ML19316A894
| ML19316A894 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/24/1980 |
| From: | Olson J, Senechal M, Spannaus W MINNESOTA, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8005280031 | |
| Download: ML19316A894 (8) | |
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In the Matter of DOCKET NOS. 50-282 50-306 NORTHERN STATES POWER COMPANY Prairie Island Nuclear STATE OF MINNESOTA'S Generating Plant, Units 1 SUPPLEMENT TO ITS and 2 PETITION TO INTERVENE (Spent Fuel Pool Modification)
On April 8, 1980, the State of Minne sota by its Attorney General, Warren Spannaus, and its Pollution Control Agency (hereinaf ter " State of Minnesota") filed a Request for Hearing and Petition for Leave to Intervene. Pursuant to 10 C.F.R. Section ~
2.714(b), the State of Minnesota hereby files this supplement to I
its petition setting forth its contentions and the bases therefor.
In setting forth the bases for its contentions the State of Minnesota does not intend to limit in any way its right to present additional evidence and argument in support of its contentions at an evidentiary hearing on this matter. The purpose of this docu-ment is merely to summarize with reasonable specificity the bases for the contentions as required by 10 C.F.R. Section 2.714(b).
RESERVATIONS As these contentions are in part based upon documents which may be superseded, modified, or supplemented before or during a hearing on this matter, the State of Minnesota respectfully reserves the right to modify, amend, add or delete contentions, s o os esoggggg
CONTENTIONS
- 1. The license amendment request and supporting documenta-tion do not contain a safety analysis with respect to the routine storage of spent fuel in Pool No. 1 and the insertion of a shipping cask into Pool No. I when it contains spent fuel. Until such a safety analysis has been performed and it has been deter-mined that such actions can be conducted safely, the Commission should deny the Licensee's request for routine storage of spent fuel in Pool No. 1.
- 2. The license amendment request and supporting documenta-tion do not contain an analysis with respect to the increased con-sequences which would result if the proposed spent fuel pool expansion is executed and there is subsequently an accident, including a Class Nine accident, which results in a loss of water in the spent fuel pool. Until such an analysis has been performed to identify and quantify any such increased consequences, the Commission should not consider Licensee's license amendment request.
- 3. The license amendment request and supporting documenta-tion present a flawed criticality analysis, because boron-10 depletion does not appear to have been considered in the calcula-tions. Until such an analysis has been performed to determine whether exceeding the criticality acceptance criteria is positively precluded during the entire service lifetime of the storage racks, l
the Commission should not consider Licensee's license amendment l
l request.
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BASES FOR CONTENTIONS Contention 1 A review of Table 1 and Figure 3 of Exhibit A of the license amendment request filed by the Licensee Northern States Power Company (hereinafter " Licensee") shows that the Licensee intends to store spent fuel assemblies in Pool No. I as a routine matter.
When the plant was originally licensed, Pool No. I was intended to be used solely for the temporary non-routine storage of spent fuel (e.g., in the event of a core off-load) and for the acceptance of a shipping cask to transport spent fuel assemblies from the Prairie Island site. A shipping cask was not intended to be inserted into the pool at a time when there was spent fuel in Pool No. 1.
Since Pool No. 1 remains the only logical location to insert a shipping cask, the Licensee is, by its amendment request, seeking to create a situation in which a shipping cask will be lowered into Pool No. I when spent fuel is present in the pool.
Obviously, this situation presents a clear risk of an accident involving the dropping or sideway slippage of a cask onto or against stored spent fuel.
The license amendment request and supporting documentation do not analyze accidents involving shipping casks in a pool con-taining spent fuel. The only analysis in such documents pertains to shipping cask accidents in an empty spent fuel pool.
At page 24 of Exhibit A of the application the Licensee states: "The FSAR section 9.5 provides a description of the cask i
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drop accident. Cask drop is also described in Section 3.3.4 of the Exhibit C report." As noted above, the original license did not provide for routine storage of spent fuel in Pool No. 1, and thus the FSAR prepared at that time does not analyze the risk or con-sequences of an accident involving both a cask and spent fuel, bection 3.3.4 (at page 3-17) of Exhibit C of the application addresses cask drop in the following manner:
[Njo fuel shipping cask will be inserted into pool 1 until further licensing action is completed.
Because of the above, no consideration i.n the nuclear analy-sis has been given to the drop of a fuel shipping cask in the pool.
Thus the license amendment request and supporting documentation f ail to analyze the safety hazards which will be created if the license amendment is granted.
The Commission's duty is to insure that spent fuel can be loaded into shipping casks without adversely af fecting the health and safety of the public. Therefore, a safety analysis should be performed to determine whether a cask may be safely inserted into Pool No. I when it contains spent fuel. If the analysis finds that it cannot be safely inserted, routine storage of spent fuel in Pool No. 1 should not be licensed.
Contention 2 A review of the license amendment request shows that the Licensee intends to store 1483 spent fuel assemblies in the spent fuel pool. This is almost eight times the amount of spent fuel which was originally authorized to be stored. There are several
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l situations which could result in a loss of water from the spent tuel pool. The license amendment request and supporting documenta-tion do not analyze accidents involving a loss of water in the spent fuel pool and the difference in consequences between those which would result from the proposed spent fuel pool and those which would result from the present spent fuel pool.
Section 3.5.2 at pages 3-57 through 3-70 of Exhibit C of the application sets forth the Licensee's spent fuel pool cooling analy-sis. The purpose of the analysis was to calculate heat genera-tion and pool temperature during normal, abnormal, faulted and accident conditions. " Accident" conditions are defined as: " Loss of all external spent fuel pool cooling when the spent fuel pools are filled with 1483 fuel assemblies, including a recently removed full core." Exhibit C at page 3-59. Although the phrase " loss of external pool cooling" sounds like loss of water in the pool, the analysis results on page 3-63 state that "[f]or the accident con-dition the pool water temperature would rise until boiling at the pool surface began [ sic]." The analysis then goes on to address the time to boiling and the sources of water that could be used to replenish pool water. Obviously, this analysis does not analyze at all the consequences of a true loss of water in the pool, since the analysis assumes all along that water will remain in the pool or can be provided to the pool. In other words, the purported
" analysis" concludes that the accident assumed could not happen and thus no further analysis need be done.
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9 The consequences of a loss of water in the pool need to be analyzed because the risk exists.
A review of the Final Safety Analysis Report (FSAR) shows that water could be lost from the pool, especially in the event of an accident involving either of Prairie Island's two reactors. The plant is designed so that the component cooling system and the refueling water storage tank serve both the spent fuel pool and the engineered safety features of the reactors.
In the event of a severe loss-of-coolant acci- t dent, including a Class Nine accident, in one of the reactors, large amounts of water would be demanded by the engineered safety features and would deplete the amount of cooling water available to serve the spent fuel pool.
If the spent fuel pool was at the same time experiencing high heat loads due to a refueling or core off-loading operations of the other reactor, the depleted water supplies may not be adequate to provide enough water to prevent a loss of coolant accident in the spent fuel pool itself. In that event the Licensee may be required to utilize water sources not ordinarily used, such as fire mains, on-site wells, or the Mississippi River. Therefore, a comprehensive safety analysis should be performed to determine whether the refueling water storage tank and the component cooling system are adequate to supply all necessary amounts of sufficiently cooled water to both the engineered safety features and the spent fuel pool in th e event of a simultaneous LOCA in one reactor and increased heat levels in the spent fuel pool.
The analysis should include an essessment of the feasibility of installing separate cooling
~7-systems for the spent fuel pool and the engineered safety features of the reactors.
In addition, a safety analysis should be per-formed to determine the capability of plant systems to contain ,
decontaminate and safely discharge any water drawn from the extraordinary external systems listed above.
There are other scenarios which could result in loss of pool water, but the Licensee has refused to recognize this possiblity.
A safety analysis should also be performed to identify all scenarios in which water could be lost from the spent fuel pool, including scenarios which include a Class Nine accident. The con-sequences of such scenarios, including on-site and off-site con-sequences need to be analyzed.
The Commis? ion has recently been forced to deal with the actual occurrence of a Class Nine accident. Since the accident at Three Mile Island, the Commission cannot continue to pretend that Class Nine accidents are not credible. The Commission has stated its intention to resolve the generic issues of consideration of Class Nine accident situations in policy development and rulemaking; however, the Commission has reserved the right to con-sider Class Nine accidents in individual cases if appropriate. In the Matter of Public Service Co. of Oklahoma (Black Fox Station, Units 1 and 2) Docket Nos. STN-50-556, STN-50-557, Memorandum and Order, March 21, 1980.
The Commission noted a number of cir-cumstances in which consideration of a Class Nine accident may be appropriate.
Such circumstances included unusual design features.
The shared component cooling system and refueling water storage tank
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constitute an unusual design i.eature. Therefore, the Commission should consider Class Nine accidents in connection with the pro-posed license amendment request.
7 Contention 3 Section 3.3 at pages 3-5 through 3-15 of Exhibit C of the application sets forth the criticality analysis performed in sup-port of the application.
Boron-10 depletion does not appear to have been considered in the calculations. This results in the analysis being flawed, and thus additional analysis needs to be performed to determine whether exceeding the criticality accep-tance criteria is positively precluded during the entire service lifetime of the storage racks.
Dated: April 24, 1980 Respectfully submitted Warren Spaanaus Attorney General
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.i Ms i W .k d Mar ene E. Sencrpal Spe ial Assistant Attorney General
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Jo,c,elyn F. Olson S[,5cial Assistant Attorney General