ML19275A753

Adopts Certain Comm Ed Proposed Findings of Fact & Conclusions of Law.License Amend,Re Spent Fuel Storage Racks Replacement,Should Not Be Issued.Draft of Order & Certificate of Svc Encl

ML19275A753
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Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/25/1979
From:	Sekuler S ILLINOIS, STATE OF
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ML19275A749	List: ML19275A748 ML19275A753
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NUDOCS 7910190081
Download: ML19275A753 (60)

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

COMMONWEALTH EDISON COMPANY

)

Docket Nos. 50-295

)

50-304 (Zion Station, Units 1 and 2)

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STATE OF ILLINOIS'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW July 25, 1979 1179 161 7 91019 00 P /,

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TABLE OF CONTENTS I PRELIMINARY STATEMENT II FINDINGS OF FACT: MATTERS IN CONTROVERSY A.

Environmental Impact Appraisal B. Nuclear Regulatory Commission's " Notice of Intent" C.

Need for Power D.

Accidents 1.

Drops of Heavy Objects 2.

Pool Boiling E.

Corrosion F.

Quality Assurance G. Board Questions 4 (d) Accidents 4(h) Pool Liner Leak 4 (i) Component Cooling System Leak 2(e) Monitoring III CONCLUSIONS OF LAN IV ORDERS 1179 162

i e

a I.

PRELIMINARY STATEMENT NOTE: To promote consistency and clarity the Findings of Fact and Conclusions cf Law proposed by the People of the State of Illinois will follow the format previously presented by Commonwealth Edison.

For the sake of brevity, Illinoia has adopted some of the Commonwealth Edison Company's findings of fact.

In other cases the findings are rejected but certain of the language proposed has been incorporated into the Illinois findings.

The People of the State of Illinois (Intervenor) adopt the Preliminary Statement proposed by Commonwealth Edison Comoany (Applicant /

Licensce) Findings of Fact ]-7.

II.

FINDINGS OF FACT: MATTERS IN CONTROVERSY Intervenor adopts the Applicant's statement of matters in controversy, Paragraphs 8-17, with the following exceptions:

10.

Intervenor did not oppose the summary disposition motion regarding contention 2(n) on the grounds that the affidavit submitted by Mr. Leider in support of that motion satisfied the requirement for ALARA.

Intervenor requested that the Board allow review of the procedures to be used prior to the installation to assure that any changes from the procedures outlined in the affidavit would also meet the ALARA standard.

Thus the Board granted the opportunity to present argument as iadicated by Applicant.

1179 163

14.

No evidence was presented at the evidentiary hearings in regard to contention 2(d).

17.

The Intervenor adopts only the first sentence of Applicant's Finding #17.

1179 164

Contention 2A:

The State of Illinois contends that approval of the proposed license amendment would be a major action of the Commission significantly affecting the quality of the human environment in Illinois.

The National Environmental Policy Act of 1969, as amended, requires the Commission to submit ;n environmental impact statement with respect to the proposed license amendment.

The State adopts Licensee's Proposed Findings 50. 18 and 19.

1.

The NRC Staff represented in papers filed in this proceeding in September 1978 that it did not plan to perform an Environmental Impact Statement on the proposed spent fuel pool modification.

By fall of 1978 the Staff essentially completed its review of the environmental effects caused by licensing the expanded spent fuel pool, and recommended that tha licensing would cause no additional significant environmental effects, obviating the need for an Environmental Impact Statement.

(Zech, Tr. 614).

2.

The Staff issued its Environmental Impact Appraisal in March 1979 (Zech,Tr. 613).

3.

Mr. Zech supervised the preparation of the Environ-mental Impact Appraisal on the proposed spent fuel pool modification.

He also supervised the preparation of the Environmental Impact Appraisal on the spent fuel pool modification proposed by the Public Service Company of New Jersey for its Salem plant. (Zech, Tr, 626)

Mr. Zech explained that it had been his intention that sections of the two Environmental Impact Appraisal's be identical (Zech,Tr-637) and that he expectec other paragraphs to be fairly close to being 1179 165

identical.

(Zech,Tr. 638).

The wording of other paragraphs in the Zion and Salem Environmental Impact Appraisal's that dealt with similar subject matter were for the most part identical.

(Zech, Tr. 639).

4.

The Board finds that the NRC Staff's Environmental Impact Appraisal was not an adequate, independent, and site-specific assessment of the environmental impacts of the proposed modification.

The decision not to perform an Environmental Imoact Statement was made in September 1978; the Environmental Impact Appraisal was pre-pared after that decision had already been made.

Contention 2B:

Approval of the amendment request would be con-trary to the NRC policy position on spent fuel storage which prohibits non-emergency licensing of any existing storage facility prior to the adoption of an official long term policy regarding the permanent storage of spent fuel.

See " Intent to Prepare Generic Environmental Impact Statement of Handling and Storage of Spent Light Water Power Reactor Fuel," 40 Fed. Reg. 42801, September 16, 1975.

(1)

There is no emergency need to rerack as the existing storage pool contains more space than is necessary to accommodate full core discharge.

(2)

The existing pool is able to accommodate normal refueling discharges until 1981; therefore, failure to grant the application at this time coses no threat of imminent shutdown of the facility.

The State adopts Licensee Proposed Finding No. 37, 33 and 36, 1179 i66

5.

'Jith regard to the fourth f actor set forth in the Commission's Notice of Intent, the State in its contentions and the Board in its own questions have raised technical issues for resolution in this proceeding.

The testimony demonstrates that the performance and safety of the racks over their expected lifetime cannot be assured without further testin7 and ex,2rience with the constituent materials in the spent fuel pool environment.

(Findings

' No77,83). These issues cannot, therefore, be resolved within the context of the review of this license application.

6.

Tes tifyi'g on the fif th f actor, Mr. Plimi stated that the acditional occupatignal exposure would be well within 10 C.F.R.

Part 20 limits, should the reracking begin af ter the S^ptember 1979 refueling outage.

(Plimi prepared testimony at 6, Tr. 677)

The Bo.rd finds, accordingly, that deferral of the spent fuel pool modification will not adversely affect the public interest in terms of occupational exposure.

7.

There are no compelling reasons why the proposed mod-ification should proceed at this time.

Rather, the unresolved technical issues presented in this proceeding (Proposed Finding No. 5) provide compelling reasons for deferral of the pool modifica-tion.

The Board finds that a deferral of this licensing proceeding for up to three years would be in the public interest.

Contention 2C:

Should it be necessary to shut down the Zion facility, pending the development of an al-ternate, away from reactor facility, the An,

plicant has not shown that the community cur-rently being served by Zion would be adversely i179 i67

affected econcaically or by experie.cing loss of electricity.

(1)

The Applicant has not explored the possibility of meeting current demand by increased use of underutilized fossil-fueled plants serving the Edison syste :.

(2)

The Applicant has not considered cur-tailing the output from Zion in conjunction with a conservation program and c]ordinated rate structure which would reduce the demand for electricity in the area served by Zion.

The State adopts Licensee Proposed Finding No. 49, 53 and 55.

8.

The Zion nuclear units are utilized in a baseload manner because of their low operating cost.

(Kraatz preoared testi-many at 4, Tr. 815)

The types of units most affected by energy conservation are oil and coal fueled units because they are used for peak loads rather than base loads. (Kraatz, T-823).

In 1979, 28% of Licensee's total generating capacity is nuclear, but by 1985, 48% of the total generating capacity will be nuclear.

As the per-centage of total generating capacity that is nuclear increases, some of that nuclear capacity will be used for peak loads as well as for base loads.

Energy conservation will then affect the nuclear units used to satisfy peak load demand. (Kraatz, Tr.-

826, 827) 9.

Contention 2(c) raises issues that Licensee has not satisfactorily answered.

Licensee contends that because they are base loaded nuclear plants are not affected by energy conservation measures.

Mr. Kraatz, however, testified taat Licensee's nuclear plants cill be used for peak 1 cads by 1985.

Thus Licensee's need for pc. er generated by Zicn Station may be affected in the near future t\\19 \\68

by its adoption or rejection of conservation measures, 10.

Licensee has conceded the elasticity of demand for electric power by admitting that its one special rate program is intended to encourage energy conservation (Kraatz prepared testimony at 4, Tr. 815).

Nevertheless Licensee still maintains declining block rate structures for commercial and industrial users, (Intervenor Exhibit 4).

11.

The Board finds that Licensee has not sustained its burden of proof on Contention 2c.

It has shown that curtailment of power from Zion would have a substantial adverse economic impact on the community.

While the replacement costs if both Zion unit a :ere shut down would be between $240,000 (Toalston prepared testimony at 2, Tr 846) and $441,000 (Kraatz prepared testimony at 2, Tr. 815) per day, the replacement cost should Zion's capacity factor be reduced from its current 67% to 40% would be only $178,000 per day (Kraatz af fidavit).

The production cost of operating Zion at a 40% capacity factor is approximately 8.1 mills /kwh (Kraatz, Tr.

835), which ccmpares favorable to the cost of other energy sources, (Kraatz prepared testimony, Attachment following p.5, Tr. 815) 12.

Licensee has not adequately explored energy conser-vation as a means of reducing demand for power from the Zion Statien.

The evidence suggests that operation of Zion at a reduced capacity factor is economically viable, and that reduction in demand through conservation would allow suc'r Jafaced operation.

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13.

The Board has found that a delay of the proposed mor iiication would be in the public interest.

This delay is also ci..aseled by the Licensee's need to explore further conservation measures that may reduce its need for power from the Zion Station and defer or eliminate any need to modify the spent fuel pool.

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D.

Accidents 1.

Drop of Heavy Objects Contention 2(f) states:

There has been insufficient development of credible accident scenarios.

For example:

(1)

There is insufficient documentation to establish the methods by which the Applicant will positively prevent the movement of heavy objects, such as shipping casks or empty fuel racks over the pool during modification; thus accidental droppings of such heavy objects, which could lead to un-acceptable damage to spent fuel or the pool liner and consecuent release of radionuclides, has not precluded.

(2)

There is insufficient information regarding the metheds by which accidental damage to stored spent fuel assemblies will be prevented during the installation of the new poisoned spent fuel storage racks.

14.

Applicant's witness, Mr. John P.

Leider, former plant superintendent at Zion, described how the proposed rack replacement was being developed.

He sta ed that no racks would be carried over the spent fuel (Leider, prepared testimony at 3, Tr. 7 58 ).

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5 9

15.

Some of the rack movement will be controlled by crane interlocks which prevent loads fror moving over the pool.

At other times, to allow movement over the pool, the interlocks will be bypassed.

At that time writte. procedures are planned to prevent movement of the racks over spent fuel (Id.)

Reliance is placed on administrative controls because it is difficult to design a scheme of mechanical incerlocks to handle crane movement in many directions [Leider, Tr. 1390-91) 16.

The written procedures for rack installation and the written procedures which will set forth the administrative controls had not been developed at the time of the evidentiary hearing (Leider, Tr. 1900-1902) 17.

Applicant testified that there would be no casks carried over the pool as there are no casks in the plant and there are no plans to bring any into the plant (Tramm, Tr. 1903).

18.

The NRC Staff testified that it plans to restrict the =cvement of heavy loads over the stored spent fuel.

During the proposed modification the Staff would require notification of plans to handle heavy loads in the vicinity of the spent fuel pool.

The Applicant has committed to notify the NRC as requested.

(S taf f, Ex.

lA S 2.3). There was no specific testimony as to what NRC action would be taken upon notification that a heavy load would be lifted in the pool area, although Mr. Kohler, resident SRC insnector at Zion did state that commitments can be enforced (Xchler, Tr. 1972) and that 1179 172

he would stop the job if he detected a heavy load being above the core.

(Kohler, Tr. 1975).

19.

The Staff intends to issue a technical specification which will preclude handling loads of greater weight than a single fuel assembly plus the spent fuel handling tool over stored spent fuel. (Staff Ex. lA, S 3.2).

The technical specification is in draft form.

It is intended to be included in any license amendment issued for the proposed rack replacement.

20.

Applicant's contractor, Nuclear Services Corporation has analyzed the consequences of dropping a single fuel assembly onto a rack.

The analysis generally addresses the consequences in terms of criticality.

(Hossain, prepared testimony,Tr. 1700; Ap. Ex. 4 S3.4.3.5 and 3.4.4).

The assembly is hypothesized to drop from a height of 24 inches because that is the maximum height a fuel assembly can be carried over the pool when the crane interlocks are on.

(Hossain, prepared testimony, Attachment B, Tr. 1700).

21.

When there are no interlocks on the crane it will be possible to lift loads higher than 24 inches above the pool.

(Leider, Tr. 1899-1900).

22.

Applicant's witness Leider testified that if a rack fehl into the pool, the greater the height from which it fell the larger the impact en the pool would be (Id.)

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23.

Administrative controls have been proposed to control lifting heavy loads more than 24 inches above the pool, but no technical specifications were envisioned by Applicant to be part of those controls,(Leider, Tr. 1901).

24.

Although Administrative controls were proposed as the means by which certain loads would be precluded from being carried over the pool, neither the procedures describing the rack placement, nor the controls had been developed at the time o f the hearing -(Leider, Tr. 1900-1902).

25.

It is credible that a dropped' rack could tear the stainless steel pool liner.(Tramm, Tr. 1903, Zudans,Tr. 1970).

26.

Although Staff and Applicant have made assertions that a rack drop would not cause major damage no analysis was made of this accident.

27.

Should a heavy drop cause the stainless steel pool liner to be torn, water could leak from the pool at 288 gallons per minute and the pool could drain in 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />.

(Tramm, prepared testimony at 10-ll,Tr. 564: Tramm,Tr. 1917).

23.

Leakage would drain frcm the pcol through six 1 1/2 inch drain lines (Tramm,Tr. 1904, 1912).

There are no valves on those drain lines.

Either the drainage pipes would have to be crimped mechanically or the leak would have to be plugged with metal or plastic sheeting to cut off the ficw.

(Tramm, prepared testimony

.m.,

m.

..= c,.,

1179 i74

29.

Based on the foregoing, the Board finds that all credible drop accidents associated with the proposed rack replacement have not received sufficient attention to assure the public health and safety.

The major concern would appear to be the drop of a rack onto stored spent fuel.

We find that the administrative controls and Technical Specification described by the Licensee and the Staff, are likely to be less positive and less predictable than the mechanical schemes normally employed.

We expect the Licensee's management and the NRC's Office of Inspection and Enforcement to devote sufficient attention to the rack replacement operation to confirm that the administrative controls and Technical Specification are follosed during the rack replacement.

However, we also find it desirable to have the Applicant devise a scheme for mechanically interlocking the crane movement during installation, to prevent movement of the racks over spent fuel.

ii.

Pool Boiling Contention 2 (g) states:

The Applicant's discussion of spent fuel boiling is inadequate in that (1) there is no consideration given to the possibility that the pool might boil, and (2) there is no discussion of possible damage to fuel cladding or of the consequent release of radionuclides under such conditions; therefore, there is no assurance that public health and safety will not be endangered.

1179 17

In addition, the heat removal capacity of the spent fuel cooling system has not been shown to be adequate to support the expanded pool capacity.

30.

Intervenor accepts the Applicant's proposed finding 84 as it described the Zion spent fuel pool cooling system and rejects all other proposed findings on this issue, numbers 83 and 85 to 108 'nd in their place offers the following proposed findings.

31.

Applicant utilized two computer programs to compute pool heat and cooling: POOLHT, which analyzed maximum bulk pool temperatures,. (Licensee Exhibit 4) and CIRCUS, which calculated natural circulation flow rates within the pool (pd.)

32.

For le purposes of its PCOLHT calculations, the Applicant's assumption was that the temperature of the ;omponent cooling system water at the inlet to the spent fuel heat exchangers is 80 F.

On cross examination the Applicant's witness admitted that the corresponding temperature assumed in the FSAR is 95 F.

(Tramm, Tr. 1454-5).

Tramm testified that if the Applicant had used a base of 90 instead of 80 for the component cooling water temperature that the pool temperatures would have been calculated at about 15 F higher (Tramm, Tr. 1459-60).

1179 176

33.

The Board finds the discrepanc3 between the temperatures assumed by the codes POOLET and CIRCUS and the FSAR creates some doubt as to the accuracy of the Applicant's calculations regardinc c.ool boilina..

34.

According to Licensee's witness, Mr. Tramm, the perform-ance of the spent fuel pool cooling system is related somewhat to the other heat loads which are transferred by the component cooling system in that such performance is a function of the temperature of the component cooling system water.

Postulated plant upset conditions such as a loss of coclant accident ("LOCA") could increase the tempe-ratures in the component cooling system and therefore possibly cause a temporary reduction in spent fuel pool cooling (Tramm, prepared testimony at 29, Tr. 564, Tr. 1460-1).

Neither POOLHT nor CIRCUS calculate d the temperature of the component cooling system during a

LOCA, nor das there an analysis of the effect of a LOCA in the reactor on the spent fuel pool cooling system (Tramm, Tr. 1464-66).

35.

Intervenor's witness Dr. Marvin Resnikoff testified that the computer programs used to calculate pool heat are based on asssumptions that are not sufficient to forecast v_rects of LOCA in the spent fuel,ccol.

(Resnikoff, Tr. 1574).

Resnikoff agreed with Tramm's testimony that a malfunction of the component cooling system could lead to loss of pool ecoling (Resnikoff,orecared testimony at 5, Tr. 1528).

1179 177

36.

Tramm testified that single failure in the spent fuel pool cooling system could cause both cooling trains to malfunction (Tramm,Tr. 1441).

Both Staff and Applicant concede that a single failure of the inlet pipe which returns water from the spent fuel cooling system to the pool is a credible event. (Lantz,Tr. 1677; Tramm,Tr. 1514).

37.

The failure of both cooling balns to operate would cause the pool to boil in 6-12 hours, depending on the temperature at the point of LOCA in the spent fuel pool, unless sufficient cold water was added'to pool.

(Tramm, prepared test at 20-21,Tr. 564; Lobel et al, prepared testimony at 3,Tr. 1632; Resnikoff, prepared testimony at 2, TR. 1523).

38.

Resnikoff testified that localized boiling could take place where a full core discharge followed a refueling discharge by 10 days or less and only one cooling train was operative.

Localized boiling can also be caused by blockage of the hole in each storage tube which allovs entry of cooling water.

(Resnikoff prepared testimony at 9-10, Tr. 1528).

39.

On cross examination Dr. Resnikoff agreed that the question of pool boiling would be negated if there was a guarantee of a continuing source or readily available makeup water for the Zion spent fuel pool,(Resnikoff,Tr. 1556) but Resnikoft questioned whether the sufficient quantities of makeup water would always be readily available.

Resnikoff raised questions about mechanical failures which could prevent the makeup systems from operating

( Re s nie:o f f, Tr. 1557.

If those events occured it could beccme 1179 i78

necessary to use some method such as cross ties or pumping water frcn the Lake, which necessitate human intervention (Resnixoff,m..

1557-3). Resninoff questioned whether it would always be possible for manual methods of supplying makeup water to be used.

(pi.)

40.

One possible event that could preclude the entrance of workers into the pool room to provide makeup water would be the presence of radioactive steam or condensates in the spent fuel cool area.

Staff witnesses testified that if boiling were to occur, some non-violatile radioactivity normally present in the pool water could be entrained in water droplets in the air above the pool.

(Lobel et al., prepared testimony at 6, Tr.1632).

These droplets could also condense out on surfaces on the fuel building (Id. ) The Staff opined that workers would be able to enter the pool area.

Lcbel et al,Tr. 1652).

But on cross examination it was shown this cpinion was based on mere speculation as no calculations had been per-formed (Lobel et al, Tb 1651-2).

The Staff witnesses did state that access to the area could have to be controlled -hould such an event cCCur.

41.

In the event that boiling continued for a pericd of tim' access to the pool area would become even mora difficult because high humidity would disable the prefilters and HEPA filters in the building's filter system, thus the additional radioactivity wculd not be removed from the environment of the pool building (Conahew, Tt.1673-32).

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42.

Staff witnesses testified that boiling in zhe pool woulf be in the nucleate mode (Lobel et al, prepared testimony a: 1, 77,1632).

Dr. Resnikoff testified that localized boiling and bulk paci boiling could both occur in a pool where cooling were not available.

[Resnikoff, prepared testimony at 5, T r.15 2 8, Resnikof f T r.

156 9).

Resnikoff testified that the effects of unchecked bulk pool boiling would lead to uncreased hydrogen in the fuel building.

Potentially a hydrogen explosion could occur and the effects of such an explosion could include release of radioactivit; into the environment surrounding the station.

43.

Resnikoff hypcthesized that a zirconium / steam explosion or other major accident in the nuclear facility could prevent workers from getting to the pool in order to supply makeup water.

He there-fore recommended total automation of all makeup water systems to

'ssure that the pool heat would be maintained below the boiling level (Resnikoff,Tr. 1570-71).

44.

The Board requested information about the location of valves which would make water available in case of overheating.

The Staff's witness Lantz tectified that valves could be reached without going past the pool by entering the fuel building on the ground level.

The valves are located on the lower level of the same builling that houses the pool. (Lantz, T 'r.16 8 3 ).

1179 i80

45.

Resnikoff reiterated his concern that workers would not be able to enter the building at all under certain extreme circumstances such as a LOCA occurring in the reactor.

46.

NRC Staff and Applicant's witnesses testified that under certain conditions the temperatures in the spent fuel pool could rise sharply, yet would remain below the Boiling point. Staff witnesses estimated that the pool could heat to 170 with one cooling train out (Lobel, et al., prepared testimony 8-9, Tr.

1632).

Tramm estimated the pool could reach 180 with one cooling train out (Tramm, prepared testimony at 18, Tr.564).

These temperatures correspond to those cited by Draley in his recitation of conditions that would lead to accelerated corrosion in Boral.

(see S E infra).

47.

The Staff testified that cumulative spent fuel pool experience has shown that no commercial water reactor fuel has yet been observed to develop defects while stored in spent fuel pools under normal spent fuel pool conditions.

(Lobel et al,repared testimon, at 2, Tn 1632)

No evidence was put forth about the reaction of fuel stored under abnormal boiling or post-boiling conditions, or at conditior such as those hypothesized in the Zion pool when one cooling train becomes inoperative.

Nor was there any testimony regarding the history of Boral tubes stored in any spent fuel pool.

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48.

The effects of Boiling on the corrosion of the Soral was alluded to in the testimony of Dr. Draley and Almeter (See SE infra).

Accelerated evaporation would tend to concentrate boric acid in the pool and lower pH (Lantz, Tr.1664).

This condition combined with temperatures of 170 and higher can lead to accelerated corrosion of the aluminum matrix and clad of the Boral.

(See S E, infra).

49.

Applicant's witness did not calculate time it would take for all water to boil off, or the consequences of pool boiling in terms release of radioactivity or the possibility of exothermic reactions.

The staff and Mr. Tramm all testified that it was not necessary to do such calculations because in their judgment the events were not credible (Staf f, Tr.165 5) (Tramm,1655) Tr.

1486-7)

Ecwever the Staff testified that the rate of boil off could be 1/2 1/hr and it would take 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> for the pool to boil dry (Lantz, Tr.1641) 50.

In response to a question from.he Board, the St.af f testified that boiling would have no effect whatever on the neutron absorbing material Boral present in the proposed storage racks (Lantz, Tr. 1683-4).

Boiling would tend to increase the concent ation of boron present in solution in the pool water, since the water would boil away,but the boron would remain (Lantz, T'. 1664).

Licensee's expert wit' ness, Dr. Draley testified that if higher concentrations of boric acid were continued for periods of at least two weeks, they

\\\\79 i82

could have any possible effect on corrosion of the T.etals within the stsrage tubes (Draley, Tr. 1324-1327).

Accordingly, boiling probably will not increase the risk of criticality in the spent fuel pool; unless, possibly, there is sufficient heat to cause overheating, fuel clad failure and possible reconfiguration of the fissionable material.

51.

The Board believes Intervenor has raised a valid concern that the pool boiling / loss of water accident represents an accident with possibly serious consequences which has not yet been analyzed by the Applicant and Staff.

According to Dr.

Resnikoff, there would be a critical period o three to six days to add water to the pool to prevent this occurrence.

Although the supplies of makeup water at the Station are adequate for this purpose, Dr. Resnikoff has raised a question whether human intert.ention to add makeup water would be possible under all circumstances.

The Licensee and the Staff have testified that such~ intervention would al, cays be possible, but have not conducted the analysis to prove their assertions.

Thus, the Board requires that the Applicant conduct an analysis of the spent fuel pool loss of ater accident and append it to their application.

117")

183

E.

Corrosien Intervenor's contention 2 (e) (3) and (4) state:

The amendment request and supporting docu-mentation do not adequately discuss monitor-ing procedures.

In the light o f the proposed modification and long term storage of nuclear spent fuel the Applicant should clarify the following:

(3)

Methods for detecting the loss of neutron absorber material and/or swelling of stainless steel tubes in storage racks.

(4)

Details of a corrosion test program to monitor performance of materials used in the construction of racks.

Intervenor's contention 2 (h) states:

The amendment request and supporting docu-mentation have not analyzed the long term (including storage during the operating lif ctime of the reactor) electrolytic corrosion effects of using dissimilar alloys for the pool liners, pipes, storar racks and storage rack bases, such as the galvanic corrosion between unanodized aluminum as is used in Brooks and Perkins storage racks, and the stainless steel pool liner.

Intervenor's contention 2 (i) states:

The Applicant has not discussed whether the proposed modification and long term storage may cause the following effects on the stored fuel:

acclerated corrosion, micro-structural changes, alterations in mechanical preperties, stress corrosion, cracking, intergranular corrosion, and hydrogen absorption and precip-itation by the zirconium alloys.

Intervenor 's contention 2 (j ) states:

The amendment recuest and supporting focumen-tation do not give sufficient data to fully assess the durability and performance of the Ecral-stainless steel tubes hich form the spent fuel storage racks:

1179 184

(1) there is inadequate analysis of the corrosica rate of the tubes.

(2) there is no calcalation of the effect of water chemistry on the Boral within the stainless steel.

(3) there is no mention of the possible swelling of Boral within the stain-less steel tubes, a condition which could effect, among other things, re-moval of fuel assamblies from the racks.

Intervenor's contention 2 (k) states:

The amendment request and supporting docu-mentation do not consider possible degener-ation of the Boral density due either to generic defects or to mechanical failure which would diminish the effectiveness of Boral as neutron absorber, thus leading to criticality in the spent fuel pool.

Intervenor adopts Applicants finding No. 110.

Intervenor's reject the remainder of the Appli-cants Proposed Findings of Fact on the issue of corrosion, Nos.

109 and 111-133 and sets forth its own findings on this issue.

Applicants presented Dr.

A.

B.

Johnson, Jr.,

as a witness on corrosion of fuel and metals in the spent fuel pool, and effects of vented racks on any corrosion.

Dr Joseph E.

Draley testified to corrosion of the Boral and the corrosion test program.

NRC staff testified on all the contentions regarding corrosion.

52.

Dr. Johnson is known as an expert in the behavior of spent fuel in sto rage pools, primarily because he has authored 2 articles in the area. (Johnson prepared testimony, Tr.10 5 7).

On cross examination 1179 185

Dr. Johnson admitted that most of the in f o r.?.a tion in his studies came frca third parties, not from personal knowledge (Johnson,TL. 1074-5, 1081-2, 1033-9).

Dr.Jchnson also admitted that most,f the data upon ehich he has based his assessments of long term integrity of fuel cladding was acquired through visual inspections, and visual inspection can detect only advanced stages of cladding degradation (Jchnson, prepared tes timony, Attachment 3 at 167, Tr.10 5 7 ; Tr.10 7 2-10 7 5 ).

53.

The data base for all physical testing of spent fuel cited by Dr. Johnson, consists of a total of 9 spent fuel rods, tested in Great Britain.

No other data on spent fuel rodsare yet available (Johnson, Tr.1077-8).

The data cited for rates of fuel failure and embrittlement are speculative based on developing experience, not broad previous experience. (Johnson, Tr. 1039).

54.

No tests or observations have involved fuel stored in Brooks and Perkins racks, vented or unvented.

55.

Although Dr. Johnson concludes that there is an adequate basis at this time to proceed with long-term storage of spent fuel in a pool environment, he expressed concern that surveillance should continue to be provided #or the spent fuel over whatever time period the spent fuel will be stored (Johns cn, Tr. 1113,1117).

The NRC Staff is in agreemen t ' lith ~. Johnson (Almeter and Lantz, prcpared testimony at 9-11, Tr. 1141, 1149).

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\\86

56.

The Board finds, therefore, that the State's Contention 2(i) has been answered sufficiently to permit the addition of a greater volume of zirconium-clad fuel to the Zion spent fuel pool without undue concern for cladding corrosion and degradatica effects over the short term, less than forty years.

However, the Board finds that there is insufficient data to substantiate any claims regarding fuel stored in Brooks and Perkins boral tubes for a period of forty or more years; therefore, licensing should be limited to the shorter period of forty years or the life of the reactor.

57.

In its " Order following Prehearing Conference" dated January 19, 19i9, and again at the hearing, the Board requested information regarding the effects of vented racks on the storage of spent fuel. (Tr. 1100).

58.

On cross examination Dr. Johnson testified that damaged fuel could give off helium as well as.ot5ar gases.

Without analysis one cannot determine whether the gas bubbles were helium from leaking fuel or hydrogen from a rack. (Johnson, Tr. 1084-85).

Johnson testified that krypton-85 is among the gases that can be released by leaking fuel.

Krypton-85 is difficult to monitor. (Johnson, Tr. 1116).

Apolicant's witness Nestel, testifying in response to Contention 2(e),

stated that noble gases, such as krypton-35, could only be detected by the final effluent monitor.

Krypton-85 woulf not be detected in the spent fuel area partly because it.could be 1179 187

difficult to get an air grab sample that could accurately indicate the source of the leaking gas.

It would not be possible tc deter-mine, at the final monitoring point, whether the gas came from defec-tive spent fuel or from another source, such as the reactor.

[Nestel, Tr. 995-6].

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s 59.

Neither Applicant nor staff presented evidence onahowsthe vented rack design would effect corrosion of fuel and racks.

Witness Johnson was unprepared to answer a question relating to changes in the rack design and corrosion.

Although he said he could not see the relationship, he admitted he had not studied the question (John son,

Tr. 1099).

60.

The Board finds that the use of vented racks, which exhibit bubbling activity, combined with the lack of monitors and the inability to sample air for noble gases in the spent fuel pool area may lead to a masking of the existence of defective fuel lea %ing radioactive materials.

61.

Dr. Draley was called by Applicant to testify about corrosion in the Boral.

Dr. Draley stated in his testimony that he has done some short term experiments on corrosion of Eoral in the early 1960's.

The tests lasted only a few weeks and man. of the fetails cere lost.

':o of ficial report cas ever made of the results of these e::periments.

These experiments cere

.ever folicwed up.

Crale. has d:ne nc research or Ecral since these earl tests.

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\\\\19 \\88

action between Boral and stainless steel except for preparing for this hearing (Draley, Tr. 1292-1296).

Draley has done no research specifically into the behavior of materials in spent fuel pools (Id. at 1296).

62.

The Board finds that Dr. Draley's expertise in the area of aluminum corrosion may be helpful in assessing some of the contentions at issue in this hearing, but his expertise in the area of Boral deterioration is more limited both by lack of available data and lack of personal research experience.

63.

Dr. Almeter was presented by the NRC to be an expert on corrosion generally.

On cross examination he stated that he had no personal experience with Zirconium and that he had done no corrosion stork with Boral. (Almeter, Tr. 1146-7).

He has done neither destruc-tive or non-destructive examination of spent f uel ( Alme te r, Tr. 1148-9).

Almeter stated most of his knowledge of the spent fuel corrosion field came from literature searches and previous research work on materials he thought were similar to those used in the fuel and in the Boral racks (Almeter, Tr. 1146).

Almeter's written testimony is based in large part on his reading of reports by Draley and Huddle.

These studies were done 10-25 years ago ( Almeter prepared testimony, Tr. 1141; Almeter Tr. 1201, 1203, 1204).

The Huddle report was " theoretical";

based on no actual experiments or statistical sample.

(Almeter, Tr.1203)

Although Almeter is supposed to be an expert in the spent fuel area

e "as had this NRC assignment for just over one year and he admits "e has not fisited all the pools he has been "in col'ced

.-ith" in his cacaci '. as 52C e,uluator (Almeter, Tr. 1147).

~

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1179 189

64.

Based on his knowledge of spent fuel pcols Almeter testified that he found no objection to Dr. Johnson's testimony.

65.

The Board finds that as Dr.Almeter's knowledge of corrosion in spent fuel pools is based primarily on reading reports of others, his experience in this area is neither e, _ensive enough nor specific enough to give weight to the opinions presented in his testimony regarding corrosion ofstrcalloy or Boral in the spent fuel pool.

66.

Galvanic corrosion will occur between the stainless steel and the Aluminum in the Boral racks (Almeter/Lantz prepared testimony at 8, Tr. 1141; Almeter, T r. 1145; Draley, prepared testimony at 5-7, Tr. 1290).

Dr. Almeter stated that thereis a major difference in electric potential between aluminum and stainless steel and therefore galvanic corrosion will occur between the aluminum cladding in the Boral and the stainless steel tubes which encapsulate the Boral. (Almeter and Lantz, prepared testimony at pp.

3-9, Tr. 1141).

Dr. Draley agrees on this point. (Draley, prepared testimony at 5-7, 9,

Tr. 1290).

67.

General corrosion of the Aluminum in the Boral will pro-habi; take place within the first 5 days of immersion (Almeter, Tr.

1202-3, 1239-40. 1250).

Dr. Draley states that one can expect some p it tin g of the edges of the Boral plate and perhaps the 1100 aluminum claffing ehich forms the cutside layer of the 2cral ' tere the ele::rical

\\19 \\90

c:ncac

/ich the stainless steel tube is good. (Draley, crepared testincny at 5-6, 10, Tr. 1290).

A 63.

Although Draley and Almeter tended to minimize the serious consequences of pitting in the Boral, the State of Illinois introduced into the record evidence of testing which indicates that the pitting problem may not be fully understood.

During an in camera session Intervenor questioned Dr. Draley about several proprietary re-ports describing galvanic corrosion experiments conducted by Brooks and Perkins, Inc., the manufacturer of Boral, and by Eattelle, Columbus Laboratories for Brooks and Perkins (Interveno r 's In Camera Enhibits 1 and 2).

The Ercoks and Perkins report (Intervenor's Ig Camera Exhibit 1) contains a conclusion that maintaining a significant oxygen concentration in the water surrounding the Eoral could lead to unaccep-cable corrosion behavior.

Probably on the basis of this research the Licensee changed its rack design so that the vent holes through the stainless steel tubes are located only et the top of the tubes.

This chanc.e will limit the amount of oxv.9en bearinc. water in the tube.

(Dralev., --In Camera Tr. 1342-3).

On cross examination Intervenor also questioned Dr. Dralsy on the Battelle, Columbus report ( Intervenor's in Carera Exhibit 2) which reports experiments in which a high rate of galvanic attack of Eoral in a concentrated boric acid solution was chserved.

Dr. Draley testified that this experiment did not influence

.t i s testimony very strongly because the boric acid solution invcived

_n the enperi9.antas quite a bit more aggressive than the conditiens

- che Iicn spen fuel pool.

~herefore Dr. Drale; testified than the

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69.

Dr. Draley did not deny that the results of the Brooks and Perkins and Battelle-Columbhs tests were accurate.

In fact his own experiments showed similar results.

Of these Draley testi-fied that it was his recollection that Boral subjected to high tempera-tures (about 300 C) would swell, blister andultimately disintegrate because a protective film of corrosion would be unable to form.

Draley also testified that an aluminium clad would not stop disinte-gration of the type described. (Draley, Tr. 1293-4).

70.

In formulating his opinion as to the relationship between the high corrosion rates seen in the recent tests and the performance of Boral racks in the Zion spent fuel pool Draley did not cnnsider abnormal conditions that could credibly occur in the pool. NRC Staff and Applicant have both testified that the loss of one cooling train could boost pool temperature to 170* - 180 :

(See SD (ii) supra).

It has also been calculated that a loss of coolant accident could lead to pool boiling and consequent evaporation of water and concentration of the baron to create the higher temperature and lower pH solution which would lead to accelerated corrosion (See SD(ii), infra).

71. Another means by which pH could be raised was suggested by Applicant 's witnes s,Mr.

Tramm, who stated that in the event of an increase in the current leakage rate from the pool it might beccme

.ecessar; to lower the level of the pcol aater.

\\\\19 \\92

Dr. Draley testified that lowering pool water would increase concen-traticn of Boron in pool, but unless the pH in the Boron tubes were lowered there probably would not be a great e ffect over a short period of time.

However,when asked if the lower pH in the pool would have no effect on the metals in the tube,Draley admitted that given a "long enough time " there would be an effect. (Draley, Tr. 1325-6).

Draley hypothesized that a week would be too short a time for accelerated corrosion; but within a month a significant difference in concentration would become observable.

Although on cross examination Dr. DrLiey testified that he had never seen a pH of 4 for the Zion spent fuel pool, the basis of this answer was a series of pH values recorded in the past 3 years at Zion.

In that time the Zion pool has nou lost an excessive amount of water through boiling, leakage or evaporation which has not been promptly replaced. ( Draley, Tr. 1359 ).

72.

Draley stated that he had considered the conclusicn of the Battelle-Columbus test that both the average and localized rates of attack are probably too high to guarantee a 40 year life for the Boral.

But it did not strongly influence his testimony.

Draley indicated that he had discussed both the Brcoks and Perkins and the Battelle results with Commonwealth Edison. Although he dic not reccmmend closing the racks, Ccemonwealth Edison decided to change the rack design after the Erooks and Perkint tests and reccrr.endations to cicse the racks had been reviewed ( Draley, Tr. 1343, 1350; Almeter, Tr. 1233).

1179 i93

73.

Dr. Almeter, when questioned about his opinion cn the design change *eas unable to state a conclusion. (Almeter, Tr. 1234).

74.

Several other pieces of evidence brought the question of pittina to the attention of the Board. Dr. Draley appended to his prepared testimony an article by Wee: s entitled " Corrosion Considerations in the Use of Boral in SpentFuel Storage Pool Racks".

(Draley prepared testimony, Reference 4, Tr. 1290).

Weeks cites experiments ehich yielded pitting of depths up to 45 mils at pH of 5, at 100 C in 1 1/2 years (Gaton Lake Fanama) and 30-40 mils in 1 1/2 -

2 years ( Potemac R.,

Washington).

The pitting was due to galvanic corrosion between Aluninum and Stainless Steel.

The general cor.osion of thi'. alloy was negligible in both enrironments.

Weeks recommends a surveillance program which would include couples of aluminum and stainless steel to be installed in spent fuel pools where cotcl cavities are vented because venting which is used to eliminate swelling due to hydrogen may produce pitting corrosien of the Boral (pf., at 6).

Additionally Weeks recommends that there should be no contact between Aluminum and Zircalloy because that could lead to hydriding of Zircalloy cladding.

75. Dr. Almeter testified about tests done by Exxon (3ee Draley, prepared testimony, Raference 6, Tr. 1290).

This stufy cle2rly she.ted that 'chere pitting was begun the areas of pitting

\\ \\ 1,3

\\ Q' 4 de27ened i.- cne fear. (Alme:er, Tr. 1210).

Alneter testified that in an affidavit in cupport of motion for summary diposition filed January 31, 1979 he cited rates of corro-sion for Boral which, 'chen extrapolated over to 4 0 years, indicated total corrosion of the Aluminum clad on the Boral.

These original figures were based on the Exxon study and an additional report not in evidence in this proceeding.

No figures were listed in the testimony filed by Almeter prior to Hearing in May.

Almeter admitted that the figurcs which cited ccmplete deterioration of the Boral Clad were ccrrect as they applied to pitting. (Alme ter, Tr. 1217, 1218).

76.

4 Almeter's prepared testimony, p 4, states that acclera-tion in corrosion will occur with either increase in aqueous: tempera-ture, change in electrical potential differential, change in ionic concentration of the aqueous environment, or coupling of dissimilar metals where one is nobler than another.

On cross, alt.eter testified that Stainless Steel is nobler than Aluminum and therefore galvanic corrosion can occur, in the Zion pool that temperature will increase in the pool at certain times, for instance when fuel from reactor is placed in pool, and that the ionic concentration in the pool is sub-ject to change, e.g. when there is not a continuous clean up of pool

( Alme te r, Tr.ll44).

Almeter stated that the entire surface of the Ecral would be subject to pitting with the initial attack around the top vent hole (Almeter, Tr. 1212-1217).

1179 195

si Based on the testimony, the Ecard finds that Inter-venor's co ntention 2(h) has raised valid concerns about corrosion of aluminum and stainless steel in a spent fuel environment.

Based on the testimony, the Board finds that additional testing and analysis is.ieeded to predict the corrosion effects on Boral in proximi + y to stainless steel in an oxygen-saturated boric acid solution (i.e.,

the spent fuel pool water).

The Board also finds that the continued integrity of the Boral within the tubes is of sufficient concern to merit a corrosion surveillance program.

78.

Additionally'Almeter stated the Exxon study show0 that in cases where there were defects in the matrix and/or bonding of the Boral, bulging could be expected.

(Almeter, Tr. 1223-1226).

He indicated that he did not expect to see such bulging in the Zion pool, but it "would depend on the quality control formulation of the Ecral plates the particle size of the boron carbon, and the uniform mixing of the aluminum bonder the boron carbon in the formulation of these plates".

79.

Applicant's witness Mr. Shewski, testified that Brooks and Perkins quality control had been deficient and some boral tubes that did not correspond to specifications had been shipped to Leckenby (See S F, infra).

1179 196

'o.

d Dr. Draley testified that he expected that there could be T.easurable swelling of the Eoral itself tithin a vented tube.

The degree of swelling is expected to be from.1 to.234 inches.

The cause of this swelling would be the replacement of the aluminum in the Eoral matrix with corrosion products. (Draley, Tr. -131%.

In his opinion the swelling would be greater in an unvented tube that leaked than in a vented tube, but the amount of additional swelling was not estimated (Draleye Tr. 1318).

81.

Dr. Draley testified th3t another kind of Eoral swelling which might occur would be related to local corrosion or pitting which might be induced by galvanic interaction between the aluminum in the Eoral and the stainless steel tubes where the two plates are pressed together.

The solid corrosion product has a greater volume than that of the corroded metal, and local < welling could result.

Using the density of the prefominent aluminum corrosion product, Bayersite, Dr. Draley calculated that the corrosion product will occupy a volume some 3.2 times that of the aluminum from which it is formed.

Draley estimated that even if a Boral plate in a Zion storage tube corroded all the way through cladding and core material the maximum swelling produced by the corrosion product rould be.234 inch. (Draley, prepared testimony at pp. 12-13, Tr. 1316-1313).

This type of swelling is found in the Eoral itself, r.o t the st,inless steel tube.

There was no estimate made for the degree of s-elling that could be anticipated in a tube or shroud if some o#

he cas pr:duced

the corrosion of the Eoral 'eca

2 entrappe d ce:weer 1179 197

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1179 198

84. Dr. Draley testified about the sufficiency of the Commonwealth Edison neutron attenuation test plan. (Draley, prepared testimony, Attachment,, TR 1290).

On cross examination Dr. Daley admitted he had not prepared the plan or its predecessor which was submitted to the ::RC in response to a question asking for a proposed surveillance program for boron. ( Draley, TR. 1298-9, 1303).

Draley was unable to state whether neutron attenuation tests would be performed prior to installation of the racks and was unable to testify as to the sensitivity needed in the test.

(Draley, TR. 1301)

The witness did testify that a neutron attenuation test conducted under water would be less sensitive than a test conducted prior to installation of the racks.

(Draley, TR. 1302).

This testimony was corroborated by NRC *eitness Lant: who testified that underwater test results would give "i' sufficient accuracy" (Lantz, TR. 1237).

Draley stated that the plan as presented in his testimony was " adequate" but he would not nake a statement that it was " complete" except if complete were defined as describing the " current commitment of the company" to carry out the plan as written. (Draley, TR. 1302).

85.

Both Draley and Lantz testified about testing for 3-10 content at the Zion station.

Lantz testified that Commonwealth Edison did not have the accuracy to determine the B-10 ccr.t.ua t o f the 3 oral that had been fabricated into racks.

Given that adequate testing for 3-10 would ae available, Draley stated that he did not incy tat measures would be taken in the event that neutron absorber

\\\\19

\\94

tasts fetact the B-10 content of the samples ffll below.02.

Cn cross examination by Mr. Miller, Mr. Lantz gave an opinion that Commonrealth Edison's existing license might require a report to Nic of an unanticipated loss of neutron absorbing capacity or some structural deficiency in the absorber plate.

No provisions of the license were placed in evidence. (Lantz, TR. 1257).

86.

Lantz testified that the NRC has not developed any criteria to monitor Boral ccntent, nor does the NRC staff plan to issue Technical Specifications in this area (Lantz, TR. 1238).

37.

The Board finds that the accumulated evidence shows that the possible degeneration of Boral density 'ue to mechanical d

f ailure or boron depletion in the pool is unlikely, accordingly we find the risk of criticality from loss of Boral after installation is small.

However, there is a grea er probability that deficiencies in manufacture and/or quality control will lead to inadequate concen-trations of 3-10 in the Boral matrix or f ailure to properly encapsulace Boral sheets in all racks, therefore we find an afeguate program to test for neutron absorber capacity should be implemented at the Zion station before rack installation.

1179 200

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_mo He stated that virual inspections would be used to monitor swelling (Dralev, TR. 130f).

Dralev. testified that there were no plans to monitor generation of gas in the Boral tubes, and that there were no plans to monitor the creation of corrosion products in racks being used to store fuel, and that there were no plans to observe accumulations of corrosion oroducts around the vent hole.

(Draley, TR. 1308-1310).

89. Lant testified that the coucon testing procram could be u.riu:

in detecting whether or not boron would be lost but that it would not be useful in detecting swelling. (Lantz, T.7 11 3).

Lant also testified that at time of hearing theru were no plans or procedures developed to deal with any swelling that r.ight occhr, or were there an"J plans or procedures developei to deal with fuel that was damaged or otherwise af fected b.v swellinc.

or racks (Lant:, TR. 1242-1243).

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u-fu21 assembly into the rack thus to insure that any sc.ecific rack was not wollen before placing actual fuel in it, it would be a " good idea" to test in with a dummy fuel assembly. (Lantz, TR. 115 3.-? ).

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.s the S2C had not set standards for the corrosion ronitoring program and it *;as not known if anv re.corts of monitorinc. or of unantici_cated events would be required by NRC unless it was so specified in the license amendment as issued ( Alme ter, TR. 1244-6).

Neither Almeter or Lant: was able to testify to whether NRC planned to oversec the surveillance program or if I & E would check the accuracy of the testing devices and procedures (Almeter/Lantz, TR. 1241).

91.

In response to a question by Chairman Wolf, witnesses Alme:er and Lant agreed that monitoring and event reports general.'v should be required by the NRC but the requirement would have to be articulated in a techni$al specification or written into the license amendment (Almeter,Lantz, TR. 1245-6).

92.

The Board finds the surveillance program described by the 3.c.olicant is, in generalr adequate to protect the oublic health and safety, however several revisions are required to assure a complete program. Pre-installation neutron attenuation tests are more significant and can achieve the intent of assuring proper neutron absorber capacity.

Surveillance of swelling by visual means is not accurate, therefore dummy fuel test of each installed rack are necessary to avoid the inserti of fuel nto swollen racks. The Board finds that the NRC has a responsibility to oversee the monitoring program.

Finally, the Board also finds that there is a need for the che docurentation of Licensee's acceptance criteria for the surceillance tes samples in order to specificalli establ.sh conditions under rhich c.

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1179 202

Contentica 2K:

The acendment recuest and succortinz docu-mentation do act ~ consider po's'sible degener-ation of the Boral density due either to generic defects or to T.echanical failure which would diminish the effectiveness of Boral as neutron absorber, thus leading to criticality in the spent fuel pool.

Contention 2L:

The Applicant has not described the proce-dures it intends to employ to prevent the installation and use of damaged and defei.-

tive racks.

The State adopts Licensee's Proposed Findings No. 134, 136, 137 and 142.

93.

Licensee has retained Nuclear Services Corporation

("NSC") to perform independent inspections of Brooks and Perkins' fabrication of the boral tubes to be used in the new racks.

(Shewski, Tr. 719)

NSC has been to Brooks and Perkins several times to do inspections.

(Shewski, Tr. 719).

During its inspections NSC reviews Brooks and Perkins documentation on a random basis.

(Shewski, Tr, 720) 94.

The Licensee has also done three of its own audits of Brooks and Perkins:

in March, April and early June 1979 (Shewski, Tr. 720, 721).

During its audits tae Licensee looks at some of the inspection, data, audit, and surveillance reports kept as part of Brocks and Perkins's quality control and quality assurance programs.

(Shewski, Tr. 723) 95.

Brooks and Perkins is required to assure that the 1179 203

P80R OL E M boron-10 lcading in the tubes be a mininum of 0200 grams per square centireter.

(s n ews':., Tr. 724, 753)

Cn March 14 and 23, 1979, NSC released five boral tubes frcn Brooks and Perkins that had boron-10 leadings of less than 0.02 g/ cm (Shewski, Tr, 725, 726).

This deficiency was first discovered by Brooks and Perkins on May 4 and

, 1,

,9/a, in the course of a review o, previous shipments prectpttatea.

1 by two May shipments of apparently non-conforming tubes (Shewski, Tr.

738, 739, Intervenor Exhibit 3).

Licensee was not aware of the March shipments of non-conforming tubes until Monday, June 11, 1979, when Mr, Shewski received Intervencr's Exhibit 3.

(Shewski, Tr-735)

Licensee did not discover the non-conformino shipments during its o

April 1979 audit of Brooks and Perkins (Shewski, Tr. 737)

96. Licensee first orcered the boral tubes fron Brooks and Perkins for the neu Zion racks in July 1978.

The original purchase order did not specify that the fabrication of the tubes was " safety-related," so that Brcoks and Perkin's quality assurance program was not required to conform to 10 C.F.R.

Part 50, Appendix 3.

(Shewski, Tr. 737)

Licensee subsequently reversed its decision and in November 1973 required that the tube fabrication be safety related.

(Shewski, Tr. 738)

Licensee has not required that the suppliers of the ccm-ponent parts of the tubes have c.ualit.7 assurance programs conformine 0

to 10 C.F.R part 50, Appendi 3.

(Shewski, Tr, 739).

97 Accorcing to Licensee's plan, the new dense rachs eculd be installed in the spent fuel cool this vear, Some of :he racks ill sit in the ;cci for a paried of years befcre spent fuel assemblies are claced in ther

~J e t no cunn7 fuel 2333Chl'.' tests Till be perforCed at ar" tiCe after the racks

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PDDRORISINA_

still conform to their original shape. (Leider, Tr 763) 98.

The in-pool neutron at tnuation test vill not

're cerforced or e;crv tube.

Licensee has not established the number of tubes that will be tested. (Trama, Tr. 1942-43)

Mr. Trama could not cuantify the contribution of the boric acic in solution in the pool to the neutron attenuation ceasured by this test. (Tramm, Tr. 1943-44)

If these tests reveal that boral plates are missing in the sample tubes, Licensee plans to subject every tube to a neutron attenuation test.

Any tube that is missing a boral plate vill be plugged to prevent insertion of a fuel assembly (Tramm, Tr-1947 68, 1950) 99.

Dr. Olsen testified on behalf of the Licensee that if one boral plate vas missing out of every four tubes, and there was an extra fuel assembly at the side of the racs, the.K-errective, or criticality coerrictent, would exceed

.95.

(Olsen, Tr 1733)

On the basis of the K-ef fective calculations that SSC perforced in the Licensing Report (Licensee Exhibit 4), Dr. Olsen stated that it is cery important to knov vhether T.issing boral plates vould be permitted in the racks because it is not likely that tha nissing plates ;ould be unifornly distributed.

If t'.'. e O l a t e s ~7 e ' 7 locally all missing fr0C a series of

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are adequate to protect against the installation and use of tubes containing insufficient neutron absorption material.

Routine procedures implementing the quality assurance program failed to prevent or detect the shipment of non-conforming tubes to the rack fabricator.

The presence of five nonconforming tubes in one shipment illustrates that deficient tubes are not likely to be distributed uniformly.

Licensee proposes in situ neutron attenuation testing, but has not specified the number of tubes to be sampled.

The Board finds that Licensee's assurances are too vague to form the basis f 6r the conclusion that its program is adequate.

Accordingly, the Board finds that Licensee's test" e and Quality Assurance procedures cust be augmented by a neutron attenuation test of every boral tube in each rack before installation in the spent fuel pool Licensee must, in addition, perform a dummy fuel assembly test on each tube in the pool shortly before a spent fuel assembly is inserted in it.

1179 206

Changes in Accidents Postulated in Previous Licensina Peviews Soard Ques:icn.; 4 (c), 4(d), 4 (e) and

'f) stato:

(c)

. hat postulated accidents, which might affect the safety of plant operating personnel in the spent fuel storage building or which might result in the release of radiation or radioactive materials from the spen: fuel storage building, were specifically analyzed in the FSAR, SER, ER and FES utilized in the CP and OL licensing reviews of Zion Units 1 and 2?

(d)

Which, if any, of the ;ostulated accidents in (c), above, will be increased in pro-bability, magnitude or consequence (to personnel, to the general public or to the environment) if the proposed spent fuel pool modification are carried out?

(e)

What provisions have been made or procedures developed to protect the workmen and/or plant personnel from the consequences of such pos-tulated accidents during the period when the proposed spent fuel pool modifications are being performed?

(f)

Which, if any, of the postulated accidents in (c), above, will be increased in proba-bility, magnitude or consequence (to personnel, to the general public or to the environment) as a result of the completion of the proposed spent fuel pool modifications and the proposed subsequent usage of the increased spent fuel storage capacity.

Intervenor adopts Applicant's prcposed findings of fact nunbered 165, 167, and 169 and rejects the remaining findings numbered 1 170 and 174, in place of which the following findings of f act are propos-117"?

207

The Board finds that NRC concern abou: thc 01.

1 radiological effects of drc_o_oing a shic.cinc. cask is such that casks should not be permitted within the pool area until any mcdification activity tha' might cccur has been fully carried out.

102.

With respect to Board questions 4 (d) and 4 ( f),

Mr. Tramm stated that since the proposed modification will necessitate additional fuel moves, the likelihood, and corres-ponding risk of a fuel drop accident will increase slightly.

The incremental risk will however be minimal since the number of fuel moves necessary to accomplish the modification will add less than li to the total number of fuel moves which will be acccmplished during the plants lifetime.

(Tramm, prepared testimony at p.

27, TR. 564).

The Staff testified that since the fuel which will be moved during the modification will have decayed at least one month prior to being moved, this will be a decrease b; a factor of 10 in the magnitude or consequences of a fuel handling accident postulated to cccur immediately after shutdown because of radioactive decay of the gaseous fission products contained in the fuel.

103.The Board finds the risk of additional probability of accidantal dropping must be balanced ac "nst the potential consequences of a drop in deterni..ing ultimate risk.

1179 208

Pool Line

_e Tk Board gus c-3 4(h) states:

The Applicant and Staff are - ':ed to provife a history of the apparent lea

he liner of the spent fuel pool. Specif:

/, the following should be addressed:

(1) Has the leak intensifie 3 ith time?

( 2) What is being done with the water leaking from the pool?

(3)Why has the leak not been repaired?

(4)How will possible future leaks be located and repaired if the proposed increase in storage capacity is permitted?

Intervenor adopts the Applicant's proposed findings of fact numbered 131-183,. and in addition proposes the following.

104. The Board finds that at the present rate of leakage there is no danger that water loss will lead to a deficiency of cooling or shielding potential in the stant fuel pool. Also, as it is impractical to measure leaks of less than.005 gal / min. there is no adequate measure of leakage available.

However, in the interest of public safety it is desirable to maintain leaks to a minimal amount,therefore the Board finds that the Applicant has a responsibility to measure the leak periodically. If it is found that the leak has increased to 10 gal./ day measures must be taken to repair the leak.

If the leakage rises to 20 gal./ day, no additional spent fuel will be allo.ed to be placed in the pool until the leak is repaired.

1179 209

Component Coolinc System Leak Board Question 4 (i) states:

The Applicant and Staff are asked to address the contention made during the limited appearance statements that the component cooling system has had a number of leaks which have not been repaired.

Intervenor adopts the Applicants proposed findings of fact numbered 189 and 190. Intervenor rejects findings 191 and 192 and in their place propose findings of fact as follows.

105. Applicant's witness, Tom Tramm has stated in his testimony

• Sere is an interrelationship between the component cooling system and the spent fuel pool cooling system, in that the cooling of the spent fuel is a function of the temperature of the com-ponent system water. Postulated plant upset conditions which affect the component ecoling system therefore could affect the spent fuel pool cooling system.

106. The Board finds that as there is an interrelationship be-tween the component cooling system and the spent fuel pool cooling system the leaks in the component cooling system could possibly cause an adverse effect on the spent fuel pool. Therefore the Eoard finds that as a condition precedent to the grant of a license amendment authorizing modification of ti.e racks in the Zion pool Applicant nust correct the e:csting leaks in the cenpanen cooling r; ster.

1179 210

Fu21 Buildinz and Groundwater Mcnitorinz Contention 2(e)(1), (2), and (3)

(e)

The amendment request and supporting documentation do not adequately discuss monitoring procedures.

In the light of the proposed modification and long term storage of nuclear spent fuel the Applicant should clarify the following:

(1)

The monitoring equipment that is used and the ranges of sensitivity; (2)

The method by which incremental air-borne radioactive emissions created by the spent fuel pool expansion will be measured; (5)

Procedures to monitor groundwater move-ment in the vicinity of the plant to detect leakage from the spent fuel pool.

The State adopts Applicant's Proposed Findings Nos, 198 through 211. and in addition proposes the following.

107.

Mr. Jack Leider also testified for the Appli-cant on the demineralizer system that processes spent fuel pool water and on air monitoring in the spent fuel pool building..

10a.

In response to Ms. Little's questions regarding the demineralizer system for the spent fuel pool, Mr. Leider testified that the two demineralizers for the pool also process the cavity ater during refueling and the refueling water storage tank water prior to refueling.

The demineralization of the spent fuel pool eater is intermittent, not continuous.

(Leider, Tr. 771) 109 Grab sampling of pool eater is the caly method used cc determine hether the capacity of che demineralizing bad resin 1179 2i1

as been exhausted.

(Leider, Tr 771, 772)

The demineralizer system does not have available for it a device that automatically indicates :: hen the resin capacity _s exhausted, unlike the maj ority of ccamercially available demineralizer systems.

(Leider, Tr 772)

Licensee has no hard exact schedule for taking these grab samples, 110.

Licensee uses the clarity of the spent fuel cool water as an indication whether the demineralizer is operating properly (Leider, Tr. 772).

The removal of the particulate material that con-tributes to turbidity does not, however, indicate that all of the sol-cable radioactivity has been removed.

(Leider, Tr-772, 773).

The controls for operation of the demineralizer system are located in the fuel handling building,.not in the control room (Leider, Tr. 776) 111.

There are two area radiation monitors in the spent fuel pool building and a continuous air monitor in the exhaust venti-lation system.

(Leider, Tr. 776, 777)

The ventilation system monitor is the more sensitive and accurate of the two.

The station usually runs the exhaust ventilation system, but when it is not running only the area monitors could detect gaseous effluent from the fuel in the pool.

(Leider, Tr, 779).

112.

Applicant samples water at the Zion Station intake and discharge structures in Lake Michigan, hich are 2500 feet and 700 feet frca the shore, respectively. (r. olden, Tr. 1013)

The closest public water supply intake monitored by the Applicant is th_ Lahe County Publ'_c ~?ater Supply intake, "hich is about cne mile norti-of the Station. (Golden, Tr. 1912, 1019) 13.

The area immediately surrounding the Zion Staticr

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114.

The 30 arc finds that the Applicant's yrogram for monitoring the spent ?uel pool builcing and Lake

'.ichigan is generally sufficient to protect public health anc safety and t.ne environment, hot: eve r, it rails to protect the health and safety of the public using the Lake in the recreation area immediately adj acent to the Station.

In addition, no surveillance of groundwater down-gradient of the Station is done to signal leakage frca the spent fuel ' col into the soil.

Therefore, the Board finds that the Applicant should be recuired to install at least two groundwater monitoring stations between the spent fuel pool building and Lake Michigan.

Each station should consist of two wells, one each to sam-ple the deep and shallow acuifers.

i179 213

III.CONCLUSICNS OF LAW The Licensing Board has thoroughly reviewed and evaluated the evidence submitted by all parties in respect to the Contentions raised by the People of the State of _llinois and in response to the questions raised by the Board. The Licensing Board has also considered the proposed findings of fact and conclusions of law submitted by the parties.

Those proposed findings of fact and conclusions of law not adopted herein by the Licensing Board are rejected. The Licensing Board makes the following conclusions of law:

(1). The NRC staff failed to perform a site specific Environmental Impact Appraisal; it therefore improperly reached its con-clusion that the issuance of the requested license amendments does not constitute a major federal action significantly affecting the quality of the human environment.

(2)

As the Nuclear Regulatory Commission directed in its " Notice of Intent to Prepare Generic Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel", 40 Fed. Reg. 42801 (September 16,1975), the Board has applied, weighed and balanced the five factors set forth in that Notice and concludes that issua.nce of the requested

. license amendment should be deferred.

(3)

Since the NRC Staff's environmental assessment of the pro-posed action is deficient, the Board has considered the alternative of curtailing the output of the Zion station as part of its NEPA analysis of the license amendments.

"oreover, the NRC's " Notice of Intent to Prepare Generic Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel", referenced in Paragraph 2 of these conclusions imposes on the Board a duty, idependent of the legal requirements of NEPA, to consider the curtailment of output alternative.

The Scard concludes that the existence and feasibility of this this alterna ive supports deferral of the license amendment for up to three years.

(4)

As there can be no reascnable assurance that the activities that.could be authorized by an operating license amend-1179 214

Cent suc? as that reque s te.:! by the A;plicant can'he. conducted tithout endangering rhe health and safety of the public the license should be denied.

(5)

If at some future time Nuclear Regulatory Commission policy and lack of any feasible alternative spent fuel storage facility should necessitate a license amendment be granted,no amendment should be granted unless it is conditioned on the acceptance of the conditions and technical specifications set forth in the Alternative Order below. These conditions and technical specifications shall be incorporated into the license.

1179 2i5

I'/ ( A)

ORDER

'EdEREFORE, it is ORDERED, in accordance with the Atomic Energy Act, as amended and the regulations of the Nuclear Regu-latory Commission, and based on the findings and conclusions set forth herein, that the Director of Nuclear Reactor Regulation shall not issue any license amendments authorizing the requested replacement of spent fuel storage racks at Zion Station.

It if further ORDERED in accordance with 10 C.F.R $ 52. 760, 2.762, 2.764, 2.785, and 2.786, that this Initial Decision shall be effective immediately and shall constitute the final action of the Commission forty-five days after the issuance thereof, subject to any review pursuant to the above-cited Rules of Practice.

IT IS SO ORDERED.

THE ATOMIC SAFETY AND LICENSING BOARD John F.

dolf, Esq.

Chairman Dr. Linca..

Little, Memoer Dr. Forrest J.

Remick,..emcer Dared at Bethesda,

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