ML20210K679

Contentions on Util Request to Increase Waste Storage by Reracking Spent Fuel Pools.Alternatives to Proposed Reracking Listed,Including Contracting Out or Transshipment of Spent Fuel for Storage at govt-owned Spent Fuel Facility

ML20210K679
Person / Time
Site:	Diablo Canyon
Issue date:	04/22/1986
From:	Silver S FRIENDS PEACE EXCHANGE (FORMERLY MOTHERS FOR PEACE), SAN LUIS OBISPO MOTHERS FOR PEACE
To:	Atomic Safety and Licensing Board Panel
References
CON-#286-934 86-523-03-LA, 86-523-3-LA, OLA, NUDOCS 8604290004
Download: ML20210K679 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos. 50-275-OLA

) and 50-323-OLA

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

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(Diablo Canyon Nuclear ) April 22, 1986 Power Plant, Units 1 and 2

_________________________________)

MOTHERS FOR PEACE CONTENTIONS ON PACIFIC GAS &

ELECTRIC COMPANY'S REQUEST TO INCREASE WASTE STORAGE BY RERACKING THE SPENT FUEL POOLS 1.

The Applicant has not adequately considered alternatives to the proposed reracking of the spent fuel pools. In particular, close proximity because of theofHosgri the increased danger. posed by the considered. Some alternativesfault, alternatives should be include:

a.

The contracting out or trans-shipment of spent fuel for storage at a government owned spent fuel facility; b.

Derating the facility or reducing the plant output and thereby reducing the generation of spent fuel.

c. Closing or shutting down the faciities.

2.

The Applicant f ailed to evaluate the overall cost terms of both Sealth effects and potential associated (in medical costs) associated with the additional exposures of the plant personnel to increased radioactivity levels due to the increased spent fuel storage.

3. No analysis has been made of the overall costs (in terms of both health effects and potential associated medical costs associated with the additional exposures of persons duethe off Diablo to the Canyon increased site to increased radioactivity levels spent fuel storage.

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haveThe a expansion of the spent fue l environment and therefore requires Environmental Impact Statement e human thsignificant a 5

. e preparation of an Applicant's proposal does not pool conditions will be maintain edensure that spent fuel design limits in the event of within regulatory or extreme accident shown that in the main reactor.a Class 9 accident or other systems to and plant personnel will stems, fuin such coolingcases the elec

6. ensure continued safe operation ofethnction spent sufficiently well The application for rerackin fuel pools.

will have noneed for the immediate expansion has bg is premature next 4 years.need for the increased een shown storage capa. Applicant 7 city for the The NRC has ordered PG&E to c program and Commission submit by 1988 the results of thonduct a long-term seismic e study to the done inadequate. on the spent fuel pools that asstill the studyin the is early plann well as on the racks, any seismic analyses 8

premature, and' woefully inadequateIt .

also makes reracking are consideratio (

the long term health, safetyThe Applicant has not adequ the proposed re-racking with and environmental effects ofely cons respect over which the the expiration of Applicant'sspent fuel pool is likely to be uto such periods of time

9. operating license. sed beyond evacuated in the event of a simultThe at people could safely Applicant be has n A accident at Diablo Canyon's spent aneous fuearthquake l and '

evacuation times are inadequate to e pools. Current safety given the increased quantit occur with a spent fuel pool stora ypreserve the health and of radiation that would

10. ge expansion.

consequencesThe Applicant has not e analyz d of an accidental misfired, misguided Vandenberg missile range or exploded impact minor considered the from an aborted, facility for the U.S. Air ForcVandenbergssile is a majorlaunched launch from the prime launching facility for NASA {

have been occurring with increas e de, and soon will become a Accidenta i frequency.l explosions

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11. .In light of increased terrorist activities, the Applicant has not adequately analyzed nor considered the consequences of sabotage of the spent fuel facilities. The possibility of increased harm due to sabotage of the spent fuel pools will necessitate increased security measures over and above current forces.

Respectfully submitted, 4272 f4l

• Sandra A. Silver Mothers for Peace cc: NRC Docketing and Service Lawrence Chandler Philip A. Crane, Jr.

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