ML19269C453
| ML19269C453 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/29/1979 |
| From: | Millhollin G Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| NUDOCS 7902020380 | |
| Download: ML19269C453 (8) | |
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UNITED STATES CF MERICA sff 7 4
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/C NUCLEAR REGE.ATCR': C3GESSICN OV A6
,W Eefore the Atcr11c Safety and Licensinz Ecard
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In the Matter of
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Dccket No. 50-272
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PUELIC SERVICE E1ECTRIC L GAS CCMPA 2 )
Prepcsed Issuance cf Amendment
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to Facility Operating License (Salem Nuclear Generating Staticn,
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No. DPR-70 Unit No. 1)
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CEDER CCNCERNING LICENSEE'S OBJECTICNS TO IM=:tCGATCRIES Cn November 21, 1978, Mr. arri Mrs. Alfred C. Coleman, Intervenors in the above-referenced proceeding, prcpounded a set of interrogatcries entitled "Intervencrs First Set of Interrcgatcries of the Licensee".
The Licensee objects to Interrogatcries 18,18(a),18(b),19,19(a),
19(b), 19(c), 20, 21 and 21(a) and, in part, to Interregateries 13 and
- 17. The Licensee also moves, pursuant to 10 CFR 2.740(c), fcr a protec-tive crder that the discovery not te had. The Interacgatcries read as fcilcws:
Colemans' Inter ccateries 13 Please descrite why the licensee believes that the increased spent fuel ccmpacticn and stcrage will nct affect the ccnsecuences of a spent fuel pool accident?
(see p. 21) Explain hcw the censecuences of sn accident would te affected by acts of sabotage.
17.
I in-pcol surve11ance f'nds prcble.s requi-ing repair of spent fuel rods cr racks, what are the licensee's centingency pis.s fcr re m ?.1 and repair?
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- 18. Does the page 28 reference to "two prase ficw" signify trat local boiling can occur? If so, hcw many bundles arxi fcr how 1cng would such boiling have to occur to reduce the water level to the tcp cf the fuel?
13(a). Please describe the circumstances cr situaticns wrJ.ch would lead to two prase flow.
18(b). Please provide a worst case analysis and an average cr typical case analysis for the ecolant mass flew rate fcr each fuel assembly.
19 Regardirs spent fuel ecoling capacity (at p. 30) please provide the basis for the licensee's detennination that "the spent fuel ecoling system can provide the necessary cooling fcr the nonnal annual discParge as early as 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after reacter shutdcwn."
19(a). htat is the minimum delay between a shutdcwn and full ccre discharge?
19(b). Assumirg a full spent fuel pccl (but with full c~ M = charge space available ard after shutdown) when could the core be discrarged to the spent fuel pcol and still receive adequate ecoling frcm the spent Nel ecolire system?
19(c). hYst are the voltras, masses, heat rates, flew rates, temperatures, and all other pertinent va-iables calculated and pictted as a functicn of time after shutdown? Shcw the calculaticns.
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20.
Please describe the allcwable disterticn or damage fcr fuel stcrage cells.
(see p. 33) What is the sensitivity of the K eff to darage er distertion of the cell dimensicns?
- 21. WPat are the results of the seismic ncn-linear aralysis ard structural analysis described at the bottcn of p. 34? Please provide a ecpy of the relevant aralysis and stwiy.
21(a). Similarly, please provide the results ard a ccpy of (1) the analysis described en p. 36 (" Time history aralysis"), (2) the postulated dropped fuel assembly accidents (p. ?6), (3) the cases to be evaluated regarding fuel assemblies drcpped inside the stcrage cell, ard (4) the fuel assembly drcpped frcm above tne racks but with the assumption that the assembly rotates as it drops and impacts a row of stcrage cells.
(see p. 37)
The Licensee cbjects to the seccnd sentence of Interrogatcry 13, which requests an explanation of "hcw the ccnsequences of an accident would be affected by acts of sabctage", en the g curd that no centen-tien pertaining to this subject has been ad-itted as an issue in the procee & g.
The Licensee objects to the other Inter cgatories en sub-stantially the same grcunds. Ccncerning Interrogatcries 13, 13(a), 13(b),
19,19(a),19(b) and 19(c), which elate to the ficw characteristics and ccoling capability of the eccling system fcr the spent pcc1 fuel, the Licensee notes tbat no cententicn pertaining to this matter presently is
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in the case. The same cbjecticn is made to Parts 2 thrcugh 4 cf Inter-regatcIy 21(a), which relates to accidents caused by hardling spent fuel, and Irr;errogatcry 21 and Part 1 of Interrogatcry 21(a), which relate to seismi: questiens. The Licensee cbfects to Interrcgatcry 17, which re-lates to contingency plans for removal and repair of spent fuel rods ard racks, insofar as it cencerns the reds, and cbjects to Interrcgatcry 20, which relates to distortion of fuel s crage cells. Se Colerans have not respcnded to the Licensee's moticn.
The Nuclear Regulattry Cccmission has provided in its Rules of Prac-tice standards which specifically govern the secpe of discover. Under
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10 CFR 2.740(b)(1), "... discovery... shall relate only to those matters in centroversy which have been identified... in the prehearing crder en-tered at the conclusion of... [the] prehearing ccnfe"ence.... It is not greurri for objection that the infor aticn scught will be iredssible at the hearing if the infer =ation scught appears reascrably calculated to lead to discovery of admissible evidence." In this case, the matters in centroversy are the cententicns which the Scard has admitted. Sose cen-tentions are:
Colemans' Cententions 2.
The licensee has given 1*adec.uate censideration to the occ r ence of accidental criticality due to the increased density or ccmpaction of
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s the spent fuel assemblies. Additicnal consideraticn Of criticality is required due to the follcwirg:
A.
detericraticn of the neutrcn abscrbtien raterial provided by the Beral plates located between the spent fuel bundles; B.
detericraticn of the rack structure leading to failure of the rack and consequent dislodgirs of spent fuel bundles; 6.
The licensee has given inadequate censideraticn to q1:alificaticn and testing of Scral material in the envircrment of protracted asscciaticn with spent nuclear fuel, in crder to validate its centinued prcperties fcr reactivity ccntrol and integri'y.
9 The licensee has give, iradequate censideraticn to alternatives to the prcpcsed acticn.
In particular, the licensee has not adequately evaluated altercatives associated with the Nuclear Regulatcry Ccr=issicn adcptire the "no action" alterrative fcr licensee's applicaticn, which wculd 1.:plicate the follcwing:
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expansion of spent fuel stcrage capacity at reprocessing plants; 3.
licensirg of independent spent fuel stcrage installaticrs; C.
stcrage of spent fuel frcm Salem No. I at the storage pcols of Other Nacters;
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crdering the generaticn of spent fuel to ce stcpped cr restricted (leading to the sicw-dcwn or termination of nuclear pcwer produc-tien until.ultirate disposition can te
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effectuated); and 13 The licensee has failed to give adeqwite censideraticn to the cumulative i.v acts of expanding spent fuel storage at Salem Nuclear Generating Staticn Unit 1 in associaticn with the recently filed prcpcsed amendment to the applicaticn for an operating license at the sister unit, Salem Unit 2.
(See Amendment No. 42, Docket No. 50-311, filed April 12, 1978 which prepcses modificaticns of spent fuel stcrage which the inter-venor believes are similar in secpe to the Salem Unit 1 application.)
Fcr exar:ple, the licensee assumes an increase in releases of Kr-85 by a facter cf 4.5 - due to the facter of 4.5 increase in spent fuel (licen-see's application, at 10). A similar increase, absent exceptional ccn-trols, can be expected at Salem No. 2, resulting in a cumulati":
increase in Kr-85 emissiens by a facter of 9 - almcst a fall crder cf magnitude increase.
(If similar spent fuel incraases are pcstulated fcr the ccm-panien units, Ecpe Creek 1 and 2, ncw under ccnstructicn, the currAtive increase cculd rise by a factcr of 18, or o " cst two full crders of magnitude.)
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It is evident that ncne of the abcVe cententiens relate to sabotage (Interrogatcry 13), contingency plans for rer:cval and repair of fuel rods (Interrcgatcry 17), ficw or capability of the spent fuel ecoling system (Interrogatcries 18, 18 (a), 18 (b ), 19, 19 (a), 19 (b ), 19 (c ) ), fuel hand-ling accidents (Inter cgatory 21(a), Parts 2 thrcugh 4), or seismic ques-tiens (Interrogatory 21 and Part 1 of Interrogatcry 21(a)). F.creover, the Scard does not see hcw the information requested by these Interroga-tories could, with respect to these contentiens, be reascrably calculated to lead to the discovery of admissible evidence.
Interrogatory 20, how-ever, insofar as it is concerned with allcwable disterticn of fuel stcr-age cells as it affects K eff cells, could be relevant to the Colerans' Centention 2.
This Scard must, under 10 CFR 2.740(b)(1), limit discovery to the matters in controversy. See, e.g., Allied-3eneral Nuclear Services, et al. (Farnwell Fuel Receiving and Storage Staticn), LSP-77-33, 5 HRC 489 (1977) and cases cited therein. The Scard must therefcre sustain Licen-see's cbjections to Interrogatcries 13, 17, 18, 13(a), 18(b), 19, 19(a),
19(b),19(c) and 21. These Interrcgatcries need not be erswered. Inter-regatcry 20 is proper, however, insofar as it relates to distcrtien, and must be answered to that en ent. The Licensee dces not cbject to Inter-regatcry 17 inscfar as it relates to spent fuel racks, rather than spent fuel reds.
FCR 'IFE ATCfEC SETIY MD LICEISEIG ECAED
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,, y Gary L. Milhollin, CP2L7an cated at Madisen, Wiscensin, this 29th day of Ja:Lar"/, 1979