ML20206D750

Affidavit of Jd Shiffer Re Proposal to Increase Spent Fuel Storage Capacity,Approved by NRC on 860530.Intervenor Risk Allegations Refuted.W/Certificate of Svc

ML20206D750
Person / Time
Site:	Diablo Canyon
Issue date:	06/18/1986
From:	Shiffer J PACIFIC GAS & ELECTRIC CO.
To:
Shared Package
ML20206D737	List: ML20206D732 ML20206D750
References
OLA, NUDOCS 8606200184
Download: ML20206D750 (11)

Text

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1 UNITED STATES OF AMERICA BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of )

) Docket Nos. 50-275 0.L.A.

PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 0.L.A.

)

(Diablo Canyon-Nuclear Power )

Plant, Units No. 1 and 2) )

)

AFFIDAVIT OF JAMES D. SHIFFER James D. Shiffer, Vice President, Nuclear Power Generation, Pacific Gas and Electric Company ("PGan'dE"),

being first duly sworn, states as follows:

i PGandE owns and operates the Diablo Canyon Nuclear Power Plant Units 1 and 2 ("Diablo Canyon"), both units of which are now in commercial operation. As Vice President, Nuclear Power Generation, I am responsible for the operation and maintenance and related construction activities at Diablo Canyon. The purpose of my affidavit is to set forth the activities PGandE proposes (and is now undertaking),

which have been approved by the United States Nuclear Regulatory Commission ("NRC"), to expand the spent fuel storage capacity at Diablo Canyon; and to explain that such activities do not involve any significant hazards and indeed have been routinely accomplished at many other nuclear 0606200184 060618 PDR ADOCK 05000275 O PDR

plants in the United States without any undue risk to the public health or safety. I will also explain why any delay in PGandE's now ongoing activities, such as would be occasioned by a stay, will harm PGandE irreparably.

I have more than 25 years of experience in the nuclear power industry. I am particularly familiar with Diablo Canyon as a result of my involvement with the plant since its inception and am responsible for the activities described in this affidavit. Accordingly, I can testify cf my own personal knowledge to the following:

1. There are two' separate spent fuel storage pools at Diablo Canyon Units 1 and 2, one for each unit. The original, existing storage racks in each pool are capable of storing 270 fuel assemblies. PGandE proposes to replace the existing racks with new higher-density storage racks which can store up to 1324 fuel assemblies in each pool.

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2. Each unit of Diablo Canyon is expected to operate on an approximately 18 months refueling cycle. At each refueling, 76 fuel assemblies, approximately one-third of the total of 193 fuel assemblies, would be permanently removed from the core and placed in storage in the adjacent spent fuel pool. The capacity of the existing racks in each pool is sufficient to store the spent fuel discharged from

approximately five years of reactor operation. Diablo canyon Unit 1 started commercial operation in May 1985. Its initial refueling is scheduled for August 1986. Therefore, Unit 1 spent fuel pool with the existing rack arrangement is expected to be filled to capacity with spent fuel by 1990.

Unit 2 is approximately one year behind Unit 1. The new high density racks will provide sufficient capacity for spent fuel to the years 2010 and 2011 for Unit 1 and Unit 2, respectively. However, even though PGandE plans to complete the reracking now for the reasons explained below, the increased storage capacity, assuming the planned refueling schedule, will not be utilized until 1990.when the existing storage capacity would otherwise be exhausted.

3. The Nuclear Waste Policy Act of 1982 requires PGandE to pursue expansion of spent fuel storage capacity at Diablo canyon. Such storage capacity is needed since there is no federal spent fuel repository and none is expected to be in service prior to 1998, about 8 years after the Diablo Canyon pools are filled to capacity. PGandE has signed a l contract with U.S. Department of Energy to transfer possession of the spent fuel for storage at the federal repository when it becomes operational.

4. PGandE applied for an amendment to its operating licenses for Diablo Canyon to allow expansion of

the pools on October 30, 1985. The Intervenors San Luis Obispo Mothers For Peace and Sierra Club filed requests for hearings. The NRC's Atomic Safety and Licensing Board (ASLB) held a prehearing conference on May 13, 1986, in which Intervenors participated.

Intervenors were then advised that the NRC staff expected to issue the license amendments authorizing reracking shortly, within a couple of weeks. Hearings are expected to commence in the fall of 1986. The NRC staff made its finding of no significant hazards consideration and issued the license amendments authorizing raracking on May 30, 1986.

5. Because of the' desirability to complete the work on the spent fuel pool before the storage of spent fuel from the first refueling of Unit 1 in August 1986 to j minimize exposure to workers, PGandE commenced construction work, as authorized by the license amendments, promptly on May 31, 1986. The raracking work is now well along, and is scheduled to be completed on July 16, 1986. This work consists of removing the existing racks, cleaning the pool, and placing the new racks. All of the new racks for Unit 1 have been received at Diablo Canyon. The new racks for Unit 2 will be shipped to Unit 2 between July and September 1986. This will allow ample time for raracking of Unit 2 i

prior to that unit's scheduled refueling outage in 1987.

6. The NRC has found that Diablo Canyon has been designed to withstand the maximum earthquake that is possible in the vicinity of the plant. The spent fuel pools and the existing racks have been designed to meet those same stringent seismic design criteria. The new high density racks have also been analyzed and are qualified to meet the same seismic criteria. Thus, the new racks and the pool structures are qualified to withstand the stresses from the maximum earthquake which is possible.

7. The particular technology to be employed at Diablo Canyon to enlarge the storage capacity of the spent fuel pools, raracking with high density fuel racks, has been performed at dozens of other plants. To date, the NRC has approved over 100 applications for raracking. Some plants

have performed reracking two or three times. PGandE's proposed raracking concept is similar to that used at these other plants. Additionally, the new high density racks at Diablo Canyon are designed similarly to those which have been used for years at several other plants. No significant safety or other problems have been identified with raracking procedures or with the operation of the high density fuel racks when installed and in use. The NRC staff has reviewed and approved the designs at these other plants. This industry and NRC experience with raracking with high density racks demonstrates the proven nature of that technology and

the lack of risk to the public health and safety presented by the installation and operation of the high density racks.

8. The NRC staff has determined that the proposed raracking at Diablo Canyon does not involve significant hazards considerations. (Safety Evaluation at 31) In particular, the NRC found that the raracking does not involve a significant increase in the probability or consequences of an accident previously evaluated; does not create the possibility of a new or different kind of accident from any accident previously evaluated; and does not involve a significant reduction in any margin of safety.

In addition, the staff concl'uded that there are no signifi-cant radiological or nonradiological environmental impacts associated with the raracking action and that there is no significant effect on the quality of the human environment.

9. It is particularly important that PGandE perform the reracking now because spent fuel has not yet been stored in the pools. Thus, the pools remain free of any radioactivity. The first refueling outage of Unit 1 is scheduled to begin in September 1986. At that time, spent fuel, which is radioactive, will be removed from the reactor and placed into the pool. This will contaminate the pools and the racks with radioactivity. Accomplishing the raracking prior to storage of any spent fuel will allow

workers to conduct the construction activities without exposure to radiation from the spent fuel or from  !

contaminated surfaces. Therefore, raracking at this time l will minimize personnel radiation exposure, as required by NRC regulations. 10 CFR Part 20. If raracking is delayed so that work must be performed while spent fuel is stored in the pool, workers will be required to use special contamination protection equipment during reracking to minimize their exposure to radiation. Radiation protection

equipment can only provide partial protection from exposure, however, and will also physically burden workers. Thus, overall time to complete the work will increase and workers will be unnecessarily expose'd to radiation. Further, since spent fuel must be stored under water to provide continuous shielding and cooling, all raracking work must also be performed under water, creating yet another difficulty.

Thus, " wet" raracking will increase both personnel exposure and raracking costs unnecessarily.

10. If the offloading of spent fuel from the Unit i reactor is delayed to allow completion of raracking work, the refueling outage will be correspondingly delayed.

Once a nuclear unit is ready to be refueled, it cannot continue to operate at full capacity. It therefore must curtail operation and shortly shutdown. This makes the unit unavailable for power generation for an additional time, and

2 PGandE must therefore purchase or generate more expensive replacement energy to supply the power that would have been generated by Unit 1. Each day of such a delay would result in increased fuel costs to PGandE's ratepayers of approximately $1 million. Because of this large cost, PGandE has no choice but to commence the refueling outage when scheduled, resulting in performing the raracking " wet" if PGandE cannot complete the raracking on the current schedule.

11. Reracking work is progressing now on a schedule to allow completion by mid-July. Any delay in raracking work now will cause a day for day delay in the i completion schedule. Because of the tight schedule for i completion of the raracking prior to the September refueling outage, any delay other than a few days will force PGandE to complete the raracking " wet," that is, with the radioactive spent fuel stored under water in the pool.

12. If PGandE is required to stop the raracking work prior to completion, the pool will be unable to accommodate spent fuel. Therefore, in such event PGandE would be required to, in effect, reverse its work by i

reinstalling the original racks to restore the pool to operational status. This will, of course, involve additional time and expense which would be wasted.

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13. I have reviewed the motion for a stay and supporting affidavit of Richard B. Ferguson submitted by Intervenors to the NRC on June 17, 1986, particularly the allegations concerning the risks from an earthquake associatedwiththehighbensityfuelracks. While I disagree with the assertions in the affidavit, should Intervenors prevail on any of their contentions, appropriate modifications could be made to the storage racks, long before any increased amount of spent fuel was stored in the pools.

I swear that the foregoing is true and correct to the best of my knowledge.

Dated fd di h[b i

%b JAMES D. SHIFF g k

Subscribed and sworn to before me this 18th day of June, 1986 .______________ _____

OFFICIAL SEAL l WINDY SPAQUL NOTARY NsOC

• CAUFORNIA NM 4

b l hr NEsYo ases Notary Public in and for the City and County of San Luis Obispo, State of California My commission expires on June 30, 1986.

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' UNITED STATES OF AMERICA gy NUCLEAR REGULATORY COMMISSION JUN 191986* g_

BEFORE THE ATOMIC SAFETY AND LICENSING B SUIV s2;craq NI //3 In the Matter of ) co

, )

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 OLA >

) 50-323 OLA (Diablo Canyon Nuclear Power Plant )

Units 1 and 2) )

j )

CERTIFICATE OF SERVICE l I' hereby certify that copies of the foregoing document in the above-captioned proceeding have been served on the following by deposit i

in the United States mail, first class, or as indicated by an asterisk through delivery by courier:

O

! B. Paul Cot ter, Jr. , Chairman Docketing and Service Branch l Administrative Judge Office of the Secretary i Atomic Safety and Licensing US Nuclear Regulatory Commission Board Panel Washington DC 20555

+

US Nuclear Regulatory Commission 4350 East Wert Highway 4th Floor' i Bethesda MD 20814 ,

0

, Glenn O. Bright Lawrence Chandler, Esq.

• Administrative Judge Henry J. McGurren, Esq.

Atomic Safety and Licensing Office of Executive Legal Director Board Panel US Nuclear Regulatory Commission

! US Nuclear Regulatory Commission Maryland National Bank Building 4350 East West Highway 4th Floor Room 9604 i

Bethesda MD 20814 7735 Old Georgetown Road Bethesda MD 20814 i 0 Dr. Jerry Harbour Lewis Shollenberger

Administrative Judge Regional Counsel

! Atomic Safety and Licensing US Nuclear Regulatory Commission 3

Board Panel Region V US Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 4350 East West Highway 4th Floor Walnut Creek CA 94596 Bethesda MD 20814 l Atomic Safety and Licensing Bruce Norton, Esq.

) Board Panel Norton, Berry, French and US Nuclear Regulatory Commission Perkins, P.C.

1 Washington DC 20555 2002 East Osborn Road

] Phoenix AZ 85016 j

j i

. Dichlo Canycn S:rvico Liot Page 2

• Atomic Safety and Licensing  :

Appeal Board Panel  !

US Nuclear Regulatory Commission l Washington DC 20555

• Commissioner Nunzio J. Palladino Commissioner James Asselstine

• Chairman US Nuclear Regulatory Commission US Nuclear Regulatory Commission 1717 H Street NW 1717 H Street NW Washington DC 20555 Washington DC 20555

• Commissioner Frederick Bernthal Commissioner Thomas Roberts

• I US Nuclear Regulatory Commission US Nuclear Regulatory Commission  !

'1717 H Street NW 1717 H Street NW Washington DC 20555 Washington DC 20555

• Commissioner Lando W. Eech, Jr. Dian M. Grueneich a

' US Nuclear Regulatory Commission Grueneich & Lowry 1717 H Street NW 345 Franklin Street Washington DC 20555 San Francisco CA 94102 Mr. Lee M. Gustafson Mrs. Jacquelyn Wheeler Pacific Gas and Electric Company 2455 Leona Street 1726 M Street NW Suite 1100 San Luis Obispo CA 93401 Washington DC 20036-4502 Janice E. Kerr, Esq. Laurie McDermott, co-ordinator Public Utilities Commission C.O.D.E.S.

5246 State Building 731 Pacific Street Suite #42 350 McAllister Street San Luis Obispo CA 93401 San Francisco CA 94102 Ms. Nancy Culver Managing Editor 192 Lun'ata Street San Luis Obispo County San Luis Obispo CA 93401 Telegram-Tribune 1321 Johnson Avenue San Luis Obispo CA 93406 Dr. Richard Ferguson Richard E. Blankenburg l Vice-Chairman Co-publisher Sierra Club Wayne A. Soroyan, News Reporter  :

South County Publishing Company Rocky Canyon Star Route Creston CA 93432 P. O. Box 460 l r oyo Grande A 420 I 1

k- 71111 Pacif

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A! Crane,[Jr.

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Gas and ltlectric Company

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77 Be le Street,(31st Floor San Francisco CA 94106 Dated at San Francisco, California, this is day of June,1986.