ML19241B729
| ML19241B729 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 05/29/1979 |
| From: | Kunihiro D Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19241B710 | List: |
| References | |
| NUDOCS 7907230356 | |
| Download: ML19241B729 (13) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFCRE THE ATCMIC SAFETY AND LICENSING ECARD In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-295
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50-304 (Zion Station, Units 1 and 2)
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NRC STAFF TESTIMONY ON 3 CARD OUESTICNS ala) AND afb) by Dean M. Kunihiro The Licensing Board has requested response to specific questions regarding certain security impacts of the proposed spent fuel modifications at the Zion Station, Units 1 and 2.
These questions and my response are set forth below.
(4)(a) Will the proposed modificaticns of the spent fuel pool and/or operation of the Zion Station with increased spent fuel pool storage capacity:
(1) increase the potential risk of threats to special nuclear material or to Staticn f acilities?
It is not readily apparent that the increased storage capacity of spent fuel and/cr the related ccerations will increase the ;otential risk of threats t; the Zicn Staticn. Cnly if cne assumes that the increase of s::ent fuel inventcry presents a mcre attractive target for any ;otential threat will there be a corres;;cncing increase in the potential risk of throats.
In my coinicn, the likelihood of this teing a valid assumpticn is extremely lcw.
Since tne additional storage of spent fuel elements does not increase the attractiveness of the Zicn facility, as it relates to theft or sacotage of special nuclear material, it is my judcment that the proposed scent fuei pool mcdificaticn will not increase the ::otential risk of threats.
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. (2) increase the potential risk of theft of special nuclear material from the Station?
No.
To begin with the quality of the material does not lend itself to being desirable enough to " steal." Consequently, the added inventory would not increase the potential risk of theft.
(3) increase the potential risk of industrial sabotage to the Station or to the special nuclear material?
No. Sin;e the greatest inventory of dispersible radioactive material exists only immediately after refueling (30-60 days), and since the additional storage capacity will not increase this amount of dispersible radioactive material, in my judgment there will be no more radioactive material inventory that can titeoreti-cally be dispersed by a given sabotage scenario. Therefore there will be no greater potential risk of industrial sabotage to the Station or to the special nuclear material than exists presently.
(4) decrease the level of physical protecticn of the facilities or special nuclear material at the Statien?
No.
The level of protecticn is not decreased since the ievel cf protection is nct a function of :ne ;uantity of spent fuel in stcrage.
(4)(b) As a result of the prcposed modificaticn of the spent fuel col and the pecposed cperation of the Staticn with increased scent fuel capacity, will it be necessary to mcdify the Physical Security Plan, Safeguards Contingency Plan... for the 5:ation?
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. No.
The currently approved Security Plan treats the spent fuel pool as a vital area. The increased quantity of irradiated fuel which may be stored in the spent fuel pool as a result of the proposed amendment does not require an increase in the level of security protection under NRC regulations. The level of security protection required is independent of the quantity of irradiated fuel contained in the spent fuel pool. The type of material to be stored in the spent fuel pool, as a result of the proposed amendment, is the same as that presently being stored.
In addition, the proposed amendment does not change the security requirements or the structural design of the external barriers of the pool.
PRCFFESSIONAL QUALIFICATIONS by Dean M. Kunihiro My experience in nuclear safeguards began in 1976 when I was acpointed to the Office of Nuclear Material Safety and Safeguards as a Program Analyst in the Division of Safeguards.
I remained in that pcsition until January.1973 when I was acpointed to my preser.t positicn.
I am presently a Reactcr Safeguards Analyst in the Divisien of Cperating Reactors, Office of Nuclear Reactor Regulaticn', U.S. Nuclear Regulatory Cccmission.
I am cnarged with the tecnnical evaluaticn of the Security ?lans submitted cursuant to 10 CR 73.55 fcr 13 nuclear pcwer reac'cr f acilities.
Accng these facilities is tne Zicn Staticn, Units 1 and 2.
?rior to joining the Nuclear Regulatcry Ccnmission, I served in the U.S. Army for 9 years in a variety of assignments to ir :lude ccmcat inf antry cuty in '/iet Nam, and radicciology research with the Defense Nuclear Agency.
I have a 3achelcr of Science degree frca :ne United States Military Academy (1967) and a Master of Science degree in Physics fr:m the Naval Postgracuate School (1972).
I am a past member of the Health Physics and Radiaticn Research Sccieties.
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UNITED STATES CF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket Nos. 50-295 Commonwealth Edison Company
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50-304
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Zion Station, Units 1 and 2
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SUPPLEMENTAL TESTIMONY OF JOHN R. SEARS ON BOARD CUESTION J(b)
EMERGENCY PLANNING I am presently a Nuclear Engineer in the Environmental Evaluation Branch, Divi-sion of Ocerating Reactors, Nuclear Regulatory Commission.
My responsibility includes evaluating the adequacy of a licensee's plans for coping wi th e.Ter-gencie for acerating reactors. Until Novemcer 1976, I was a member of the Industrial Security and Emergercy planning Branch, D'ivisicn of Project Manage-Tent, unere my responsibilities included the evaluation of an acclicant's : Tans for caring with emergencies, anc also its clans for iriaustrial security Orc-tection cf its reactor site pursuant to i 50.3a(c) of 10 CFR Part 50.
I have reviened the licensee's emergency plan which acolies to all his generating staticns and the specific plan for the Zion staticn.
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The Licensing Board has requested the parties to respond to the following regarding the emergency plan at the Zion Station, Units i and 2.
(4)(a) As a result of the proposed modification of the spent fuel pool and tne prcposed operation of the Station with in-creased spent fuel storage capacity, will it be necessary to modi fy..
the Emergency Plan for the Station?
As explained herein, this question must be answered in the negative. The Generating Station Emergency Plan (GSEP) which is applicable to all of the licensee's nuclear generating stations, including Zion Station, and the Zion Station Emergency Plan (ZSEP), a separate plan for the Zion Station, were re-viewed and evaluatec by the staff in the U. S. Atomic Energy Commission Directorate of Licensinn Safety Evaluation Report (SER) dated October 6, 1972. Section 13.3 of tne SER (copy attached) described the basic elements of these plans and stated that they meet the requirements of 10 CFR Part 50, Appendix E.
It was further concluded that the plans provide reasonable assur-ance that appropriate protective measures can ',1d will be implemented promotly and effectively in the unlikely event of an accident having a potential effect on the health and safety of the public. Cetailed procedures to imclement tnese emergency clans are ins;ected and evaluated by field inspectors of the NRC Office of Inscection and Enforcement.
- nave :ersonally reviewed these ;ians.
The plans are designed to ccce 3 tn t e 4
consequences :f a spectrum of accidents, including tne design basis less-o#-
cociant accident anc cesign basis fuel nancling accident in the scent fuel 2001, that could result in radiological releases from tne Staticn.
The NRC staff's evaluation of tre ;otential offsite cases cue to the spectrum of acci-dents is listed in Table
- t. O of the SER. The doses for tre design basis loss-of-ccolant accident and fuel handling accident are presented belcw.
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a Course of the Two-Hou-Exclusion Accident, LPZ Boundary (415M)
(1600M)
Thyroid Whole Body Thyroid Whole Body (Rem)
(Rem)
(Rem)
(Rem)
Loss of Coolant 123 6
147 5
Fuel Handling
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<l The fuel handling accident analyzed for the SER assumed complete damage to, and release of activity from, a fuel assemoly (204 fuel rods) dropped to the bottom of the spent fuel pool imnediately after its removal from the core.
Even if 5 fuel assemblies were to be similarly damaged and the activity released, the consequences would be less than that resulting from the design basis loss-of-coolant accident. The proposed expansion doe ~ not significantly affect the as-sumptions underlying the postulated fuel handling accident or its consequences due primarily to decay of the gaseous activity in the stored assemblies, Consequently, no changes to the GSEP or ZSEP are required as a result of the proposed modification of the spent fuel pool and the proposed operation of the Station with increased spent fuel storage capacity.
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13-3 Siru l a t e r, the lion Nuclear Pcwer Plant Simulcto and at L.sselaer Polytechnic Institute's pool reactor.
Seven of the supervisory and operating personnel have had previous nuclear training and experience in the U. S. Navy.
Operators who are not required to be licensed, such as technicians and repairmen, will have attended classes or received on-the-job trair.ing in these areas required by their respective functions and respcnsibilities. All personnel will receive training in Radiation Protecticn. We conclude that the program for training Zion Sta_ ton operating personnel is adequate.
13.3 Emergencv Planning The Cocoonwealth Edison Company has prepared a comprehensive plan called the Generating Station E=ergency Plan (GSEP), which is applicable to all of Commonwealth's nuclear generating stations, including the Zion Statien. GSEP desc:ibes the applicant's e=ergency organization, and the assignments, authority and responsibilities of personnel assigned to that emergency organiza: ion.
The eajor groups identified in GSEP that would respond to an emergency at the Zion Station a re the Command Cente r, the Divisicn and the Envirens Groups.
The functi:ns of al'.
three groups are defined in CSEP.
The GSEP describes the arrangements that have been made by the applicant with Federal, S tate, and local officials and agencies to cope wi:h potential radiological e=ergencies.
The State of Illinois
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The Technical group will consist of approxt=atel-31 technical engineers and technicians.
The technical group is headed by the Technical h
3 Staff Supervisor, who exercises supervisory control over four technical a
s areas:
Radiation-Chemis try Environs, Therral, Nuclear and instru=entation.
In addition, the applicant is in the process of increasing its corporate technical support by in-house transfers and by the employment of additional i
personnel.
I The Fuel Loading group will consist of approximately seven fuel handlers supervised by the Fuel Handling Fore =an who will have a limited B
l Senior Reactor Cperator's License.
The Fuel Handling Fore =an, under the direction of the Operating Engineer, is responsible for fuel 2
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preparation, loading, unloading, in-plant transporting and shipping.
The qualifications of the manage =ent and operating staf f will =eet the =inimum acceptable levels as described in the American National Standard " Selection and Training of Nuclear Power Plant Personnel."
We conclude that, subject to the success ful ce=ple tion i
j of cpera:Or exa=inations and licensing, the staffing fc operating both Units L and 2 is acceptable.
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The Cicn Station superviscry and cperating personnel have taken the Westinghcuse Reactor Cperating Training Prcgra: conducted at Walt: M.ill and Saxton, Pennsylvania, and a: Zion Statien. Additional training was received at the Sabccck & Wilcox Nuclear Pcwer Plan:
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13-4 has the statutory responsibility and authcrity for prctecting the health and safety of the public from icnizing radiat ion.
The Illinois Depart =eric of Public Health is the responsible agency within the state organization for activating the State of Illinois Peacetime Radiological Response Plan, and is the key coordinating agency a=cng the applicant, U. S. Ccast Guard, Illinois State Police, Illinois Civil De fense, AEC, and other local, State and Federal agencies.
In addition to GSEP, the applicant has developed a separate, station ecergency plan for the Zion Station.
This plan, Zicn Station E ergency Plan (ZSEP), is cc=patible with the GSEP.
ZSEP describes the Zion Station energency organization for coping with e=ergencies.
The plan covers a spectrum of emergency conditions which may arise and the procedures to be followed. Pri=ary notification of of fsite support agencies will be through the Ccemonwealth Load-Dispatcher, upcn request frca the ZSEP Director.
The ceans for determining the magnitude of a release s provided by the preparation of relative concentration factors, precalculated and plotted X/Q graphs for es ti=ates of dcwnwind doses, hased en release rate and representative merecrolcgical conditions.
In a dditica,
twelve envirenzental surveillance sta:icas have been estabitshed, cf which 9 are cutside the plant site.
Cf fsite acnitoring equipnent and erergency supplies are available ir a mobile trailer parked a: :he Cicn metecrciogical cwer.
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i 13-5 A small infirmary is located in the Zion Station service building with first aid kits and stretchers located throughout the Zion facility.
First aid and decentamination procedures have been prepared.
For additional =edical help at the facility, two doctors, a nurse and a third physician as a consultant will be available on call for medical treatrent at the station. Offsite medical support will be furnished by either 'lictory M corial Hospital or St. Therese Hospital in Waukegan.
The two hospitals in Waukegan have established procedures for the handling of radiation casualties and have agreed to accept and treat such patients. Transportation frem the plant to the hospitals will be caken care of by the Zion Rescue Grcup or by the Safe-Way Acbulance Service in Waukegan.
Require =ents for emergency training and retraining of personnel have been addressed in ZSEP, but stronger emphasis will be placed en these requirements in the Technical Specificacicas, which will require training and retraining of personnel as set forth in AliSI-NLS.1 "Section and Training of :;uclear Pcwer Plant Persennel." Emergency exercises will be conducted at the Zion Station on a quarterly basis.
Recoverj and reentry considerations are discussed in both CSEP and ZSEP. GSE? sets forth the precedures that must be develeped fcliewing an incident and the State of lilinois respcas bility fer offsi e recovery.
ZSEP prescribes allewable dose and ccatarinatica levels during recovery and reentry cperaticas at the Zion Statien.
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13-6 We have concluded that the extensive preplannin-g for ccping with potential accidents reflected in the CSEP and ZSEF, and the arrangements made for support from both private and governmental groups outside the applicant's organization meet the requirements of Appendix E of 10 CFR Part 50 and prevides reascnable assurance that appropriate protective measures can and will be implemented promptly and effectively, in the unlikely event of an accident having a potential ef fect en the health and safety of the pub!ic.
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