ML20091M512

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Response Opposing Applicant Motion for Summary Disposition on Contention 67 Re Low Level Radwaste.Motion Irrelevant Since Southeast Low Level Radwaste Compact Not Yet Approved.Related Correspondence
ML20091M512
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 06/05/1984
From: Eddleman W
EDDLEMAN, W.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20091M518 List:
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8406110328
Download: ML20091M512 (2)


Text

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RELATED CORRESrgnttEh@k arr KETED UNITED STATES OF AMERICA 1

June 3, 1984 NUCLEAR BEGULATORY COMMISSION 84 JJN -8 P2 55 f,a ei _

BEFORE THE A'!OMIC SAFETY AND LICENSING BOARD CD]fi[ich Glenn O. Bright Dr. James M. Carpenter James L. Kelley, Chair m n In the Matter of J

Docket 50- 9 OL CAROLINA POWER AND LIGHT CO. et al.

)

(Shearon Harris Nuclear Power Plant,

)

Unit 1)

)

ASLBP No.82-468 01

)

OL Wells Eddleman's Response to Summary Disposition on Contention 67 Much of Applicants ' Motion & Affidavit, and Staff 's " Response" and first affiant's testimony, is irrelevant because the Southeast Low Level Radioactive Waste (LLRW) Compact has not yet been approved by Congress.

This key fact, they ignore.

" Progress" a s they allege is not assurance.

Nor do they deny that the Sonpact has failed to be auproved so far.

As to the contingency plans for handling low-level radioactive wastes, I think there's a genuine material issue of fact between the Auplicants' affiant, the Staff's aff&&nt (2d), and the PSAR, Table og(g 114.2-1 (Amendment 5), attached with my notations.

o n

While CP&L claims t,

(no suoporting square footages are provided) they can store about 7.5 oo gg (55-ga11cr)

N times the normal 1020 drun capacity of the Harris Waste Processing o

gu:s

-8 Building on-site, this amount is only about a year's storage at the 4

Y Table 11 4 2-1 level.

CPlcL presents no discussion of this table or OE mte the reasons for differences between it and their affiant Warriner's statement (item 10,p.5 of affidavit).

Stafr noticed the discrepancy, and says it's OK, but they never explain why.

They-just offer their Judge Kelley crally approved filing on this date; Staff Resporse was received 5/30784

, second affiant's unsupported opinion (Willis affidavit, item 1h, n.h).

The Staff says they've done a calculation but do not provide it.

It's hard to respond to a calculation you can't see.

(attached)

However, examination of the FSAR Table shows some serious discrepancies f

Evidently, Applicants' affiant simply halved dae number of drums in the rightmost column of the Table, assuming volume reduction as in note ***" of the table for evaporator bottoms.

A conservative calculation on the maximum volume shown in the table gives about a year's storage even using the whole WPB avcilable space to store LLRW.

The halving is unjustified, as shown by the calculations I made on the attached Table.

The compressed dry solids are already allowed h:1 reduction of volume, and then connuted as 6 ft per drum -- close to the 7 33 ft maximum capacity of a 55-ga11on drum.

Moreover, re-expansion of compressed material, and space-filling problems where the LLRW is solid (as here) and may have shape or objects in it that won't fully fill a space (like trash in a trash can).
Finally, used protective clothing and so on may not stay comnressed even to 4:1.

But CP&L's halving the numbers of drums implies that each

$$ gallons drum will hold 10 or 12 cubic feet of LLRW.

That just isn't so.

The internal volume is only about 7 and 1/3 cubic feet.

Now there seems to be no penalty for errors (or false statements or misicading ones) made by Staff or Applicants' affianta, but at the least affidavits so far discrepant with the information in the FSAR are a material issue of fact.

Finally, the Staff's " Turkey Point test" ("Resoonse at 7) held that 6 years' safe storage was enough.

If corrected for errors, as shown above, the Harris facility can hold at most a year or two

's worth of LLRW.

This isn't enough time -- the facility has an operating life of 25 Years estimated) and there 's no guarantee of a ratified cwget by 1985 nor h(ave Staff o,r Applicants asserted any such guarantee.jgnfgw