ML20203G268

Contentions of Sierra Club Re Consideration of Issuance of Amends to Licenses DPR-80 & DPR-82 on Proposed Reracking of Spent Fuel Pools & Proposed NSHC Determination Before NRC

ML20203G268
Person / Time
Site:	Diablo Canyon
Issue date:	04/24/1986
From:	Ferguson R Sierra Club
To:	Atomic Safety and Licensing Board Panel
References
CON-#286-940 OLA, NUDOCS 8604280426
Download: ML20203G268 (7)

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l UNITED STATES OF AMERICA NUCLFJtR REGULATORY COMMISSION l

l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PACIFIC CAS AND ELECTRIC ) Docket Nos. 50-275 OLA

• COMPANY ) 50-323 OLA

)

(Diablo Canyon Nuclear Power Plant )

Units 1 and 2) )

CONTENTIONS ,OF_ THE SIERRA CLUB, SANTA LUCIA CHAPTER Enclosed are the contentions of the Sierra Clu b,- Santa Lucia Chapter, t-regarding the proposed reracking of the spent fuel pools at the Diablo Canyon Nuclear Power Plant.

Re ectfully bmitted, Y f

• Dr. Richard B. Ferg on Conservation Chairman Sierra Club, Santa Lucia Chapter Dated: April 24, 1986 cc: Diablo Canyon service list 8604280426 860424 PDR G ADOCK 05000275 PDR 33O 3

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Docketing and Service Branch Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Henry J. McGurren Office of the Executive Legal Director U.S. Nuclear Regulatory Commission 20555 Washington, D.C.

Fhilip A. Crane, Esq.

Richard F. Locke, Esq.

Pacific Cas and Electric Company Law Department PO Box 7442 San Francisco, CA 94120 B. Paul Cotter, Jr. , Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Mrs. Laurie McDermott CODES

731 Pacific Street, Suite #42 San Luis Obispo, CA 93401 Mrs. Sandra Silver ,

t Mothers for Peace r i

1760 Alisal Street '

San Luis Obispo, CA 93401 i

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CONTEhTIONS OF THE SIERRA CLUB, SANTA LUCI A CHAPTER, CONCERNING THE CONSIDERATION OF ISSUANCE OF AMENDMENTS TO FACILITY OPERATING LICENSES DPR-80 AND DPR-82 FOR DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2, RESPECTIVELY, AND PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION BEFORE THE NUCLEAR REGULATORY COMMISSION (DOCKET NUMBERS 50-275 AND 50-323)

I)(A) It is the contention of the Sierra Club, Santa Lucia Chapter, (Sierra Club) . tha t the report submitted to the Nuclear Regulatory Commission (NRC) entitled Reracking of, Spent Fuel Pools Diablo Canyon Units 1 and 2 and other communications between Pacific Gas and Electric Company (PG4E) and the NRC which are available to the public on the same subject (the Reports) fail to contain certain relevant data necessary for independent verification of the claims made in the Reports regarding consistency of the proposed reracking with the protection of the public health and safety, and the environment.

In particular, the Reports fail to contain data regarding:

1) the mass of a spent fuel assembly and masses of the loaded spent fuel racks (racks);

2) the spring constants used for the nonlinear springs (gap elements) to model the behavior of the racks (see e.g., p. 6-10ff of the Report);

3) the expected velocity and displacement of the spent fuel pools (pools,)

as a function of time in three dimensions during the postulated Hosgri earthquake (PHE);

4) the expected maximum velocity and displacement of the racks obtained from the computer modelling of rack behavior during the PHE;

5) the kinetic coefficients of f riction appropriate for estimating the frictional forces between the pool floor liner and the racks when eliding of the racks occurs; and

6) the dimensions and configuration of rack "H".

SIERRA CLUB CONTENTIONS PAGE 1 0F 5 PAGES

Additional data may be needed to verify claims made in the Reports.

1)(B) It is the contention of the Sierra Club that the Reports fail to include consideration of certain relevant conditions, phenomena and alternatives necessary for independent verification of claims made in the Reports regarding consisteucy of the proposed reracking with public health and safety, and the environment, and with federal law.

In particular, the Reports fail to consider:

1) collisions between racks and pool walls and collisions of various types involving groups of racks sliding in contact with each other during the PHE;

2) the resonant behavior of the spent fuel assemblies in the racks in response to the PHE and the consequences of such behavior;

3) the effects of the possible loss of pool cooling capacity on the spent fuel assemblies;

4) the statistical nature of potential f ailure of the large number of spent fuel storage system components during the PHE;

5) the consequences of possible failure of welds, materials, or structural elements of spent fuel storage system components during the PHE;

6) the comparison of the proposed spent fuel storage system with other such systems at other reactor si tes having less severe seismic design criteria;

7) alternative on-site storage facilities including:

(i) construction of new or additional storage facilities and/or; (ii) acquisition of modular or mobile spent nuclear fuel s torage equipment, including spent nuclear fuel storage casks; SIERRA CLUB CONTENTIONS PAGE 2 0F 5 PACES

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8) the use of anchors, braces, or other structural members to prevent tack motion and subsequent damage during the PHE;

9) the use of "boraflex" neutron absorbing material for all spent fuel racks; and

10) the structural integrity of the pool following collisions of the racks with the pool walls as described in (I)(B)(1) above.

Additional information may be needed to verify claims made in the reports.

1 II) It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which include the following:

A) during the PHE, collisions between the racks and the pool walls are expected to occur resulting in:

1) impact forces on the racks significantly larger than those estimated in the reports;

2) impact forces on the racks significantly larger than those expected to damage the racks;

3) significant permanent deformation and other damage to the racks; j 4) reJLetion of the spacings between fuel assemblies;

5) increase in the nuclear criticality coef ficient k(ef t) above 0.95;

6) release of large quantities of heat and radiation.

l 7) radioactive contamination of the nuctear power plant and its employees 7

above the levels permitted by federal regulations; i 8) radioactive contamination of the environment in the vicinity of the i

nuclear power plant above the levels permitted by federal regulations; i

l and j SIERRA CLUB CONTENTIONS PACE 3 0F $ PAGES L

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9) radioactive contamination of humans and other living things in the vicinity of the nuclear power plant above the 1 :vels permitted by f ederal regulations.

B) during the PHE, collisions between groups of racks with each other and/or with the pool walls are expected to occur with results similar to those described in II)(A) above.

III) It is the contention of the Sierra Club that:

A) no attempt has been made to ascertain the views of the population surrounding the reactors at Diablo Canyon concerning the proposed spent. fuel storage facilities and that the proposed reracking is probably inconsistent with these views; and that B) as discussed in Sec. II above, the proposed reracking is inconsistent with the protection of the public health and safety, and the environment; and that C) existing s torage f acilities at Diablo Canyon will be effectively used to the maximum extent practical within the next few years; and that D) adequate storage capacity at Diablo Canyon cannot reasonably be provided to assure the continued, orderly operation of the reactors.

IV) In light of the foregoing, it is the contention of the Sierra Club that: ,

(A) the Federal Government has the responsibility to provide sufficient capacity for interim storage of spent fuel from Diablo Canyon; and that SIERRA CLUL CONTENTIONS pAGE 4 OF $ PAGES

(B) the Federal Government is required by law to of f er to enter into contracts with PGAE for purposes of providing storage capacity for spent fuel produced at Diablo Canyon.

Rysp ctfully submit ed, A / pf

• ir. Richard . Fergus%n Conservation Chairman Sierra Club, Santa Lucia Chapter SIERRA CLUB CONTENTIONS PAGE $ OF $ PAGES