ML20203L536

Contentions Opposing Util Request to Increase Waste Storage by Reracking Spent Fuel Pools.Alternatives to Reracking Not Considered.Consideration of Seismic Design Premature Since Program Not to Be Completed Until 1988

ML20203L536
Person / Time
Site:	Diablo Canyon
Issue date:	04/26/1986
From:	Mcdermott L CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20203L522	List: ML20203L519 ML20203L536
References
86-523-03-1A, 86-523-3-1A, OLA, NUDOCS 8605010291
Download: ML20203L536 (2)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

-) Docket Nos. 50-275-OLA 50-323-OLA In the Matter of: )

) ASLBP No. 86-523-03-LA PACIFIC CAS AND ELECTRIC COMPANY )

April 26, 1986

)

(Diablo Canyon Nuclear d2 Power )

_Plgnt2_ Units _1_ag _ _____________

C.O.D.E.S.

CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SA CONTENTIONS ON PACIFIC GAS & ELECTRIC COMPANY'S U L POOLS _ REQUEST TO INCREASE WASTE STORAGE BY RERACKING i s to re-1.

Adequate consideration has not been given to7,alternat fuel ponds at Diablo Canyon. 1983, the veUnder the racking the spent im storage Waste Policy Act of 1982, Public Law h 97-425, January ites of such of spent nuclear fuel for civilian nuclear power d reasonably provide adequate storage capacity at t e sly operation of reactors when needed to assure the continued, or erlly owned subsidiary, such reactors (emph. added). PG&E and its twho(P.E.T.) at this time.have a c Pacific Energy Trustof Energy for storage of high level radioactive was e fuel pool's is unreasonable'and premature to considert the when spentthe long '

2. It siesmic design, as modified by the proposal; is to be completed in

) adequa e term seismic program (a licensing condition 1988, 2 years from now. Commission By ordering the long term seismic program study, the ible seismic 3.

has indicated that there are unanswered questions and poss hazards that must be investigated. t 4.

No site in California is being considered ly for a permanent because of the was reposttory for high-level readioactive waste partto extend the stora It is unreasonable seismic conditions.

acity of spent fuel pools for the same reasons.

8605010291 860426 PDR ADOCK 05000275 9 PDR

' page 2 fuel pools The additional spent fuel rods in the reracked spentin an accident involving th 5.

would fuel pools.

increase radioactive contamination 6.

Human error and its possible consequences in thefuel pools have no operation of the reracked spent considered tor and 7.

Inadequate and/or faulty proceedures been adequately combined with opera considered.

technician errors has not i dmin-8.

The adequacy of proceedures, technical specificat ons,t a istrative controls and their implementation and training has no been considered adequately. i deviation 9.

The possibility of faulty reasoning and inappropr ate d quate-from procedures during an emergency or accident has not bee ly considered. i rsonnel The consequences of poor communications i

of an emergency betweenors te pe 10.

and NRC personnel contributing to the sever fuel pools ty has not been given accident involving the reracked spent adequate consideration. fuel cooling has not been considered for the reracked fuel 11.

issues pools.

being in-Adequat 12.

The lack of resolution and action i on critical (01) and Office of Inspe vestigated by the Office of Investigat onissues i which have notare beendirectly re and Auditor (OIA),

Hazard Issue of the fuel pools reracking applicat on given any consideration. Nuclear 13.

The views of the population surrounding Diablo Canyonl radioa '

Power Plant concerning the Thisstorage of high with is inconsistant leveand repugnant have not been considered.to the Nuclear Waste Policy dioactive wasteAct of 198 14.

The uncertainties as to how long high level rafacility, neutron em-d environmencal would be stored at the proposed Diablo Canyon t fuel ponds br*ttlement and ot.her metallurgical deterioration an have stresses to the structural integrity of the dspen l not been adequately analyzed and determine . implimen-l The Applicant has not demonstrated gramthe which would effectively existance nor 15.

tation of a detailed quality assurance pro d vendors involved detect and prevent defective fuel poolwork by contractors an reracking.

with the proposed spent dards (Fed p7754)

16. The contentions submitted abovefueldopoomeet the Reg, Vol 51,icant Hazards Determination on the spent for a"Signif y k-racking at Diablo Car. yon Nuclear Power Plant. k / ]

Respectfully submitted,/I- p M4(dal 1]t 2 4 - -=~-

cca tiRC Docketing & S.trvice Laurie McDermott, Coordinator Lawrence Chandler er, Jr. C.O.D.E.S.

NU3( bP P.A. Crane, Jr.

Sierra Club Erfters For Peace