ML20116A910

Petitioners Reply to NRC Staff & Gpun Answer Opposing Request for Hearing & Petition for Intervention of Nuclear Info & Resource Svc,Oyster Creek Nuclear Watch & Citizens Awareness Network.* W/Certificate of Svc

ML20116A910
Person / Time
Site:	Oyster Creek
Issue date:	07/18/1996
From:	Decamp W, Gunter P, Katz D AFFILIATION NOT ASSIGNED, CITIZENS AWARENESS NETWORK, NUCLEAR INFORMATION & RESOURCE SERVICE
To:	Atomic Safety and Licensing Board Panel
References
CON-#396-17801 OLA, NUDOCS 9607290026
Download: ML20116A910 (17)

Text

{{#Wiki_filter:; 1 1 /'/80/ - July 18,1996 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION s BEFORE TITE ATOMIC SAFETY AND LICENSING BOARD 4 'b S Before Administrative Judges: 4 G. Paul Bollwerk, III, Chairman 4 e D. Charles N. Kelber Dr. Peter S. Lam g j g 1996' g In the Matter of ) g ) General Public Utility Nuclear Corporation ) Docket 50-219 OLA

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OL ) Tech. Spec. 5.3.1.B ) Movement ofHeavy Loads Over Ovster Creek Nuclear Generatina Station ) Irradiated Fuel l PETITIONERS REPLY TO NRC STAFF AND GPUN ANSWER OPPOSING REQUEST FOR HEARING AND PETITION FOR INTERVENTION OF NUCLEAR INFORMATION AND RESOURCE SERVICE, OYSTER CREEK NUCLEAR WATCH, AND CITIZENS AWARENESS NETWORK INTRODUCTION Pursuant to ASLB Order (Scheduling Filing Deadline for Supplemental Intervention Peitions and Responses and for Prehearing Conference) dated July 3,1996, petitioners Nuclear Information Resource Service (NIRS), Oyster Creek Nuclear Watch (OCNW) and Citizens 1 Awareness Network (CAN) submit this Reply to both the General Public Utility Nuclear (GPUN) Answer (June 21,1996) and NRC Response (June 26,1996) Opposing Request for Hearing and Petition for Intervention of Nuclear Information and Resource Senice, Oyster Creek Nuclear Watch, and Citizens Awareness Network as penains to the Oyster Creek Nuclear Generating Station's (OCNG) proposed operating license amendment to Technical Specification 5.3.1.B. i t 9607290026 960718 PDR ADOCK 05000219 0 PDR ob

e 2 BACKGROUND On April 15, 1996, GPUN applied to modify the technical specification for OCNGS which currently restricts movement of heavy loads over irradiated fuel to weights no greater than a single fuel assembly. The license amendment application is necessary for OCNGS to complete the loading of NUHOMS dry cask. The task will require the movement of the shield plug and hoisting mechanism totaling 7 tons over the fuel pool storage pond and over a NUHOMS dry shielded cask (DSC) which would be submerged in the storage pool and loaded with up to 52 irradiated fuel assemblies. On June 6,1996, NIRS, OCNW, and CAN Sled a Request for a Hearing and Petition To Intervene in the GPUN license amendment application process. On June 21,1996 GPUN responded that the petitioners should not be granted standing for a hearing on the proposed amendment for OCNGS. GPUN argues that none of the petitioners have demonstrated that they will be injured by the proposed amendment. GPUN additionally argues that the petitioners should be denied discretionary intervention in this proceeding because the petitioners have not demonstrated that they will make a contribution to a hearing or otherwise satisfy the standards for discretionary intervention. On June 26, 1996, the 'NRC staff responded that the petitioners should not be granted standing for a hearing on the proposed amendment. NRC similarly argues that none of the petitioners have demonstrated that they will be injured by the proposed activity. PETITIONERS REPLY TO GPUN ANSWER IN OPPOSITION The petitioners respectfully take issue with several of GPUN's responses in opposition to i the request for a hearing and right to inten ene. 1.) GPUN responds to the petition by arguing that the " narrow amendment only addresses the movement of one shield plug over a limited number of fuel assemblies that are in the DSC, inside the transfer cask, inside the Cask Drop Protection System (CDPS), under 20 feet of water inside the spent fuel pool, and inside the reacter building." GPUN further states its intention in footnote 3 that "the spent fuel that GPUN intends to place in the DSC has cooled at least 10 years." GPUN Answer at 3. I

3 In reply, the petitioners establish that the shield plug movemect could occur over potentially degraded fuel assemblies loaded into the DSC. The petitioners point out the Daily Event Repon dated June 16,1995 (Reportable Event Number: 28954) describing the June 15, 1995 event at Oyster Creek where fuel assembly UD003Y stmeturally failed while behg transferred from one cell location in the fuel pool to another cell. [ Attached]. This fuel assembly was discharged to the irradiated fuel pool on April 21, 1980 and the fuel channel had been removed from the assembly on April 4,1984. The petitioners additionally point out OCNGS Licensee Event Report dated July 1,1986. [ Attached] The LER indicates that at least forty-seven (47) fuel bundles have cladding failure stating that the event "has safety significance in that a primary barrier against fission product releases has been breached." The petitioners bring forward their concern that the material condition of an undetermined number of irradiated fuel assemblies in the storage pool at least ten years have undergone documented deterioration to the fuel rod cladding and fuel bundle assembly integrity. In light of these events where irradiated fuel assemblies are falling apan under their own weight while being transponed by the refueling bridge and also experiencing deterioration of the 4 I fuel rod cladding, the petitioners present concerns regarding what assurance are there that other weakened fuel assemblies will not be placed into the DSCs? If such weakened irradiated fuel assemblies do get placed in DSCs, what are the consequences on recriticality and shielding if they break apart and disintegrate within the cask as the result of a potential shield plug drop accident?' The petitioners interpret the deterioration of fuel assemblies and fuel cladding to constitute a threat of palpable injury-in-fact when associated with a potential accident resulting from the 1 reduction of safety margins governing the movement of heavy loads over irradiated fuel.

2) GPUN responds that the crane capacity far exceeds the weight of the shield plug and i

lifting devices totaling seven (7) tons. GPUN Answer at 4. The petitioners are concerned with the more relevant fact that the shield plug and the lifting yoke weigh 28 times more than the heavt:st load currently allowed to be carried over irradiated fuelin the fuel pool. The petitioners poli t out their concerns with regard to what could be the consequences of dropping such a multiplied load on a cask containing up to 52 irradiated fuel bundles? As previously stated, the petitioners ce add'.tionally concerned with the dubious

e l 4 l \\ and potentially weakened condition of an unknown number of fuel assemblies ' Aded into the cask subjected to such a drop accident.- The petitioners interpret that such an event consticutes u l-credible accident with an increased risk and threat ofpalpable injury-in-fact. i

3) GPUN describes the design features that will prevent the shield plug from falling.

These features include the employment of"four steel cables bolted at' four separate locations on the shield plug and at four separate locations on the transfer cask lifting yoke, and each of these cables is independently capable of supponing the shield plug." GPUN Answer at 4. GPUN states earlier in its response in footnote (1) on page 2 that " transportation casks of spent fuel have been j loaded and sealed in the Oyster Creek spent fuel pocl using a top shielding lid with a function, l size, and weight analogous to the DSC shield plug." GPUN Answer at 2. The petitioners are concerned with whether or not GPUN used the proposed design features as stated on page 4 for the movement of the shield plug while conducting the loading of the transponation casks? Ifnot, why not? ) j i q

4) GPUN states "this amendment does not have a clear potential for offsite consequences 1

affecting the general public" GPUN Answer at 11. The petitioners argue that Technical Specification 5.3.1.B which prohibits loads from exceeding a single fuel assembly. over irradiated fuel was emplaced to prevent or to make extremely unlikely circumstances where human error a echnical failure (mechanical and/or electrical) could enter into fuel pool activities and potem._.iy damaging irradiated fuel assemblies or components designed to suppon irradiated fuel stability. NRC has recognized in NUREG/CR-4982 " Severe Accidents in Spent Fuel Pools in Suppon of Generic Safety Issue 82," as stated in the section regarding Structural Failure of Pool that "Because of the massive reinforced concrete structure of LWR spent fuel storage pools, designed to Category I seismic criteria, initiating events that would lead to a structural failure are extremely unlikely. Onthe other hand. a structural failure that resulted in raoid and comolete drainine of the water from the i rool would have serious consecuences." [Attachedl The NRC recognizes that both human I i " Severe Accidents in Spent Fuel Pools in Support of Generic Safety Issue 82." NUREG/CR-4982, _ BN L-NUREG-52093, July, 1987, p.16. 4 l l

c. i 5 l i error and technical failure will contribute to the increased risk of accidents that carry a potential f for introducing the structural failure of the pool. The petitioners are concemed that by l r marginalizing the technical specifications governing load limits over irradiate fuel in the fuel pool GPUN has in fact increased the risk of a load drop accident and the " serious consequences" as l referenced by NUREG/CR-4982. The petitioners interpret these " serious consequences" to be a f threat of palpable injury that is in fact increased by the proposed reduction in the current safety margins governing irradiated fuel pool activity. Furthermore, the petitioners are not aware that GPUN has evaluated the integrated risk or - the consequences from an accident involving the full inventory ofirradiated fuel stored in the fuel pool. GPUN's current irradiated fuel risk assessment assume that only one-third of the reactor core fuel will be damaged. The petitioners assert this to be an invalid assumption. The accident that the petitioners are concerned about involves the shield plug drop and the loss ofirradiated fuel pool cooling water and the capability to cool the stored irradiated fuel. In a i drain down accident, the fuel discharged from the reactor within the past three to four years will melt and sustain a fuel cladding fire. In a high density storage rack system, every irradiated fuel assembly could be involved. The petitioners are additionally concerned that GPUN has already removed a number of fuel assembly channels which are designed to act as fire barriers. The NRC has already recognized that certain industry actions have eroded the analysis of the risks from a irradiated fuel pool accident evolving out of expanded irradiated fuel storage in the pools. The NRC study " Regulatory Analysis for the Resolution of Generic Issue 82, 'Beyond l Design Basis Accidents in Spent Fuel Pools' " re-examined a fuel pool accident resulting from among other things a heavy load drop involving irradiated fuel and concluded that it could result in a total radiation exposure of 8 million person-rem to 667,588 people living within 50 miles of j-the reactor and resulting in $3.4 billion in 1983 dollars of property damage. i As the petitioners have already stated the proposed amendment to Technical Specification l 5.3.1.B constitutes another erosion in protective actions with associated increase in risk to the public health and safety. l " Regulatory Analysis for the Resolution of Generic Issue 82,'Beyond Design Basis Accidents in . Spent Fuel Pools'," NUREG/CR-1353, US NRC, April 1989, p.4-42.

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5) GPUN states "The shield plug handling in this amendment request does not inglicate L

reactor safety'in any way." GPUN Answer at 10. The petitioners regard a drop accident involving the shield plug and hoisting mechanism as a credible event with the potential loss of inventory of fuel pool cooling water by w2y of rupturing the fuel pool steel liner and/or funher structural failure of the pool. The petitioners assen that a significant amount documentation and discourse have been generated on BWR fuel pool deficiencies as a result of a, filing under 10 CFR Pan 21 Repon of-Substantial Safety Hazard by Messrs. David Lochbaum anil Donald Prevatte' Central to the issues presented in the Part 21 filing and subsequent documents is that-the ' mechanistic relationships of the fuel pool cooling system cannot be taken out of context with safety-re!ated systems and components in the same reactor building potentially causing the failure of safety-related equipment for reactor operation, The petitioners funher assen that issues raised by the Part 21 filing have not been closed out by the NRC and the licensees. Therefore, the petitioners argue that loss of fuel pool cooling capability resulting from a l . drop accident involving the shield plug cannot be summarily dismissed by GPUN as without merit or implication for reactor operation. k

6) GPUN states "Nor is a spent fuel pool accident credible, given the redundan:y of l

cables used to lift the shield plug." GPUN Answer at 10. l The petitioners argue that GPUN makes a irradiated fuel pool accident more credible by reducing the current safety margins for limiting the weight and movement activity ofloads over I irradiated fuel in the fuel pool. The petitioners assen that the redundancy of cables used to lid the shield plug does not make a spent fuel pool accident an incredible event. For example, human i error can not be completed eliminated merely by the introduction of redundant cables. Human error in the movement of heavy loads can be eliminated, however, by restricting activity and l establishing weight limits over or near irradiated fuel. As stated in Generic Letter 85-11 " Control of Heavy Loads at Nuclear Power Plants: Resolution of Phase II," NUREG-0612 " presents an overall philosophy that provides a 8 "Susquehanna Steam Electric Station Docket No.50-387 License No. NPF-14,10CFR21 Repon of Substantial Safety Hazard," November 27,1992, Dasid Lochbaum and Donald Prevatte, p.2. .~

defense-in-depth approach for controlling the handling of heaw loads. The approach is directed to preventing load drops. The following summarizes this defense-in-depth approach: 1.) Assure that there is a well designed handling syste:n; 2.) Provide sutTicient operator training, load handling instructions, and equipment inspection :o assure reliable operation of the handling system; 3.) Define safe load travel oaths and crocedures and ooerator trainine to assure to the extent cractical that heavy loads are not carrie:i over or r. ear irradiated fuel or safe shutdown tauioment " d. NUREG-0612 further states that "most of de risk appears to be associated with carrying heavy loads over or in a location where spent fuel could be damaged."5 The petitioners focus on the third bullet noted in NUREG-0612 which specifies the limitation of human-directed mechanical activity "over or near" irradiated fuel. The petitioners assen that the defense-in-depth concept is the basis of Technical Specification 5.3.1.B. Therefore, GPUN is proposing to amend its technical specifications which will result in an erosion of the defense-in-depth risk management philosophy as it specifically applies to irradiated fuel pool activities. An increase in human directed activity and de weight ofloads being moved over or near irradiated fuel constitutes an increase in -isk of human error, mechanical and/or electrical failure of load bearing equipment which could result in a heavy load drop on irradiated fuel and/or the ruptm-ing of the fuel pool liner thereby affecting larger inventories ofirradiated fuel in the storage racks. Such increased activity further.eopardizes e public health and safety

7) GPUN states "Even if the shield plug were somehow dropped, it would fall only within the CDPS, and can not fall in the spent fuel storage area of the fuel pool." GPUN at 10.

The petitioners argue that while GPUN is accurate in its claim that a dropped heavy load would not fall so as to directly damage irradiated ibel in the spent fuel storage area, the petitioners have already pointed out 1) the damage resu!-ing Som a shield plug drop that is of concern focuses on the irradiated fuel in the DSC with the potential for recriticality and; 2) the damage to the spent fuel pool { i.e. the steel liner) with 6e potemial drain down of the fuel pool thus adversely affecting irradiated fuel in the storage racks. Cornpletion of Phase II of " Control of Hean 1. cads At Nuclear Power Plants" NUREG-0612, jGeneric Letter 85-11), June 28,1985, US NRC, Enclosure 1. p.1. Ibid. p.4

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8) GPUN states "the amendment to Technical Specific = ion 5 3.1. Ls invches n: riticality considerations or significant accident analyses." GPUN Answer at 10.

The petitioners have not seen any analysis by GPUN which reviews se consecuences of a - shield plug drop event rupturing the fuel pool steel liner restdting in a prol drain d:wn and a criticality of the fuel in the DSC and storage racks. Additionally. the petitic ers have nn seen any analysis by GPUN which reviews the consequences of a shield plug drop cro a DSC ;:aded with 52 irradiated fuel assemblies a number of which are potential already in a s _te cf dete oration of the fuel rod cladding and the structural integrity of the fuel bundle assemE.y as previcusly stated by the petitioners. Without such analysis, it is impossible to detennine whecer er not citicality is a significant consideration. The. petitioners further note that current risk management against fael nol chicality at Oyster Creek is solely dependent on criticality prevention. The petitioners asser; that me first line of defense in that prevention strategy involves the current res:rictions esablished by Technical Specification 5.3.1.B. to limit human directed mechanical activity and weigm Fmit rest:icions.

9) GPUN states "The petitioner must allege some threrer.ed. or acual injury resulting from the action" and "The threat ofinjury must be real and imme:Iate not cerectural or hypothetical." GPUL ^ awer at 11.

As stated in the presious paragraph, the petitioners assen -hat de ec=seque ces of an irradiated fuel pool accident evolving out of a drop of the shield plug invohing -he ir adiated fuel in the DSC and the rupture of the fuel pool liner constitutes a credible crea: ofi ury to the public. 10) GPUN states "CAN and its representative mamoer re lccated :2 central Massachusetts, over 200 miles from Oyster Creek in Centri New Jersey Even i an initial operating licensing proceeding petitoners located very far hm a pla-are gene-dy denied standing." GPUN at 16. The petitioners reassert that it is the position of the pemioner CAN -hat shou : GPUN be granted a license amendment to change technical specie:ations cu ently prohriting the movement of heasy loads greater than a single fuel assembly over irradiate: faei -hat me adoption

e 9 of the amendment will be established as a precedent for similar plants, namely Vermont Yankee. As evidenced by current regulatory activity the issue of heavy load movement in nuclear power plants involving irradiated fuel is a significant safety issue. The petitioners have an understanding for the imponance of their timely participation in precedential proceedings which is likely to affect and direct near term activities at their respective reactors. The petitioners reiterate their understanding for the need to focus their resources as these precedential issues'arise rather than approach these same issues on a piecemeal basis. Therefore, the petitioner CAN seeks the opportunity to participate in a democractic process so as to make a timely contribution to the record in matters that are likely to affect and direct vital safety significant activities at their respective nuclear power stations. Accordingly, the Ccmmission should exercise its discretion to grant petitioners standing to intervene. PETITIONERS REPLY TO NRC RESPONSE IN OPPOSITION h

1) NRC states that the " Petitioners misread Bulletin 96-02." and "It is GPUN's 50.59 analysis for movement of the 100 ton dry cask that Bulletin 96-02 concerns, not a 50.59 analysis for movement of the dry cask shield plug." NRC Response at 8. The NRC further states that

" Petitioners seem to have confused the proposed action with movement of the 100-ton cask which is the subject matter of the NRC Bulletin on which Petitioners rely by which is not the subject of the amendment request." NRC Response at 13. ? The petitioners did not misread Bulletin 96-02 " Movement of Heavy Loads Over Spent Fuel, Over Fuel In The Reactor Core, or Over Safety-Related Equipment." The petitioners have i included Bulletin 96-02 as background documentation for proposed activities at Oyster Creek i involving the movement of heavy loads over or near irradiated fuel. The petitioners assert that the document relates to the specific shie.id plug license amendment application to multiply the current technical specification limiting safety system settings over irradiated fuel in the fuel pool by 28 times. i %m

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2) NRC states with regard to "IN 96-26: Recent Problems with Overhead Cranes" that l

the " Petitioners do not indicate how or why they believe this IN is applicab!e to Oyster Creek and it is not apparent on its face that it has any applicability to Oyster Creek." NRC Response at 9. The petitioners have included "IN 96-26: Recent Problems with Overhead Cranes" in the petition to document ongoing and current industry problems associated with the failure of cranes and inappropriate licensee activities regarding crane equipment at nuclear power plants. As stated in the petition, IN 96-26 indicates that potential deterioration of crane equipment and/or inadequate crane equipment combined with inappropriate licensee activities can increase associated risks with activities over or near irradiated fuel. While the Information Notice cites two specific examples practices recently discovered that have adversely impacted safe crane operation, it is not an all inclusive document of other licensee practices or conditions affecting i i safe crane operation. The petitioners assert that OCNGS, as one of the oldest reactors in the United States, is subject to the deterioration of crane equipment and/ or inadequate crane equipment. The petitioners further assert that the issuance ofIN 96-23 underscores their concern that GPUN proposes to undenaken a modification ofits technical specifications originally designed to limit human directed mechanical activity which is subject to error and failure. i

3) NRC states that with regard to the " Preliminary Notice concerning an event at Hatch on which Petitioners rely also concems lifting but that event did not involve a heavy load. It does j

1 not relate to any aspect of the proceeding in which Petitioners seek intervention." NRC Response j l l at9. The petitioners find the Hatch load drop event particularly relevant and have included it in the petition for several reasons: A.) The weight of the bolt dropped in the Hatch fuel pool was less than the weight of a single DWR fuel assembly as currently determined as the limiting load in Oyster Creek's technical t specifications. The petitioners have included this event as a demonstration that loads dropped in i the fuel pool of considerable less weight than determined by technical specification have occurred and resulted in damage to the fuel pool steel liner. An accident involving a load 28 times heavier

11 1 than currently allowed can be expected to produce significantly more damage with a significantly greater drair down of the fuel pool cooling water inventory. l B.) The classic " drop" analysis performed by licensees involves postulating the dropping I of a single fuel assembly onto a rack containing irradiated fuel. The damage is confined to the dropped asse.mbly and those assemblies it impacts until it comes to rest. The petitioners are l concerned about a load drop in the fuel pool that would miss the fuel storage rack and puncture I the line. In this specific case, the petitioners are not concerned about the fuel storage racks which are not in proximity to the cask loading area. The petitioners cite this event with regard to analysis of a load drop of the shield plug and associated lifting apparatus onto the fuel pool steel liner representing approximately 44 times the Hatch event and the review of the consequences in the rupture of the fuel pool steel liner. The petitioners have documented the Hatch event in the petition to indicate that loads less than a single fuel assembly have been dropped in the fuel pool l which resulted in damage to the fuel pool. C.) The petitioners have obviously included the Hatch drop accident in order to introduce concerns about a postulated drop of the shield plug and lifting apparatus at OCNGS. What if the l gash torn in the steel fuel pool liner at Hatch had been larger resulting in a greater leak rate and subsequently a greater loss of cooling invento:y before isolation was achieved? This is the concern that the petitioners raise by documenting the Hatch event as relevant to the potential shield plug drop onto the OCNGS fuel pool steel liner in proximity to the DSC. The petitioners are unaware that GPUN has analyzed the radiological consequences frem a loss of the fuel pool water level at OCNGS.

4) NRC states regarding the petitioners attachment of the Daily Report concerning Indian Point that the petitioners' " generalized concern about lifting does not constitute identification of an aspect of the proposed amendment on which Petitioners seek intervention." NRC Response at 9.

The petitioners have included the Indian Point Unit 2 Daily Repen to document a current event and a specific accident involving a metal transpon container weighing 5000 pounds that was dropped onto the fuel handling floor in Unit 1 on May 7.1996. T'.e petitioners assert that documentation underscores their concerns that accidents have happened involving heavy load l

4-9 12 drops and will continue to happen. The petitioners have included this documentation in a repetition of their concern that GPUN intends to reduce safety margins currently in place which restrict human directed mechanical activity over or near irradiated fuel.

5) NRC concludes the " Petitioners have failed to identify an aspect of the subject matter of the proceeding on which they seek to intervene." NRC Response at 9.

l The petitioners argue that they have sresented cogent points of concern and supporting documentation to assert that the proposed license application erodes current sat j margins in . place to prevent human error and/or mechanical and/or electrical failure of equipment and procedures from causing an accident involving irradiated fuel in the fuel storage pool. /7 / w- ~ l Paul Gunter Nuclear Information and Resource Service 142416th Street NW Suite 404 l Washington, DC 20036 (202)328-0002 (202)462-2183 FAX email-gunternirs@aol.com or pgunter@igc.apc.org b William decamp, Jr. 8 '/' Oyster Creek Nuclear Watch l PO Box 243 Island Heights, NJ 087732 (908)714-0334 (201)376-6639 email-102115.3501@compuserve.com i l Deborah Katz C/ l Citizen Awareness Network PO Box 83 Shelburne Falls, MA 01370 (413)339-4374 4 i (413)339-8768 FAX i i l l

d - - - ' ~ ~ ^ ~ ~ ~ ~ ~ ~ ~ ~ ~ 4 j NUREG/CR-4982 BNL-NUREG-52093 Severe Accicent:s in Soent ue 3 in Suaaor' of Generic Sa"ety 00 s Issue 82 c a 4 t Manuscript Completed: June 1987 Date Published: July 1987 Prepared by V. L. Sailor, K. R. Perkins. J. R. Weeks. H. R. Connell Department of Nuclear Energy Brookhaven National Laboratory Upton, New York 11973 Prepared for Division of Reactor and Plant Systems Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington DC 20555 NRC FIN A3786

estimated f recuency of 1.4x10-0Ry for an accident initiated by loss of spent 4 fuel pool cooling, j Criginally, the spent fuel : col at the Ginna plant had only one installed cooling train ith a "stid-<nountec" backup pump and heat exchanger.

However, a second cooling train was to nave been installed in 1986."

Because of the third Option for cooling at Ginna (the skid-mounted system) the probability ) estimate for an accident initiated oy a pool heatup event should be reduced to 5x10-7/Ry, i.e., anout a factor of 3 smaller than for the BWR case analyzed in l Ref. 2. For other PWRs with a typical two train pool cooling system, a some-what higher failure frequency (about 10"/Ry) would be expected. 2.2 Structural Failure of Pool Because of the massive reinforced concrete structure of LWR spent fuel storage pools, cesigned to Category I seismic criteria, initiating events that would lead to a structural failure are extremely unlikely. On the other hand, a structural failure that resulted in rapid and complete draining of water from tne pool would have serious consecuences. Probabilities of events that might result in loss of structural integrity are estimated in the following two sucsections. 2.2.1 Structural Failure of Pool Resultino from Seismic Events Procecures a>1c conventions for a cetailed probabilistic risk assessment (PRA) of seismically-induced core damage accident sequences have been present-ed in Ref. 5. The reconmended methocology could be applied to spent fuel i pools as a separate plant component, or could be coupled to a core damage se-quence that mignt occur simultanecusly curing a severe earthquake. To date the seismic PRA methodology has not been rigorously applied to spent fuel pools. Seismic risk analyses consist of three basic steps: l'

ortrayal of :ne seismic hazar: in terms of annual frequency of ex-ceedance as a function of some ground motion parameter (e.g.,

the peak ground acceleratien); 2' assessment of the pro::acility that the capacity of a structure or component can survive the seismic event, often expressed in the form of a 'ragility :urve.nicn is ne inverse of the capacity for survi-val; and, finally, T a logic model, e.g., an event tree, whicn relates a seismic-induced f ailure to a nigher or:er event that results in some category of ra-cloactive release. In princi:le, an accropriate convolution of the probability functions de-rived 'n steps 1) and 2) yiel:s a precability function for seismic-induced failure. It is recognizec that large uncertainties exist in the two input probacility functions wnicn are eflectec in the function expressing the prob-ability of f ailure.

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C5 2045 12:-- ustp; RED t - gwyrygg g, _ m p 7AICRITY 1TT23fT: N 22QU "C:D XCEN"l:33 RE?CRT - 23GICN I JUNE 15, 1995 vecification! Lican_ %_7acilitr: MR Number: 1-95-0083 Cpu Nuclear Corp. rate: 06/16/95 Oystar Crisk I Resident 3-Mail Forked River,New Jersey Dockets: 50-219 %~R/GE-2 suh4ect: Structrual Failure of Fuel Assemble nncruhls trent itaWri 28954 Discussiens On 6/15 - at 2:17 p.m., spent fuel assembly UD003Y structurally failed while being transferred from one call location in the spent fuel pool to another. cell. Fuel moves had been. in progress for about 2-3 weeks in order to rearrange the fuel in the pool. The failure occurred as theand hatt hann inserted lowered into its now location, assembly was 1,wingabout 2-4 feet. The lower tie plate, along with 41 of the 49 individ 6-8 feet to the cepersted free the funi bundle and fell nhou: fuel yim., hottom of the st: rage cell. The fuel assembly was unchanneled.' The refueling bridge operater observed a cloudy condition in the fuel pool apparently due to the release of corrosion when the failure occurred, products from the extericr surface of the assembly. The operator subsequently lifted the fuel assembly above the top of' the fuel plate that were latched to the refueling mast grapple, and there appeared (rack) to be only about aight fuel pins connected. All activities on the refuel floor promptly stopped. Samples from the fuel pool There were no releases Of radiatica detseted. water indicated some increase.in activity. due to the corro X 7 array, manuf actured by Exxon. It was first installad in th on 4/30/73, assembly f ailure occurred with Exxcn fuel in 1986, however, the bail handle, upper tie plate and the'signt sie rods were ra the fail; ire mechanism appears to be similiar, the 1986 assembly had been I dropped earlier to the bottom of a storage location. The fuel pins from that assembly were subsequently retrieved and stored by a contractor (neither GE nor Ixxon). The licensee issued a prass release, and informed the public infuel dry storage attendance at the beginning of the span: hearing en 6/15 at 7:30 p.m. The licansee completed a video inspection of the failed assembly. The top .and remained in a 7 X 7 cf the rins in the cell appeared to be intact,::ere were, hv.= var, several type ar sy (due to the grid spacers). on top of the springs located in the adjacent cells. "he springs rest fuel assemblies between the individual pins and the upper tie place. The licensas c0nfir:cd eight tie rods connected to the upper tie plate. Therelative to m icwer and plug for all eight :14 rods were intact d {brc%an) the integrity Of the fuel pins. Hcwever, they were all damage f l i { i

0:./2065 12:54 USFRC REGION 1 - CF CE REG.'CM. - 121 462 22E2 IEWs w; JUNE 15, 1995 REGION I MORNIMG REPORT 7AG: XR Number 1-95-0033 (cont.) the bottom where a threaded portion engages the lower tie plata. The licensee is develeping a recovery plan. The licensee will discuss their i at ) plan with Region I on Friday 6/16 prior to initiating any recovery actions. (2645 storaga locations) spent fuel There are currently about 2048 are Exxon assemblies in the SFP. Nearly half of them (estimata = 800) fuel; some are 7 X 7, some are B X S. For the currently scheduled spent fuel rearrangement activities, about 100~more Exxon fuel assamblies are expected to be moved. 1 Recional Action: Conference Resident Inspector are following licensee recovery actions. call to discuss recovery with Regicn and NRR prior to moving the assembly on 6/16/95. (610)337-5146 Cont.get John Rogge Larry Briggs (609)474-2589 Jacque Durr (610)337-5224 ) 4 4 i

...a x a > s s x D w GPU Mudeer Corporetton g ggf Post C"<e Son 388 Route 9 Sourn Fe' hec Q ve'. New Je'sey o8731 c388 609 97140C0 Writer s Direct Cial Numbet j I February 6,1987 ) U.S. Nuclear Regulatory Consission j Document Control Desk Washington, DC 20555

Dear Sir:

i

Subject:

Oyster Creek Nuc1 car Generating Station Docket No. 50-219 Licensee Event Report Rev sion d This letter femards one (1) copy of Licensee Event Report (LER) No. 86-016, Revision 1. Vertical lines in the right sice margin indicate those sections of the LER that have been revised. Very truly yours, i mJ Peker. eclier ~ Yice President and Director Cyster Creet PBF:BP: dam (*0205A) Encs. cc: Dr. Thomas E. Murle, Aoministrator J Region I U.S. Nuclear Regulatory Conunission 631 Part Avenue King of Prussia, PA 19406 NRC Resident Inscer. tor Oyster Creek Nuclear Generating Station Forted 31ver, 4J 08731 j Mr. Jack. N. Donenew, J r. U.S. Nuclear Regulatory Cocuission 7920 Norfolk Avenue, Phillips 31cg. j Bethesca, MD 20014 Mail 'Stoc Mo. 314 I C'I g }g i

(.*., .a. w a uta,os, c % m. a Ow$3 M OJI M s. UCENSEE EVENT MEPORT (LERI i ..ou r g c.., m m. ai = = = = _ Oyster Crea.. I."'i t 1 lotsioioioe i119: 1 IcFlo r3 ... o. i ( r"Et Cl20 ~iit'JRES DUE TO PELLET / CLAD INTERACTIONS ,,,~n.. .-,n,. ,,...a,.-,.. f .., :.. t.. i.... =-;;;h -==: ..j u. ..c.6.....-. xc.. '.u l otstototes t ll

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.sco. o= l, J m l = ~. - 4 ~ During fuel sipring operations while the reactor was in cold shutdown, it was i discoverad that forty-seven (47) fuel bundles tac claading failures. This event has safety Significance in

• hat a primary barrier against fission product releases has been Dreached. The plant operated with this condition for at least part of j

Cycle 10. TN cladding f ailures appear to be the result of pellet / clad i n te rac t1:n. l l 1 i l s Wf /= ,~ C9~ i F 0 4^*-F7 0 00/. ,.J / P"U ADf r x OMOy ! 9 i

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= = -- ! m i 01 Il 6 -{ q l 0R O' 0 l3 L Oyster' Cree 6 Unit 1 olsfotolol2;1l9 Ol E j DATE OF DISCOVERY The fuel cladding failures were determined to be reportable on July 7,1986. !t appears likely that the majority of the failures occurred near the end of Cycle 10 opera tion. IDENTIFICATION OF DISCOVERY f The fuel cladding f ailures were discovered during fuel sipping operations ] l wnile tne plant was in coli shutdown. The event is cc-sidered reportable under . 10CFR50. 7 3 ! a )( 2 )( i i ). i l CONDITIONS PRIOR TO DISCOVERY The plant was in operation f rom November 1984 througn April 12, 1986. The l j plant was tnen brou;nt to a cold snutdown for a refueling outage. DESCRIPTION OF OCCURRENCE l During Cycle 13 oDerstion, it was noted that the offgas level continually increased t9ecugMout the cycle ind the fission product ratios were indicative of fuel f ailures. Tire Sun of 6 F.G.* 1131 '!133 Period (5JAE. uCi/sec) (Rx Coola9t) j BOC 50100 .069 EOC 2:1000 144 fuel sipping oce ations identified forty-seven (47) ' fuel Sunsecuent to shutdown, Dundlas having cladding f ailure. All of the fuel f ailu-es occurred in. the Exxon fuel. The 9umoe-of cladding f ailures was consistent with the observed of fgas levals. AP0ARENT CAUSE OF OCCURRENCE l l The :1 adding f ailures accear to be the result of pellet / clad interaction. .This conclusion is ased upon the hign degree of symmetry of the failures. It is l unlikaly thtt any othar f ailure mechanism would produce failures of this type. r.G. - Fission "ases SJ1E - Steam Jet Air Ejector

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'f 6 l Q' W. Oyster Creek, Unit I o ls t o j o l e l 211 l9 816 0l1l6 ql 0l2 0F 0 l3 - c . on the pellet / clad interaction appears to be the resalt of: 1. Inability of the Power Shape Monitoring System (PSMS). Rev.1, to l adequately monitor Preconditioning Interim Operating Management i Recommend.tions (PCIOMR) envelopes and ramp rates. f 2. Imoroper Operational guidance which resulted in the occurrence of l significant " power shocks" in fuel susceptible to pellet / clad failures. t ANALYSIS OF OCC11RRENCE AND SAFETY ASSESSMENT ~he fuel cladding is 4 primary barrier against the release of radioactive fission products. The failure of the cladding causes fission products to circulate throughout the primary coolant system, eventually plating out on various l reactor comconents. This results in higher dose rates to personnel performing maintenance on these components. It can also result in higher of fsite activity levels. l l I CORRCOTIVE ACTIONS l Several careective actions have been comoleted wnich reduce the possibility 1 l of futura claddino failures rasulting from pellet / clad interaction. The corrective actions are as follows: 1. The power Shace Monitoring System Program was revi ed (Rev. 2) to allow more accurate monitoring of PCIOMR envelopes and ramp rates. 2. Operating procedures were revised to provide additional guidance to prevent exceeding PCIOMP recorsnendations. 3. Fuel considered to be susceptible to pellet / clad type failures was moved to low duty regions of the core. 023SA) l I 1

3 4 July 18 UNITED STATES OF AMERICA .~ m NUCLEAR REGULATORY COMMISSION y Jill.19 1999 BEFORE THE ATOMIC SAFETY AND LICENSING BClARD g., SETMCG ggggy M Y In the Matter of ) g ) O/ 6 General Public Utility Nuclear Corporation ) Docket 50-219 OLA ) Tech. Spec. 5.3.1.B ) Movement of Heavy Loads Over Ovster Creek Nuclear Generating Station ) Irradiated Fuel CERTIFICATE Of SERVICE I hereby certify that copies of " Supplemental Petition and Reply" for Nuclear Information and Resource Service, Oyster Creek Nuclear Watch and Citizens Awareness Network have been served by Facsimile Transmission and/or by U.S. Mail, first class on this date July 18,1996: G. Paul Bollwerk, III, Chair

• Office of the Secretag (3)*

Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Attention: Docketing and Service Branch Washington, DC 20555 Dr. Peter S. Lam

• Dr. Charles N. Kelber*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatog Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 l Adjudicatog File (2) Ernest Blake, Jr.* Atomic Safety and Licensing Board Shaw, Pittman, Potts, & Trowbridge U.S. Nuclear Regulatory Commission 2300 N. Street NW j Washington, DC 20555 Washington, DC 20555 Ann P. Hodgdon, Esq.(1)* Atomic Safety and Licensing Board Panel Office of General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 l Oflice of Commission Appellate Adjudication U.S. Nuclear Regulatog Commission l Washington, DC 20555

k r. ,+ a m 1 1 Michael Laggen GPU Nuclear Corporation 1 Upper Pond Road. Parsippany, NJ 07054 William decamp, Jr. Oyster Creek Nuclear Watch P.O Box 243 Island Height, NJ 08732 Deb'orah Katz Citizens Awareness Network P.O Box 83 Shelburne Falls, MA 01370 Paul Gunter Nuclear Information and Resourc6 Service h6 Willaim decamp, Jr. Oyster Creek Nuclear Watch Ddnna ~ p; Deborah Katz Citizens Awareness Network Dated July 18,1996 i

• Certification of Service by Facsimile Transmission and U.S. Postal Service, First Class.

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