ML20079Q090

Response to Applicant Third Set of First Round Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20079Q090
Person / Time
Site:	Harris
Issue date:	05/06/1983
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
82-468-01-OL, 82-468-1-OL, ASLBP-82-468-1, ISSUANCES-OL, NUDOCS 8305110361
Download: ML20079Q090 (12)

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UNITED STATES OF AMEEICA .s May 6,1983 A NUCISAR BEGULATORY COMMISSION ~

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright

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.s Dr. James H. Carpenter James L. Kelley, Chairman N In the Matter of

) Dockets 50 400 OL CAHOLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 ani 2) ) ASLBP No. 82-h68-01

) OL Wells Eddleman's Response to Apolicants' Interrogatorie s (Third Set - End 1st Round)

(Eddlenan 6hf and 67)

Tnis resconse is being filed under extension of time negotiated with Applicants' attorneys. (h-27 I gave then a two day further extension for their partial response to my interrogatories of 3-21-83.)

ANSWERS TO GD;ERAL INTDBOGATORIES 60ll Ita) Dr. Marvin Resnikoff of CEP, 85h Fif th Ave , NYC 1 I believe f has first-hand knowledge of his recorts and book on which Eddleman 6hf is based. (b) the facts are set forth in the contention and the suonorting references I noted in July 1982. A list of the supporting references is in a document (handwritten notes) identified in the specific resuonses below. (c) see (b); contention 6h(f).

E 2. Objection. Same as to G.I. 2 in previous resnonses, incorporating 88 them all together here by reference, along with my answer to Aunlicants' am

- Motion to Compel, as filed h-22-83

$b 00 3 None so far.

8e k. The Waste Paper, as referenced in my pleadings, for 6hf; for 67, news reports (I'm not sure which were written). (c) 6hf's

specific allegations; 67's allegation that there is no assured disposal site for Harris low-level waste.

5: Facts and information will be revealed, and docunents identified, for specific interrogatories. As to the inclusion of the name of any non-witness who supplied informa tion, or the advice of such person, I make the same objection here as in the objections and answer in-coroorated by reference for the objection to #2 above.

6. If any, will be identified in seecific responses.

7. None so far.

RESPONSES TO SEPCIFIC INTERDOGATORIES 64-1(a). I refer to any casks used to transport spent fuel to Harris. I do not understand that CP&L has limited itself or Aunlicants have linited themselves to the use of the IF-300 cask only.

(b) Any other cask which is so used.

(c) See (a) and (b) above.

6h-2. Relief valves and other valves; detailed descriptions recuire discovery of Applicants.

6h-3 Response recuires discovery of Applicants. I am conducting it already. See resconse to 6h-2 above. Each such comoonent can be identified or described once I get a detailed descriutio* of all the "The failure th"eshold for cidsure drain valves on the casks. valve and vegt valve seals is 30 min. in a fire of 1850 P" and less on a ruutured disk.

6h-k. In a design basis fire, absent the thermal mass of water, of even with water in the cask, the valve temperature could become elevated sufficiently to cause the valves to unseat or conponents to melt or the unseated valve comnonents melting or other conconents  ;

exoosed to higher tenperature by the unseated valve could melt.

" Data on Teflon valve seals indicate that failure would occur if the '

cask temperature exceeded $h0 degrees F" (Pacific Northwest Labs, - 5 An Assessment of the Risk of Transporting Snent Fuel by Trunk) t

n3-Additional information on cask valves, materials, and tempe*atures of spent fuel and the cask during shipping are required,to detail such basis. " Design basis fire" is 30 minutes at 1h75 F (note that average highway fires run 1850 degrees F); a "less severe fire" would be below 1k75 F but could still melt comnonents of valves or cause them to fail.

64-5(a). Of course. (b) It says the valve temperature itself was not analyzed. No basis whatsoever is given for the maximum expected valve temperature. No method of analysis is described.

No data is given for the cask without water in it. Indeed, no data at all is given except for unsupported conclusions. Inconel X-750 (bellows and sering material, to cuote this " generic FSAR" for the cask, NEDO-1006h-2, October 1979 nage 6-129) has " a maximum service temperature of 1300 F." That's less than the lh75 degrees of the design basis fire as I understand it.

Moreover, the valve is (same page) a Target Rock safety relief valve of the type which has been having problems in nuclear plants.

The safety analysis of the valve is reported to be for stationary application, as is the ASME code the ve.1ve is built to. (Waste Pater, Sierra Club redwaste camnaign, Vol 5 No. 2 nage 5).

l The information on page 6-128 "b" above section 6.5.2 says the pressure analysis for the cask assumes it contains water. Air pressure and volume (or either) rise much more sharply with tennerature than would water pressure or water volume. The valves are stated to relieve at 375 PSIG, and no analysis or experiment shows a lesser air p.

There is no analysis to speak of in the referenced section, and therefore I cannot set forth in mor~e detail the inadecuacies of it.

6h-6(a) I don't know. (b,c) see (a). (d) In addition to the means detailed above, the " coolant" in this case would be air, if Applicants' alleEations are correct; the "rutture disk" referred to would be a " seal" within the neaning of my $ nterroFatories of h-22 to

. -h-Applicants and more data on $ to na terials, their nroperties, degrada-tion in a radioactive environment, etc. is required for a full answer. There is also some water inside the " dry" cask as I understand it. This water could flash or boil to steam in a fire, f urther.

elevating cahk pressure inside. The air and a small amount of water in the cask lack thermal mass to hold down the cask temoerature in a fire. Metal cask components are excellent to very good heat t

I conductors, and a fire engulfing a cask is readily possible, e.g.

in a wreck involving a tanker car (rail) or truck (highway) centaining flammable materials. According to the Waste Paner Vol 5 #2 p. 5, a cask's interior can reach 1600 F within "several hours af ter a fire has been put out ... this is dangerously close to the ignition tenperature of zirconium cladding (1686 F)" Ignition of zirconium at any scraped or loose point or from any fine piece of it, either by the temperature, with air and steam around it, or in air, or by pyrophoricity at a temperature lower than normal ignition temperatures, could release significant additional heat inside the cask, and would lead to greater internal pressure. These effects, of course, raise the likelihood of valve or ruuture disk failure.

Further, independent of heat, a collision at as little. as 12.5 mph could unseat a cask valve. (Ref. Waste paper, ibid)

Fuel melting could occur (1) by cask containment failure allowing the fuel to be heated beyond the ignition point of zirconium (P) fuel cladding, or by pyrochoricity of zirconium in small pieces or at a crack or weld, or (3) by cask failure in a collision, fo116wed by a fire which ignites the zirconium cladding, or (h) by heating of the cask in a fire or by electrical lines bouching it during or af ter an accident, without avility to vent air or steam fron inside, followed by either direct fuel nelting or a zirconium-

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stcam or zirconium-oxygen or zirconium-water (or Zr with any of oxygen, (5) water, or stean together) reaction which is exothermic, or by having failed fuel {of which there 's been a lot at Brunswick) transported,

.and having any of the above occur, of (6) a crash at over 12.5 mnh (or any other sneed) causas a valve to unseat or a ruuture disk to fail in the cask and radioactive material escapes, or any of the above ensure, or (7) a valve unseats during a fire and any of the above follow (including simple release of radioactive contanination in the cask, or (8) a rupture disk or other seal fails, or a valve unsects without a fire or crash (e.g. from innaroper maintenance, oxidation of seals, overpressure or underpressure on reupture disks) and any of the above ensue, including sinnle release of radioacti ve material, or (9) a fire boils water in the cask and the water is vented to some extent, and then on cooling the steam forned in the cask condenses and the rescated valve fails to let in outside air, causing the cask to warp or implode, breaching its boundary of containnent, or does let in outside air, but allows then a leak of radioactive material in air or water released or blown out of the cask, and this scenario nay be followed by any of the above events, or (10) the cask warps or bows in a fire, and either loses its containment, crushes a valve, rips a runture disk or other seal (or otherwise twists or stresses it so it fails), and radioactive materisl ir

. released; the above scenarios may follow this one. ill) scenario (9) above occurs and a valve or rupture disk or seal fails as described in scenarion (10), with results including radioactive material release; of' (12) explosives involved in an accident with the cask breach it or war.in it, leading to . . events as described in (9),(10) or (11) above or more thsn one such set of events; (or) (13) the cask is penetrated or warped by a missile or sharn object it has inpa ed

or fallen on, followed by cask failure, seal failure, or any of the above scenarious; or (1h) a heavy object, e.g. a railroad tanker full of flammable material, falls onto the cask, or (15) the cask lands in such a position after a wreck or derailnent or accident that it either ruptures a seal or ruptur,e disk on impact, or unseats a valve, or warps of its own weight such that seal, rupture disk or valve x failure occurs, with or without a fire, and any of the above scenarios or a release of radioactive material through the failed cask, seal, rupture disk or valve follows. Cesiun boiling at its boiling point, about 2000 F, but cesium can be vanorized at temperatures below this, and radioactive cesium contributes some heat itself, so daat it can vanorize more readily than non-radioactive cesium in similar circunstances.

My analysis of the events above is not connlete, and there are doubtless other possible events leading to pressure valve unseating, radioactive releases, and/or cesium boiling and/or fuel nelting and overheating could occur which I have not yet gotten around to analyzing.

The fuel overheating and/or melting should be assumed as a nossible consequence in all scenarios above except perhaps (8) if the fuel

!. being shipped is cool enough. I an pursuing discovery of Applicants on matters related to this analysis.

(e) see above.

64-7(a) I don't know.(b) see (a); (c) I believe the N9C recuires cask integrity and elinination of radiation releases, but I don't have sufficient info on the IP-300 cask, and on other casks CP&L or others might use, to answer. Nothing in this response even deals wi th 6k(f),

and the urovisions of the Atomic Energy Act for protection of health and safety of the nublic require NRC to deal with the matters in that contention even should Anulicants neet all other reauirenents.

the Resnikoff study, its references, Besides the Waste Paner, the other docunent I rely on in 6h(f) is a list of references I believe are from that s tudy, sunnlied by a nonwitness whose nane I object to revealing, which I used at the July 1982 special prehearing conference. I am suuplying Applicante with a photocony of that, keepin5 the or.* ginal unchanged, but on the copy deleting the name and other identifying information (e.g.

telephone number) of the person who supulied the info. That nerson's identiff is absolutely immaterial to the information, which references available documents, and I object to releasing any info that would identify the nonwitness who sunnlied this info, for the sane reasons I object to General Interrogatory 2 above (incl. incorporation by ref erence in that objectien).

67-1. An " assured disposal site" is one that will isolate all low-level waste frcn Harris over its entire operating life unt51 such wastes have decayed to virtually zero radioactivity and radiotoxicity.

67-2. Without such a sita, on-site storage, incineration, or radioactive other options (such as CP&L8 s disposil of low-leve14 waste fron its Brunswick plant in scrap yards and local lendfills) can obviously .

endanger the health and safety of the public, by direct exnosure, emissions from the waste or incineration or othar processing, e.g.

volume reduction or pulverization thereof, and by the Harris nlant l

holding amounts of low-level radioactive waste (LI.RW) that it was not designed to hold and is not ecuipped to hold safely.

l 67-3 Yes, AEA means " Atomic Energy Act" in thf s contention.

AEA requires assurance that the health and safety of the public w311 be protected when licensees handle nuclear materials, including LLPW.

I hcve not yet looked up the specific cites, other than those in my 5-lh-82 supulement to petition to int ervene, which say so.

I flope geglicants a y,3, agree with ny interpretation of the Act, however, 67-h(t) 10 CFR 20 301(a) provides that a licensee may not disnose of radioactive material except to an authorized receiver. CP&L in its license Application for Harris has not requested a waiver under section 20 302 or as provided in 20 301(b) or (c) arranged for other disposal. Nor have Applicants sought to dispose of LLRW under 10 CFR 30, nor have they complied with the requirenents of 10 CFR 40.51 (c) and (d); LLE- W is not high level waste so part 60 does not apuly; LLRW is not spent fuel so part 72 does not apply. The above are the only parts of 10 CFR under which radioactive material Cisposal is permitted by 10 CFR 20 301. A licensed site under 40.51 is the only route which Applicants can seek for Harris LLFW without NPC authorization to do otherwise. Whether such a site for disuosal meets all the criteria for " assured disposal site" in my definition above, I cannot determine for sure at this time.

(c ) not Appli cable .

67-5(a). Limitations made by these states include ones on the types and volumes of LLFW accepted, e.g. hot varts or control rods or incore probles etc. may not be accepted as LLRW; total curies may be limited; etc. There is no assurance that these s ta tes will accent any Harris waste af ter 1986 (when it begins to operate).

If they do accept any, limits such as the above can and will prevent the types of waste restricted from burial or restricted in amount from being assuredly disposed of in an assured disnosal site. Harris is far from Nevada and Washington state, so these states may readily refuse additional Harris wastes (LLRW). South Carolina can refuse Harris waste either by restriction in law, exectjive order, action to protect public health and safety, or because NC is not a member of the compact for radioactive waste disposal that includes SC.

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Additional details require more information.

(b)(c)(d) Yes for each, given the 1986 date by which these states can cut off out-of-state radioactive waste shipments, and the restric-tions enacted by those states and/or their authorities previously.

The only out possible is a compact including one or more of those states and NC, but even such conoact does not guarantee assured disposal sites for Harris because the compacts may restrict waste shipments from places that violate shioning or disposal requirements.

CP&L has a history of violating shipping and disposal recuirements for radioactive wastes, so this is certa $ nly possible, that the Harris plant, CP&L, or NC would fall under such a restriction in a compact.

(e) Not applicable.

67-6(a) I don't know. (b) I believe the State of Washington has some initiatives and law on this, but I don't have the details available. Other State laws may be enacted in the future, also, limiting LLRW disposal.

67-7(a) I bg ve no idea whether these states will comply with section 4 of the LLRW Policy Act or any of its other provisions.

They may not, as evidenced by intense local opposition to landfills and LLRW facilities in NC 9e.g. Butner, Chatham, Moore, Anson co.s, ete; Warren Co.) and elsewhere, and the legislatures' agendas, possible

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failure to pass atpropriate laws, lack of availability of funds to comply with the law, the tendency of LLRW 1andfills to leak and be shut down for noncompliance with N90 and other regulations (e.g.

West Valley NY, Maxey Flats, KY, Sheffield, IL, etc), the lack of resources of state Eovernment to ensure ccmpliance with law and reculat!ons (*.g. States of NC, Rs d protection section , NY, KY, etc. )

I' don't know exactly what you mean by "southeasnt region" in yo r question but, y presume you mean the states referred to in the proposed southeast compact. The above dixfficulties and reasons would apply to all these states so far as I know.

(b) see (a), thou6h answer is not really affirmative.

(de) see (a).

67-8(a) Yes, it apnears the State of NC is not do'ng anything right now to manage LLRW safely or efficiently, though my info is incomplete. (b) the Waste Management Board hasn't done anything on the safety or efficiency of LLRW nanagement to my knowledge; the NC Radiation Protection Section is underfunded and unable to take on additional responsibilities, e.g. LLRW insuection, etc.

C (k) see (a) 67-9(a) I presume by " passed by the NC legislature and signed into law" you mean in exactly its present form as attached to your cuestions (NC Senate Bill 196). It depends , particularly on ratifi-cation by S.C. (where the licensed disnosal site is now), the avail-1 ability of a disposal site after 1992 (note that a state selected to make a site doesn't have to do it -- if they refuse, they car be kicked out of the compact) and on the integrity of ocean disnosal if any is allowed ( it is presently banned). I can't answer this question other than as a hypothetical because I don't know what the l NC, SC or other lee islatures will do. (b) see (a); (c) see (a);

(d) question (a) is a hypothetical, so I have not determined whether those conditions as stated are enough to withdraw Tddleman 67; I have l doubts, as stated in (a) above; the continued licensability and C"&L's access to a disnosal site under the compact could also be in jeonardy, as noted in resconse to 67-7 above. There may be other problems; I

since this is a hypothetical situation I haven't spent much time analyzing it.

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• 67-10. Applicants are resnonsible under 10 CFR 20 301 and ensuing sections for disposal of LLRW in compliance with applicable regulations, of fo" transferrin 6 it to a licensed disuoser. I do not believe it is up to me to advise Applicants on alternative actions, though it would certainly be prudent for then to be investigating, exploring, planning and considering such, and taking such actions as are necessary in the event the compact i's not ratified by NC, or by SC, or in the event that terms of the compact as ratified by NC, SC, or other states, would restrict Harris LLRW disposal at the compact site; and plans should be made for events that under such compact would also restrict or prevent disposal of part or all of the Harris LLRW at such site.

However, such actions are the resnonsibility of Annlicants, not of an intervenor. I have no list of adequate actions in this regard, beyond the above, and it would be more work for ne to make one un than it would be for the Applicants to do it for themselves. I know of nn actions Applicants are taking outside the LLRW compact, and am pursuing discovery re their actions concerning the LLFW connact for the Southeast.

67-11. If such technology exists, at any (unspecified) sites, I possess no information that assures me it is being used properly.

This interrogatory is so vague I don't really know what it neans.

.But it is not simply storage, but disnosal which Eddleman 67 addresses.

I do not consider " storage" to be equivalent to disposal for LL9W.

67-12. I have not performed an analysis which indicates that LLRW storage at Harris for periods of un to five years can be ,

accomplished. The volume, content, form, radionuclides in, curies of each radionuclide in, weight, and other variables concerning such LLRW would be necessary to such analysis, as well as the saf ety measures involved, if the health and safety of tl.e public is to be protected.

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h90DUCTIONOFDOCUMENTS: Documents in my possession refer-ed to in the above answers will be made available on loan, or conies loaned or given to CP&L, at a mutually agreeable tine and place, perhaus when next I go to Raleigh to look at the documents they have there.

CERTIFICATE OF SE9VICE I hereby certify that the above W.E. Response to Annlicants' UPWT N't" 6-W,i .nB+ 3MT&

interrogatories (Third Set, End Fi rs t Round), andA u) g /3; g e g Gtcff~%21shn+r Gd l,0f Xpleo;geh WI (IWaM e drNhave I). been served by 1st class US Mail to the following on May 6,1983 Judge James Kelley. .

Atonic Safety and Licensing Board US Nuclear Regulatory Commission Washin6ton DC 20555 George F. Trowbridge (attorney for Auplicants)

Shaw, Pittman, Potts & Trowbridge .

1800 M St. NW -

WashinEton, DC 20036 .

Office of the Executive Legal Director Phv111s Lotchin, Ph.D.

At tn Do cke ts 50-400/401 0.L. 10D Bridle Run USNRC Chanel Hill

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NC 2751h Washington DC 20555 Dan Read Docketing and Service Section CEME/ELP Attn Dockets 50-400/h010.L. Box 524 Office of the Secretary Chapel Hill NC 2751h USNRC Washir4 ton DC 20555 John Runkle CCNC 307 Granville Rd .

Chapel Hill Nc 2751h

'Travi.a Payne Edelstein & Payne '

Box 126!t3 Ralei Sh NC 27605 Richard Wilson, M.D. Certified by w 729 Hunter St. .

Apex NC 27502