ML20079R909
| ML20079R909 | |
| Person / Time | |
|---|---|
| Site: | Palisades, 07201007  |
| Issue date: | 03/21/1994 |
| From: | Raddatz M NRC |
| To: | Sturz F NRC |
| Shared Package | |
| ML18059A924 | List: |
| References | |
| FOIA-94-351 NUDOCS 9403240218 | |
| Download: ML20079R909 (3) | |
Text
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WASHINGTON, D C. 20 tie 6 0001
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m 21 w MEMORANDUM FOR:
Frederick C. Sturz, Section Leader Irradiated Fuel Section
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Storage and Transport Systems Branch 1
FRON:
Michael G. Raddatz 1
Irradiated Fuel Section Storage and Transport Systems Branch
SUBJECT:
RESPONSE TO TICKET :.01 0009825 AND SEARCH OF VSC-24 RULEMAKING LETTER FILE
- i With the assistance.of Storage and Transportation Systems Branch and the.
Office of Nuclear Regulatory Research staff, I initiated a search of both the VSC-24 rulemaking letter file, and the NUDOCS system.
We were attempting to identify any correspondence that raises the issue'of seismic qualifications,
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or lack there of, for the independent spent fuel storage installation-(ISFSI) i at the Palisades nuclear station. Because of the nature of the ticket item,-
we specifically searched fcr letters from Dr. Mary Sinclair. We found only one letter from Dr. Sinclair, dated November 13, 1993, that. discussed
" shifting sands." She docketed a speech that she gave to the U.S. Radioactive Waste Techinical Review Board, and in it, she discuses the fragile shifting i
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dunes near the plant. We did not find an allegation of inadequate engineering
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l on the part of the licensee or fear of seismic instability of the'ISFSI site.
l We then broadened our search to include all correspondence for the VSC-24 l
rulemaking, including the transcripts from the public meeting held in conjunction with it.
The sand dunes and shore line are brought up in several of the letters:
"These casks hav Michigandunes."pneverbeentestedintheenvironsofthefragilelake--
l "The dunes have eroded back from the lake several hundred feet over the past 25 to 50 years."
"The dunes are an extremely unbalanced geography...."
"Also in question is the wisdom of storing such a potential lethal substance in storage casks on notoriously unstable sand dunes." " Palisades is a unique and fragile dunes area."
"The storage is to be on sand dunes along an ever rising lake."
We have not been able to identify any allegation of improper seismic qualifications made by any intervenor.
The majority of the issues raised by the letters related to an environmentally sensitive area, such as a fragile wet-land, needing protection from development.
In the NRC response to public comments on the VSC-24 l
certification, April 7, 1993 (58 FR 17948), the issue of structural integrity
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of the pad is addressed in comment 15. Upon review, the wording seems to be an interpretation by staff of the many related issues.
(Because of the I
volume, we grouped letters by subject.) There does not appear to be a i
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'This exact wording shows up in several different letters, CIb q
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3 Frederick C.'Sturz 2
question raised directly by an intervenor. Our response indicates that the j
licensee is and was required to perform an assessment of the. adequacy of the '
pad per 72.212(b). There was never a question of adequate seismic engineering for the pad, because the cask analysis was independent of site characteristics.
In this case, the site credible _ seismic event produces a maximum of.29 ground acceleration.
The cask is rated for.25 ; therefore, 9
the cask analysis that bounds the site is acceptable for use.
This leads us to believe that the issue of whether or not the licensee performed an adequate ~ seismic stability study is an NRC question probably q
developed during the inspection process.
In fact, the issue of liquefaction.
first appears in a Technical Assistance Request (TAR) from Region Ill, dated October 21, 1993.
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i The TAR does not request us to address the issue of potential liquefaction, l
but instead "... requests your assistance to determine what effect being l
completely covered in sand would have on the heat removal capabilities of the I
cask...."
The Office of Nuclear Material Safety and Safeguards (NMSS) and the Office of Nuclear Reactor Regulation (NRR) staff responded that there.were not any significant effects.
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A follow up question might read, "What would the effects of such an event be, even if the analysis of seismic stability performed by the licensee, proved to be inadequate." This could apply to any newly identified accident scenario, l
and the answer would be the same.
To have public health and safety
'I consequences, you have to first breach the confinement-boundary.. Paraphrasing l'
the NMSS response to the Committee to Review Generic Requirements (CRGR),
"Without a breach of the confinement boundary, the radioactive material contained within the spent fuel cannot enter the environment, and without that.
specific event, there is not a significant public health and safety issue."
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Michael G. Raddatz, Proj'ect Manager Irradiated Fuel Section-Storage and Transport Systems Branch l
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- q Frederick C. Sturz 2
question raised directly by an intervenor. Our response indicates that the licensee is and was required to perform an assessment of the adequacy of the Dad per 72.212(b). There was never a question of adequate seismic engineering for thepad, because the cask analysis was independent of-site characteristics.
In this case, the site credible seismic event produces a maximum of.29 ground acceleration. The cask is rated for.25g; therefore, the cask analysis that-bounds the site is acceptable for use.
This leads us to believe that the issue of whether or not the licensee performed an adequate seismic stability study is an NRC question, probably developed during the inspection process.
In fact,' the issue. of liquefaction first appears in a Technical Assistance Request (TAR). from Region Ill, dated October 21, 1993.
The TAR does not request us to address the issue of potential liquefaction, but instead "... requests your assistance to determine what effect being completely covered in sand would have on the heat removal capabilities of the cask...."
The Office of Nuclear Material Safety and Safeguards (NMSS) and the Office of Nuclear Reactor Regulation (NRR) staff responded that there were not any significant effects.
A follow up question might read, "What would the effects of such an event be, even if the analysis of seismic stability performed by the licensee, proved to be inadequate." This could apply to any newly identified accident scenario, and the answer would be the same. To have public health and safety consequences, you have to first breach the confinement boundary.
Paraphrasing the NHSS response to the Committee to Review Generic Requirements (CRGR),
"Without a breach of the confinement boundary, the radioactive material contained within the spent fuel cannot enter the environment, and without that specific event, there is not a significant public health and safety issue."
Michael G. Raddatz, Project Manager Irradiated Fuel Section Storage and Transport Systems Branch Distribution:
Docket 72-1007 NRC File Center NMSS r/f STSB r/f IMlf r/f CHaughney XCleu WReamer OfC IMi [
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s NAME Mddha'tz:fb FBd' F3hz DATE 3 /2 r /94 5 / #/94
'/h/94 C= COPY E = COVER & ENCLOSURE N = NO COPY OFFICIAL. RECORD COPY g:Landmemo.mgr
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