;;e Racks Facility Operatirg; License No. NPF-h, Virginia Electric and Poi er Company, Nortn Anna Power Station, Units 1 and 2, Docket Nos. 50-338 and 50-339," January 29, 1979 (3) " Environmental Impact Appraisal By the Office of Nuclear Reactor Regulatica Relative to a Proposed Increase in Storage Capacity of the Spent Fuel Pool North Anna Po :er Station, Units 1 and 2, Virginia Electric.and Po eer Cenpany Docket Nos.
50-333 and 50-339 Facility Cperating License No. NPF-h," April 2, 1979 w)"dpent ruel nest-up rolloinng Loss of.. water uurr.g storage" cy x11an c.
et.al.,
Eenjatn/ Reactor Safety Studies Division; Candia Labs, Albucuerque (# SAND 1371); Draf t printed Septenber 1973.
($)" Nuclear Energy's Dilc=a: Disposin;; of Hazardous Radicactive Waste Safely,"
Ecpert to Conges: by the Cceptraller General of the United Stat es; Govern ent Accounting Office Rcport # EMD-77-bl, Sept. 9,1977.
(6) Letter by Professer Earl A. Gulbransen, Departnent of Metturgical cni Materials Engineerirg, University of Pittsbegh; in tne Eulletin of Atenic Scientists, June 1976, page 5, SED 3M repST) CMS 7909.Laue.8'
(7) " Draft Generic Environmental Impact Statenent on Handiing and Storage of Spent Licnt 1:ater Pouer Reactor Fuel," NUPE Oh0h, Vols.1 and 2 Executive Funnary, lhrch 1978.
(:)1etter to T. A. Ippolito of the :iRC fren R.J. Clark, project nanager, Mati.ello 1;uclear Plr.b, dated Sept, 11, 1973.
(9) "Ad Hoc Subconnittee on Spent Fuel Pool Design Storage (#CR 2702), Advisory Cennittee on Reactor Safeguards Report dated Feb. 23, 1979 (Iruin hroot, Debbie Ecuton, Renee Parsons, Tin Engebrctson) 1,h Sane as 1,3 1-5 CEF believes Vepco's Sunnary of Proposed Modifications to be deficient in its analysis of those conditiens specified in the Thernal Effects contention.
First, no representation is made concerning the changed flow of water in the pool, due to the new rack and fuel configurations, if the proposed nodification is made. Seccnd, the effects of a los s of water fren the pool on the ascenblics in on the pool and/the re=aining water, if any, are not enunerated. Third, the effects of the additional 6 3I2/hr of uaste heat to be discharged to the environnen; in light of the proposed nodification are not given or, scenin ly, even exanined by Vepco.
CEF also regards the !!RO cafety Evaluation of Jan. 29, 1979 as ccfic' e ' 4 1 that it fails tc present an analysis of water flcz in the modified pool as prepcsed. Add-the effects cf itionally, no analycis of'n loss cf water on the fuel pccl eccling systen are presented.
CEF further regards the :!?.C Environnental Inpact Appraisal cf April 2,1979 as deficient through its superficial treatnent of the environmental effects cf the additional water to be drawn fren Lake Anna, and of the additional heat to be dis-charged to the envircnnent. We do not believe that the sta tenents : "any atmospheric effects of its operatica such as fcggi.;; and icing are u.likely to occu offsite" (sec. h.3) er "This :.tuld not have noticeable increnental effects en aquatic 550 @7
- h.-
4 biota or the environ ant" (sec. h.3) constitute sufficient analysis of
~
envirenantnal inpacts 'rithout in-depth evidence of biological and neterd,cical testing presented to support such clains. (Irwin Krcot) 1-6 CH believes that fogging and icing due to evaporative cooling of the water neccc:ar/ to remove the increased heat will have measurabh effects on the env # ron~.ent, depending cn clina, tic conditions. Also, in an unusual event v
i ret._ iring the discharge of the ser7 ice water to the ESCF, we naintain that the added heat to be discharged uculd likely affect the hunan environment, I
due to the additional evaporatien of water fren the cooling lagoons, as well as the aquatic envircnnent. The additional 5.6 nil' lion ETU/hr, to be released, ahile a niner pcrtion of the total heat discharged frca the plant, is ver/
likely to affect the oxygen concentration of discharge and cooling uater, as well as caura possible heat danage or developnental effects to ssnsitive aquatic species in the vicinity of the increased heat discharge. (Ir.in F. root) 1-7 Sane as 1-5.
1-3 Although it is inpcssible to hypothetice each and ever/ possible circunstance that wculd result in an accident such as a leak in the spent fuel pool, CE centends that the fcllo: ring scenarics represent 7er/ possible sequences of events thac w~ ' d se a leak in tne rpent fuel poc1:
(1) a dropped spent fuel cask en the new rack configuratiens at near-full capacity, as has not Lem centemplated by the Design Easis Accident. Such a drcp uculd subject the spent fuel pool to an unforeseen sudden weight load which vculd cause tr.2 racks to pull a w/ fren t".e pool attachnents and crack the pool liner at th. 11cor and/cr walle. CU centends that the chance of this accident occ=ing 1; increased by tne tuo entednents which we assume were added after the criginal
- 59) 330 y,
Q n) fm - - n g, q Q u m.
4 a
4.s a
(
..Jou
-5 construction of the spent fuel pool had been completed.
(2) An carthquake exceeding the force which the cpent fuel pool has been designed to withstand.
(3) !L1 action of sabotage, such as the use of dyn1nita or other explosives, er the introduction of a chenical conpound into the spent fuel pool itself, would cause U:e spent fuel pool to crack cr break open in ceveral places.
(h) A loss of coolent in the reactor core itself, or other serious accident which would require the reacter building to be evacuated for extensive periods of time. Without personnel in the spent fuel pool area during t;d.s period of tine, the cooling water to the spent fuel pocl could be disrupted and the means to correct the situation would be unavailable since personnel would r.ct be around to even observe the nalfunction. As a repult, the pool could overheat s
(--o. rh w cm sinx -irc,'ic~ exidation and a corresponding release of E rdrpy substantiall,-[ causing an explosion that vouac cr2.cn taw pool, breacn the
/s reactor building itself and release high amounts of radioactivity in'o the environnent.
(Debbie Bouton) 1,9 Although no specific documents were enployed in the supposition that leakage frca i the spent fuel pool 5.anld result in a neasurable rise in the pocl terperature, it is a generally accepted premise based on connen sense. Since water is used to cool the spent fuel pcal, any loss of water would necessarily precipi;ata an increase in tenperatnre.
(Debbie Scuten) 1-10 CEF contends that the spent fuel pool cooling systen would be inadequate to prevent "hrt spotc" and possible boiling as a result of tne proposed nodificatica because the L20 would allov the ncdified racks to be installed wi'h no corresponding ccanges in the pool cooling systen. The more spent fuel assenblies in tne pool a t any one tine, the greater the burden on the cooling systen to maintain an acceptable tenperature. Vepco and the ::?.C clain that the coeling g7 ster uas sufficiently 55b 23\\
cverdesigned (cr "consertatively designed") to cenpensate for tne adaitional heat Ictd without any no;iifications. Eat conserv:.tive design acide, the crisi= 1 cpent fal eccling s,c;en was desi;;nad ta accor.nodate a specific nr.ber of fuf.
asse.blies, t-ith a specific a.ount of " extra" cooling capacity to acccunt for any unforeseen circunstances. With nere spent fuel assenbli,s in the pool, placed at clocer prcxinity, the cooling systen trill not be able to maintain the sane nargin of safety in regard to the " extra" cooling capacity. As a recult, there will be a greater chance for hot spots and boiling to de7elop, as there trill be a snaller chance fer error.
(Nathan Saubernan, Debbic Ecaten) j 1-11 "liot spots" are areas in the spent fuel pool uhere the fuel ele.ents are so i
closely packed that the cooling water is unable to circulate freely and therefore cannot carry away decay heat in sufficient quantities to keep " pockets" of heat 3
4 fron developing. As a result of this heat build-up in certain areac, snall i
J explosions of radioactive stem would release radioactive e.ienents in the spent fuel area and, cubsequently, into the environment. (!!athan Saubernan, Debbie Ecuton) f Contentien 2: Radioactive Enirrions 2-1 a.
CEF intends to call no wicnesses in support of centention 2.
b.
- Ict applicable.
(Ir.lin Krcot) 2-2
- ot applicable. (Irwin Krcot) 2-3 Sane as 1-3.
2-L Sane as 1-3 2-3 See 2-7.
55U 333
i,
_7-4 2-6 1.Lquid and gaseous enisciens fr:n nacicar power plants, and fron epcnt i
fuel pools, under nornal operating conditions are routine. As nore spent fuul a.:sentlics are loaded into t10 pool, gaseous enis cions will increase cccordangly.
And as the spent fuel pool cooling uater is filtered through the pool purificatica cy sten, liquid radicactive eniscions will increase in correlatior with the increased assenblies stored in the pool. In the event of an accident, of course, these liquid and gaceous emissicas would be increased even nore.
(Debbie Souton) f 2-7 Ue believe Vepco'c analyses of radiatien released in it s Sunnary of Proposed Modifications of April 1978 to be inconplete because we see no indication that such analyses have in fact been perforr.ed in considering the posulated accidents.
Specifically, in conciderlag leakage control and. chichiing (Sunnary of Propo sed Modifications, Sec. 9.2), Vepco addresses cnly accidents involving the inlet and outtake pipes tc the pool. No consideration is given to leaks which occur lower than the 233'9" level of pipe entry, due to cracks in the liner or other causes, and the effects of the resulting lowered water level on the increased amount of fua' '" '"e poc1.
'?e are especially concerned, in this case, with gaseous radio-active enicsiens fren the pcol due to such leaks.
Fuel " c.dlin; accidents (Sann:ry of Proposec Mcdifiections, sec. 7.u) have al:o been ;_ren inadequate treatnent. No ccxideration, fcr instanca, har teen gaver tc the droppin; of an asscntly perpendi clar to the top of a spent fuel storage rack in the nodified pool, putting th at assembly int 0 01000 proxinity with nore tn'n ene stored arsenbly. Also, if an accently were to be stuck between rad:s, er between a rack and *1e wall of the pool, the radiological emissienc caused by attcnpta to renove U12t at enbly are not cbnsidercd by 'repco.
(Irvin Kr.,ot)
L s
-S-2-3 The Applicant hac failed to adequately an11yze tb liquid and gasecuc ridioactive enircions that will result fron the proposed ncdification by failing tn an alyze e
such eni:sions. The Sunnary of Proposed Fodifications states at S9.0 that "the proposed expansion of the spent fucl storage capacity could affect tt offsite radiological consequences of an incident because of. the additional increment of long-lived radioactive fission products stored in the pool. The effect of this anount of additional radioactive products en normal station operations is di cussed in Section 9.5 of this report." Fec tion 9.5 of that report, however, dis-d cusses only the rgfological inpacts of the proposed nodification on plant per-sonnel. At no point does the Sunnary, at 9.5 or anywhere else, attempt to q :tntify the anounts of radicactive effluents that will be released offsite as,. recult of the proposed nodification, or to state that there will be no such rcleases.
In 510.0, the Su..a:,r states that the environmental inpacts of the proposed decay nodification will be to increcce /
heat in the cpent fuel pcol, increace the x cunt of radioactivity stored in the pool, and result in a anall connitnant of netal resources. That section cf the cunnary nakes no attenpt to esti. ate the offsite releases of radioactive emis cions resulting frcm the proposed modification.
(Jin Tcugherty) 2-9 See pas, $6 of the Sunn,ry of Prcpered F.:dificatienc:
"S cring 2dditi:nal s, rent fuel in the pool will increase the ancunt of corrcsicn and fiscion prcduct nuclides intrcduced into the pool water....During the storaga cf spent fuel undar water, both volatile and ncn-volatile radioactive nuclides may be released to tne water frcr the surface of the essemblics or frca defects in the fuel cladaing "
(Jin Dougherty) 5% 334
-9 Centention 5: Corrosion 5-1 a.
CEF intends to call no witnesses in support of contention 5 b.
Not applicabb.
2
.. t app..licaole.
ac y-5-3 sane ac l-3; in addition: Brooks & Perkins, Inc. Spent Fael Sterage Medale Corrosion Report No. 55h ( Abstract), prepared by Leslie Mollon, direc tor, Nuclear Product Developnent, June 1,1977.
5 b Same as $-3 9
5-3 CEF maintains. that the dolle::ing decunents are deficient in regard to the Corrosien contention:
(1) 7epco's Sunnary of Propoced Modificatienc, S'ec. 9.0: Vepco fails to address the topic of corrosien on either +Jie racks or the spent fuel assenblies themselves.
- There is no analysis of the use of ::irconiun cla dding ar.d its relation to corrosion.
(2) 7epco's Sunnary of Proposed Modifications, Sec. 7 0: Venco fails to re-evaluate the efficiency of the pool purification cysten as a result of additional cerrosien and its by-products.
(3) NEC Invironnrnt:1 Inpact Appraical: The Office of Huclear Reactor Regulttien dee: not address the environnental effects of corrosien en the rackc and spent fuel as cnblies in light cf the preposed nodificaticn.
(Renee Parsons) 5-6 CEF believes that chere is a potential for increased Obrrosion on the spent fuel asse.rlolics and racks ofer the life of storc;e in the spent fuel pool because:
(1) There will be nore assenblies and a h rger number of racks stored in the 55b 33 pool. Of necessity then, there is a larger anount of naterial subject to Corrosion.
(2)Accor1ing tc the 1 raft Gen;ri:., Erc/ iron ~. ental Ir. pact Statenant (I.~Jb CL ',
Vclunc 2, "Corro:icn effects that night occtr after ler.cer storage periods red to be exanined in nuch grcater detail so that effects such as accelerated correcion, nicrostructural changes, or alterations in mechanical properties ccn te detarnined."
Cer tainly, the proposed T.cdification will allo : fcr much longer storage perieds than those originally intended for the pool; the unknown effects of corrosien af ter long-tern storage, being as yet unctudied, rny prove to include greatly accelerated cerrosion rates.
(3) Page no of Vepco's Funnary of Propoced F.odifications states, " Storing additional spent fuel in the p6ol will increase the enount of corrosion... introduced into the pool water."
(Ir ein Kroot, Debbie Souton) 5-7 Problens that CEF. 'celieves ray arice due to the increnentally increased corrosion on the spent fuel assembliec and racks include:
(1) A decreased lifetine for the stainh cs steel racks (an decreased integrity d
of these racks) cver their lifeti e.
(2) Pectriction of cooling watar flow, due to a build-up cf cerrosion frcn the 9 scenbli=s and racks, and en otner pcc1 stnctures (including t e. 211: cf tac peel), resulti.c in pcacibl "ho t spots" in the pool.
(3) An increate in worker expo:rre ;c radio - ' W s due tc cnissions released in handling defective assenblies at the tine cf e ventual renoval of the ascenblies fron the pool.
(I. in Kroot, Debbie Ecuton)
OD 33{
+
LUMTED CORISM.N'"G 4
_C_ M IFICATE CF SEE7 ICE I Hereby certify that the foregoing " Response to the NRC Staff Interrogatori.:3 and Request for Documents" has been mailed this 29th day of May,1979, by depon, ir the U.S. Fill, First Class, to the folle. ring:
recrat:ry, U.S. !?uclear Regulatorf-Comission Washirston, D.C.
20555 Attn: Chief, Doc'<eting and Service Section Michael Faupin, E:q.
Hunton & killian:
I PO Scx 1538 Richnend, Va. 23212 Steven C. Goldberg, Esq.
@lIfO 4g
' f 'p.,
Office of the Executive Legal Director
+
\\
cer:ma
'D, U.S. Nuclear Regulatory Co=ission g
um:
Washingten, D.C.
20555
,4 Jr.es Dougherty, sq.
pt AY 31 1873 >,q.
0' r
, tj FC Bex 93C6
- a. + n w"=('"aj w
o're Washington, D.C.
20005
\\'
Valentine B. Deale, Esq.
% j (; t Chairnan, Atenic Safety and Licensing Board 1001 Cennecticut Ave. DT Washingten, D.C.
20036 Pe. Ernest Hill Lv.cence Liverncre Laboratory University of California pn hy can e, a
.v
... ~u, g2_;
Live =cre, Calif. 9h553 Dr. Cuentin J. Steber Fisherias Res 22rch Institute University of Washingten Seattle, Wash. 93195 j
W&
/
n Deceran A. scuten Secreta-f, CEF s
L/b 337