ML20210K679

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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  Pacific Gas & Electric icon.png
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

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NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

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Docket Nos. 50-275-OLA

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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

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April 22, 1986 Power Plant, Units 1 and 2

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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, because of the increased danger. posed by the close proximity of the Hosgri fault, alternatives should be considered.

Some alternatives include:

The contracting out or trans-shipment of spent fuel a.

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.

Closing or shutting down the faciities.

c.

2.

The Applicant f ailed to evaluate the overall cost (in terms of both Sealth effects and potential associated 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 off the Diablo Canyon site to increased radioactivity levels due to the increased spent fuel storage.

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The expansion of the spent fu l have a environment and therefore requires thsignificant a e

Environmental Impact Statement e human e preparation of an 5

Applicant's proposal does not pool conditions will be maintain densure that spent design limits in the event of fuel within regulatory or e

extreme accident shown that in the main reactor.a Class 9 accident or other systems and plant personnel will fuin such cases the elec to ensure continued safe operation of thnction sufficiently well stems, cooling 6.

The application for rerackin fuel pools.

e spent will have noneed for the immediate expansion has bg is premature next 4 years.need for the increased storage capa.

een shown Applicant city for the 7

The NRC has ordered PG&E to c program and submit the results of thonduct a long-term seismic Commission by 1988 e study to the done on the spent fuel pools asstill in the early plann that the study is inadequate.

well as on the racks, any seismic analyse premature, and' woefully inadequateIt also makes consideratio

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are reracking 8

the long term health, safetyThe Applicant has not adequ and environmental effects ofely cons the proposed re-racking with over which the spent fuel pool is li respect kely to be uto such periods of time the expiration of Applicant's operating license. sed beyond 9.

evacuated in the event of a simultThe Applicant has n at people could safely be A

accident at Diablo Canyon's spent fu l aneous earthquake and evacuation times are inadequate to e

safety given the increased quantit pools.

Current preserve the health and occur with a spent fuel pool storay of radiation that would ge expansion.

10.

consequencesThe Applicant has not analyz d of an accidental e

misfired, misguided or exploded minor considered the impact from an aborted, Vandenberg missile range facility for the U.S. Air ForcVandenbergssile launched from the prime launching facility for NASA is a major launch

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have been occurring with increas de, and soon will become a Accidenta i

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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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