ML20150C378

Amended Contentions of St of Il Re Amends to Oper Lics DPR-39 & 48 to Increase Spent Fuel Storage Capacity at Subj Facils.Asserts That to Approve Amend Would Be Contrary to NRC Policy Position.Cert of Svc & Affidavit Encl

ML20150C378
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/01/1978
From:	Sekuler S ILLINOIS, STATE OF
To:
References
NUDOCS 7811240022
Download: ML20150C378 (9)

Text

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UNITED STATES OF AMERICA 0$fMe G ljf 7Bt %

NUCLEAR REGULATORY COMMISSION T 7 1 <

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IN THE MATTER OF COMMONWEALTH )

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b EDISON CO. Zion Station, Units ) #

1 and 2

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) Docket Nos. 50-295 Amendments to Facility ) 50-304

. Operating License Nos. DPR-39 )

and DPR-48 )

(Increase Spent Fuel Storage )

Capacity) )

AMENDED CONTENTIONS ,

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1. The State of Illinois contends that approval of the proposed l license amendment would be a major action of the Commission signifi-cantly affecting the quality of the human environment in Illinois.

The National Environmental Policy Act of 1969, as amended, requires the Applicant to submit an environmental impact statement with respect l l

to the proposed license amendment.

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2. Approval of the amendment request would be contrary to the NRC policy position on spent fuel storage which prohibits non-l emergency licensing of any existing storage facility prior to the adoption of an official long range policy regarding the permanent storage of spent fuel. See " Intent to Prepare Generic Environmental Impact Statement of Handling and Storage of Spent Light Water Power 1 Reactor Fuel", 40 F.R. 42801, September 16, 1975. 7 8112 4 0 0 2 7L-A. There is no emergency need to rerack as the existing storage pool contains more space than is necessary to accomodate full core discharge. gg

B. The existing pool is able to accomodate normal refueling discharges until 1981, therefore failure to grant the application at this time poses no threat of imminent shut down of the facility.

3. Should it be necessary to shutdown the Zion facility, pending the development of an alternate, away from reactor facility, the Applicant has not shown that the community currently being served by Zion would be adversely affected economically or by experiencing loss of electricity.

A. The Applicant has not explored the possibility of meeting current demand by increased use of under utilized fossil fuel plants serving the Edison system.

B. The Applicant has not considered curtailing the output from Zion in conjunction with a conservation program and coordinated 1

rate structure which would reduce the demand for electricity in the area served by Zion.

4. The amendment request and supporting documentation do not address all reasonable alternatives for managing the spent fuel problem in the short term. Such alternatives include A. physical expansion of the spent fuel storage pool B. development of an away from reactor storage facility by Applicant.

C. shipment to a federal repository

5. The amendment request and supporting documentation do not adequately discuss monitoring procedures. In the light of the proposed modification and long term storage of nuclear spent fuel the Applicant should clarify the following:

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A. The monitoring systems that are used and their ranges of sensitivity.

B. The method by which incremental airborre radio-active emissions created by the spent fuel pool expansion will be measured.

C. Methods for detecting the loss of neutron absorber material and/or swelling of stainless steel tubes in storage racks.

D. Details of a corrosion test program to monitor performance of materials used in the construction

f the racks.

E. Procedures to monitor ground water movement in the vicinity of the plant to detect leakage from the spent fuel pool. 1

6. There has been insufficient development of all credible accident scenarios.

A. The nuclear design criteria calculations for abnormal conditions are based solely on single operator error.

B. There is insufficient documentation to establish the method by which the Applicant will positively prevent the movement of heavy objects, such as shipping casks or empty fuel racks, over the pool during modification, thus accidental dropping of such heavy objects, which could lead to unacceptable damage to spent fuel or the pool liner and consequent release of radionuclides has not been precluded.

C. There is insufficient information regarding the methods by which accidental damage to stored spent fuel assemblies will be prevented during the installation of the new poisoned spent fuel i

storage racks.

D. There is no discussion of credible accidents not directly caused by the proposed pool'lodification l which could occur during the installation of the i new spent fuel storage racks. There is no discussion l of the corrective measures necessary to be taken I should such accidents occur. Examples of credible i

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! accidents' include:

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1. pool overflow

2. pipe breaks causing leaking or spraying

of irradiated water i

3. accidents involving failure of the Spent Fuel Pool Cooling systems.

7. The Applicant's discussion of spent fuel boiling is inadec j in that (1) there is no consideration given to the possibility tha:

pool might boil, and (2) there is no discussion of possible damage to fuel cladding or of the consequent release of radionuclides under such conditions; therefore there is no assurance that public health and safety will not be endangered.

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] In addition, the heat removal capacity of the Spent Fuel Pool j Cooling Systems has not been shown to be adequate to support the i

expanded pool capacity.

8. The c.mendment request and supporting documentation have not i

analyzed the long term

• electrolytic corrosion effects of using

dissimilar alloys for the pool liners, pipes, storage racks and storage rack bases, such as the galvanic corrosion between unanodized aluminum,

! I as is used in Brooks and Perkins storage racks, and the stainless steel 3

pool liner.

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1 9. The Applicant has not discussed whether the proposed modification i i l and long term storage may cause the following effects on the stored i

I j fuel: accelerated corrosion, microstructural changes, alterations in ~

j l * "long term" storage would include storage during the operating i life of the reactor.  !

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mechanical properties, stress corrosion, cracking, intergranular corrosion, and hydrogen absorption and precipitation by the zirconium alloys.

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10. The amendment request and supporting documentation do not

. t give sufficient data to fully assess the durability and performance l l

of the Boral-stainless steel tubes which form the spent fuel storage [

racks: j A. There is inadequate analysis of the corrosion rate of  ;

the tubes. l 4

B. There is no calculation of the effect of water chemistry l on the Boral within the stainless steel. l 0

C. There is no mention of the possible swelling of Boral  ;

within the stainless steel tubes, a condition which could J affect, among other things, removal of fuel assemblies from )

the racks.

a 11. The amendment request and supporting documentation do not consider possible degeneration of the Boral density due either to generic defects or to mechanical failure which would diminish the l l

effectiveness of the Boral as neutron absorber, thus leading to J s criticality in the spent fuel pool. I 1

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12. Applicant has not described the procedures it intends to ,

employ to prevent the installation and use of damaged and defective j l

racks. l l

13. The Licensee's criticality consideration is based solely I l

on the theoretical calculations using various systems such as CHEETAll I l

and CITATION to arrive at Keff.95. The Licensee should be required to submit substantiated data using actual test results so that true l

l w e 'e

6-Kgff.95 is arrived at.

14. There is insufficient information regarding the occupational radiation dosage to workers who will be engaged in rearranging stored spent fuel, installing new spent fuel racks and disposing of contaminated racks and additional radwaste to assure that occupational exposure levels will be "as low as reasonably achievable" as required by 10CFR {

Part 20.

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15. The Applicant has failed to develop a revised health care plan to cover employees injured in accident, evacuation or emergency

, situations caused by increased storage of spent fuel, therefore the public health is not assured.

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16. The amendment request and supporting documentation do not j

i include anti-sabotage and security plans; therefore there is no i

q assurance that adequate protections has been developed.

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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION

] BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

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i In the Matter of )

l ) Docket Nos. 50-295

, COMMONWEALTH EDISON COMPANY ) 50-304 i )

j (Zion Station, Units 1 and 2) )

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! CERTIFICATE OF SERVICE l I hereby certify that copies of the State of Illinois' 1

AMENDED CONTENTIONS dated November 1, 1978 in the above captioned 3 proceeding have been served upon the following by deposit in the United States mail this 1st day of November, 1978.

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! Edward Luton, Chairman Atomic Safety and Licensing j Atomic Safety and Licensing Board Panel Board Panel i U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 Washington, D.C. 20555 l Dr. Linda W. Little Atomic Safety and Licensing Appeal l Research Triangle Institute Board Panel i P.O. Box 12194 U.S. Nuclear Regulatory Commission i Research Triangle Park, N. Carolina 27709 Washington, D.C. 20555 Dr. Forrest J. Remick Docketing and Service Section i 305 E. Hamilton Avenue U.S. Nuclear Regulatory j State College, Pennsylvania 16801 Commission j Washington, D.C. 20555

John W. Rowe, Esq.

I Isham, Lincoln and Beale Richard Goddard , Esq.

i One First National Plaza Myron Rarman, Esq.

I' Chicago, Illinois 60690 Office of the Executive Legal 4 Director j U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 l

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i SUSAN N. SEKULER l Assistant Attorney General Environmental Control Division 188 West Randolph Street, Suite 2315 l Chicago, Illinois 60601 312/793-2491 4

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. - - l il UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON CO. ) Docket Nos. 50-295

) 50-304 (Zion Station, Units 1 and 2) )

)

John W. Rowe, Esq. Richard J. Goddard, Esq.

Philip P. Steptoe, Esq..

Myron Karman, Esq.

Isham, Lincoln & Beale Office of the Legal Director One First National Plaza United States Nuclear Regulatory

. Chicago, Illinois 60690 Commission Washington, D.C. 20555 NOTICE PLEASE TAKE NOTICE that I have today filed with the Docketing and Service Section of the United States Nuclear Regulatory Commission the Amended Contentions of the State of Illinois in the above captioned proceeding.

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SUSAN N. SEKULER Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 312/793-2491 1

DATED: November 1, 1978 l

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD AFFIDAVIT I, SUSAN N. SEKULER, an attorney, hereby certify the following in support of the foregoing AMENDED CONTENTIONS:

1. That I am an Assistant Attorney General with the Environmental Control Division of the Office of the Attorney General of Illinois;

2. That I am of counsel for the State of Illinois in the matter of Commonwealth Edison Co., Zion Station, Units 1 and 2; Docket Nos.

50-295 and 50-304;

3. That all facts alleged in the AMENDED CONTENTIONS attached hereto are true to the best of my knowledge and belief.

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SUSAN N. SEKULER SUBSCRIBED AND SWORN TO BEFORE ME THIS lst Day of November, 1978.

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l Notary Public

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