ML20040C777
| ML20040C777 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/26/1982 |
| From: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | |
| Shared Package | |
| ML20040C778 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8201290231 | |
| Download: ML20040C777 (8) | |
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%gp UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of
)
Docket No. 50-155-0LA CONSUMERS POWER COMPANY
) (Spent Fuel Pool Expansion)
(Big Rock Point Nuclear Plant
)
s 01 INTERVENORS SUPPLEMENTAL HEMORANDUM RECElMD INOPPOSITIONTO
SUMMARY
DISP0SITI0{
M 271982s,. -3 nrem u mN.$i!s*f M
O'NEILL CONTENTION IIC.
Reply for this contention dif Y
the answers given in a subsequent contention.
Mr. Bordine states that the capacity ormake up requirements is 11 gpm, required to make up for e aporation lost due to the boiling of the spent fuel pool.
The heat load used to calculate this loss assumes that the full core had been discharged to spent fuel pool, which was not the case of the subsequent contention.
However the difference between 11 gpm and 2 gpm seems surprisingly large.
CHRISTA MARIA CONTENTION 3.
To minimize exposure to stress corrosion cracking of 304 SS other materials could be used.
Currently GE is replacing all 304 SS recirc piping loops on plants under construction'the the alloy is 316 K.
In any event it would be to advantage of the applicant as well as the public to use this material, which is much less susceptible to sec, and hence errors in welding during the manufacturing process (weld heat input), or in the control of water chemistry during operation, legss likely to have are a damaging effect.
In other words Consumers has no need to make o big defense of 304 SS, when better materials, proven to have significantly better characteristics in resisting scc, are available.
O'NEILL CONTENTION IIE-3.
Criticollity analysis performed assuming @ C)y by Dr. Kim cis' based on a water temperature of 212 F, boiling of the spent fuel pool, with the containment at y
atmospheric pressure.
Even assuming that the containment is at atmospheric pressure (not necessarily conservative ofter c jj LOCA), the pressure at the bottom of the spent fuel pool, due to the hydrostatic lood is 28.14 psia.
The boiling temperature at that pressure is 247 F.
Since the effective activity coef ficient K is not permitted to exceed 0.95, and since Dr. Kim's calculations reached this maximum,-assuming 212 F, it is questionable if the calculations con be considered conservative.
8201290231 820126 PDR ADOCK 05000155 O
CHRISTA MARIA CONTENTION 8 AND O'NEILL CONTENTION IIIE2.
This contention and the reply raise several questions, which should be investigated further.
Normally the containment spray, on of the engineered sofgy systems ESS, have a chemical additive, such as NaOH, to reduce the release of Iodine, in the event of an occident.
If this is the case at Big Rock, the question of the effect of this spray on the spent fuel pool should be addressed.
In Mr. Sacromo's statement, several questions gan be raised.
First-it appears a maximum temperature of 237 F is used in the analysis.
This temperature is obtained from Dr,Prelewicz statement, and corresponds to the soturation temperature at the top of the fuel elemnts, where the thickest part of the menisinmani wall is located.
The temperatures otw the bottom of the pool are higher, becauge of the greater hydrostatic heod.
Approximately 247 F.
Second-degradation of concrete strength due to neutron radiation was analyzed on the basis of placing the new spent fuel in one location, at the center of the pool floor (p 4).
It is not clear why this position is more conservative than placing the fuel adjacent to the wall of the spent fuel pool, so that the walls will receive the maximum neutron radiction, with the least amount of attenuation from the water in the pool.
Third-The analysis assumes uniform loading of 3,830 lb/ft (p 11).
In actuality, the spent fuel bundles impose point loading on the floor of the pool.
It is not apparent that this is a conservative assumption.
Fourth-reference is made to aluminum in the-construction of the spent fuel rocks. (p 11)
If NaOH is used in the containment spray system, it will react with the Aluminum, generating Hydrogen, which con compromise the integrity of the containment. (Hydrogen explosion)
In Mr. Blanchard's statement, the calculations on page 8, reconcile the are straightforward enough.
One cann difference with 11 gpm, mentioned ear $t1er.
Applicant should be asked to explain the differences in values.
In Mr. Blanchards statement, the path of the piping used for make up is described (p.10)
This concept has apparently been opproved by the NRC staff.
The yard piping associated with the fire pumps is not a safety grade system, yet it is used for the make up to the spent fuel pool.
If you ossume the scenorio of an
~
earthquake, mechanistically causing a LOCA, then the yard piping would have to be assumed to be inoperable, and make-up to the spent fuel pool would not be ovadable.
OTHER ISSUES TO CONSIDER.
The crane used for the handling of the spent fuel cask, and the spent fuel bridge crane, are probably not Class I cranes, as defined under current NRC criteria.
Upgrading of the Spent fuel cask crane to Class I should be. considered if the crone travels over the pool, or adjacent structures which, in the event of a crane failure, could jeopardize the integrity of spent fuel pool.
Upgrading of all instrumentation (level indication, temperature, make-up flow, let down flow) to redundant class I systems could be required, in view of the higher inventory of spent fuel.
e
' Charles Axtell Does Hot Qualify As An Expert Witness Charles Axtell should not be accepted as an expert witness based on his lack of academic training.
Mr. Axtell has no apparant training or qua'lifications in health physics.
His list of qualifications show him to have "about two years" of night school in general college courses.
There is no indication of courses in health or science related fields.
He does list two years of chemistry from the International Correspondence School, but does not state to what level of chemistry or what type of chemistry he studied.
From 1961 to 1981 Mr. Axtell has only a total of about thirty weeks training in addition to his night school and correspondence courses.
Three weeks of this training was management training.
The rest were job related training of one or two weeks.
An education through job experience and job-specific training courses is tailored to meet the needs of the employer and does not supply a broad enough training to competently evaluate the scientific issues involved in the contentions.
Mr. Axtell lacks a perspective that takes into account the overall engineering and physics interworkings of a nuclear power plant or the broader health and safety concerns of the public.
Additional documents in opposition to motion for summary disposition.
With the exception of the first four all are on file with the Nuclear.
Regulatory Commission 1.
Consumer Power Company.
Internal Correspondence Nov. 27, 1979 from R.A. English p.24-111
Subject:
BR Point Plant Comparison of fuel pool. water loss doses with MCA doses Contention:
0'Neill II C 2.
Consumer Power Co. Internal Correspondence JLB 5-80 to RN Sinderman
-p.24-113 fr. J.L. Beer January 15, 1980
Subject:
Technical Review of " Primary Emergency Zone Radius for Big Rock Point Nuclear Plant Contention:
Christa Maria 9 3.
Federal Register Vol. 45, No. 162 Tuesday Aug. 19, 1980 Rules &-
Regulations p.55946, 4.
%HB Technical Associates, Dale G. Budenbaugh to JoAnn Bier.
Dec. 23, 1981 Letter i
Subject:
Big Rock Point Spent Fuel Expansion (improve Safety of System)
C on.t e n ti o n :
0'Neill 7 l
l t
NRC documents 1
5 Docket No. 50-155 L 505-81-12-091 0
Dec. 29,1981 To:
David Hoffman from Dennis Crutchfield
Subject:
BR Point - Reactor Vessel Pressure - Temp limits Contention : christa-Maria 8 6.
Lessons learned from TMI March 14, 1980 NRC to C.P.
p.7, p.15 Contention:
0'Neill 7 I
Subject:
Hydrogen Recombiner 7.
Memorandum:
United States Atomic Energy Commission, Docket No. 50-155 Thru. D.L. Zieman, Chief ORB #2, L. Dec. 6,1972 pp 1-11 i
Subject:
Reload G and NFS-DA 11xil Rod Bundles with unpowered Rods and Plutonium.
Contention: Christa-Maria 9 8.
Consumer Power Co:
Letter to Dennis Crutchfield NRC from David P Hoffman (CPC) July 23, 1980 Dockets 50-155 and 50-255.
Subject:
Response to Evacuation time estimates - site emergency plan.
Contention:
Christa Maria 9 9.
U.S. N.R.C.
Docket No. 50-155, LS05 81-11-046, letter to David Hoffman from Dennis Crutchfield Nov. 20, 1981
Subject:
Shif t Staffing - Big Rock Point Contention:
0'Neill 7
NRC documents 10.
Letter from Brian Grimas, Director of Division of Emergency 1
Preparedness to Christa-Maria. Feb. 20, 1981 and attached Answers to Emergency Planning Concerns.
Feb. 20, 1981, attached Emergency Planning Guide - to Charlevoix and Emment County
Subject:
Emergency Planning Concerns Contention:
Christa-Maria 9 11.
Letter CPC David Hoffman to Dennis Crutchfield NRC. July 1,1981 Re:
Docket 50-155, License DPR 6 and attached evaluation of SEP topics XV-16, XV-18 and XV-19 (Radiological Portion)
Topic:
Radiological consequences of Failure of small lines carrying primary coolant outside containment Contention:
John O'Neill II C 12.
NRC to Consumer Power, May 28, 1981 Environmental Qualification of Sa fety Rela ted Electrical equipment p.13.
Contention:
John O'Neill'7 13.
NRC Docket No. 50-155, Fa c il i ty :
Big Rock Point Plant from l
Walter A. Paulson, Project Manager Operating Reactors Branch #5 A p r i l l,1981
Subject:
Summary of Meetings with Consumers Power Company held on March 17, and 18, 1981 to discuss the Big Rock Point Probabilistic Risk Assessment l
Contention:
0'Neill II E-2 l
NRC documents 14.
Final Response to NRCIE Bulliten 79-02
Subject:
Anchor Bolt Testing & Inspection, Inspection and testing results Contention:
0'Neil 7 and IIB 15.
Licensee Event Reports (Report dates: 12/18/80; 8/12/80, 12/23/80; 2/17/81, report upda te 2/12/80, 4/13/81; 10/15/80, 04/01/81 4/1/81, 4/1/81, 9/15/78, 2/17/81, 12/12/80, 1/28/81, 6/05/81, attachment to ler 80-048-OlT-0, 12/12/80
Subject:
Cracks and Leaks Contention:
O'Neill 7 and IIB 16.
Systematic Evaluation Program; Topic XV-8 Big Rock Point
Subject:
XV-8 Control Rod misoperation does not sa tis fy General Design Criteria 25 Contention: 0'Neill IIC 17.
Christa-Maria Contention 8 a.
CPC letter, 10/31/78, Bixel (CPC) to Keppler (NRC.
Subject:
Deficiencies found inanalysis for very small break lock.
b.
Preliminary notification of event or Unusual Occurrence, A u g. 13, 1980.
Subject:
Possible design analysis deficiency.
c.
CPC letter to Zieuan (NRC) from Bixel Subject Docket 50-155 additional information relative to i
l
fuel handling accident in containment, 11/29/78.
d.
Attachment to LER 81-016-01T-0, Docket 50-155 Herbert Semmel Attorney for Intervenors Christa-Maria Mills and Bier Antioch School of Law 2633 16th Street, N.W.
Washington D.C. 20009 (202) 265-9500 CERTIFICATE OF SERVICE' i certify that copies of the foregoing submission of Intervenors Supplemental Memorandum in Opposition to Summary Disposition were served on the attached list on the )bb7 day of January, 1982 by delivering copies to the office listed theremi or by U.S. mail, first class postage prepaid.
Herbert Sommel
m
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E Atcr.ic Safety and Licensing Jersp.' Calle, Enquire Ishe, Linen)n and Beale Ecard PancI 3
1120 Conneccicutt' Ave, N.W.
U.S.
Nuclear Regulatory Suisc 325 Cor= ssicn Washingten.
D.C.
20555 Washington, D.C.
20036 4
Peter B. Bloch,. Esq., Chairman Atomic Safety and Licensing 3
4' Board Panel U.S. Nuclear Regulatory a
Commission T,.
Washington D.C.
20555 t
i i
Dr. Oscar H. Paris Atomic Safety and Licensing l
Board Panel U.S. Nuclear Regulatory Docketing and Service Section Commission office of the Secretary Washington D.C.
20555 U.S. Nuclear Regulatory Cornission Mr. Fredrick J. Shon Washingten, D.C.
20555 Atomic Safety and Licensing J hn O'Neill, II Bohrd Panel Route 2, Bcx 44 U.S. Nuclear Regulatory Haple City, MI 49664 Commi.ssion Washington D.C.
20555 l
Janice E.
Mocre, Esq.
Counsel for NE Staff l
U.S. Nuclear Regulatory Cornission Washington, D.C.
20555
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