ML20211E212

Second Set of Interrogatories Re Contentions 1 & 2 Concerning Proposed Reracking of Spent Fuel Pools. Certificate of Svc Encl.Related Correspondence

ML20211E212
Person / Time
Site:	Diablo Canyon
Issue date:	10/20/1986
From:	Mcgurren H NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Sierra Club
Shared Package
ML20211E160	List: ML20211E152 ML20211E172 ML20211E187 ML20211E212
References
OLA, NUDOCS 8610220380
Download: ML20211E212 (7)

Text

wELATED CORRESPONDF.,Njlq 00LKETED UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOAR OFFiE 7 :h : # f In the Matter of ) 00CnET g g ! " CL

)

PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA (Diablo Canyon Nuclear Power Plant ) (Spent Fuel Pool)

Units I and 2) )

NRC STAFF SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM THE SIERRA CLUB, SANTA LUCIA CHAPTER The NRC staff hereby requests that the Sierra Club, Santa Lucia Chapter (Sierra Club) pursuant to 10 C.F.R. Il 2.740b and 2.741, an-swer separately and fully, in writing under oath or affirmation, the fol-lowing interrogatories and produce or make available for inspection and copying, all documentary material identified in responses to interrogato-ries below. Each response to the interrogatories below shall be under oath or affirmation of the individual (s) who contributed thereto. For all references requested in these interrogatories, identify them by author, l title, date of publication and publisher if the reference is published, and

! if it is not published, identify the document by the author, title, the date is was written, the qualifications of the author relevant to this pro-ceeding, and where a copy of the document may be obtained.

Sforra Club Contention

I(A) It is the contention of the Sierra Club, Santa Lucia Chapter (Sierra Club), that the report submitted to the i Nuclear Regulatory Commission (NRC) entitled Reracking l Spent Fuels Pools Diablo Canyon, Units 1 and- 2 and oth-er communications between Pacific Ges and Electric

[ 8610220300 061020 PDR ADOCK 05000275 0 PDR

Company (PGaE) and the NRC which are available to the public on the same subject (the Reports) fail to contain certain relevant date necessary for independent verifica-tion of the claims made in the Reports regarding consis-

-tency of the proposed .reracking with the protection of the public health and safety, and the environment.

In particular, the reports fall to contain date regarding:

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 modeling of rack behavior during the PHE; I(B) It is the contention of the Sierra Club that the Reports fall to include consideration of certain relevant condi-tions, phenomena and alternatives necessary for indepen-dent verification of claims made in the Reports regarding consistency of the proposed reracking with public health and safety, and the environment, and with federal law.

J In particular, the Reports fail to consider:

4

2) the resonant behavior of the spent fuel assemblics in the racks in response to the PHE and the conse-quences of such behavior;

7) alt'ernative on-site storage facilities including:

i (i) construction of new or additional storage facill-ties and/or; (ii) acquisition of modular or mobile spent nuclear 1

fuel storage equipment, including spent nucle-ar fuel storage casks;

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

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

II. It is the contention of the Sierra Club t:iat the proposed I

reracking is inconsistent with the protection of the pub-i lic health and safety, and the environment, for reasons which include the following:

1

- _ _ _ . _ _ _ _ _ _ _ _ . . . _ _ _ _ _ . _ . . _ , , , - - _ _ _ _ . , - . _ _ _ _ _ _ . ~ . _ _ . _ _ _ _ _ _ _ _ _ _ _

9 (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 esticated 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 and pool walls;

~(4) reduction of the spacings between fuel assemblies; (5) increase in the nuclear criticality coefficient k(eff) above 0.95; (6) release of large quantities of heat and radiation; (7) radioactive contamination of the nuclear power plant and its employees above the levels per-mitted by federal regulations; 3 (8) radioactive contamination of the environment in the vicinity of the nuclear power plant above the levels permitted by federal regulations; and (0) radioactive contamination of humans and other

living things in the vicinity of the nuclear power plant above the levels permitted by fed-eral regulations.

i (B) during the PHF, collisions between groups of racks with each other and/or with the pool walls are ex-pected to occur with results similar to those de-scribed in II(A) above.

Interrogatories 2-la. Identify what person or persons you now rely upon to substantiate in whole or in part your position on Contentions I and II.

, b. Provide the addresses and education and professional l

qualifications of any persons named in your response to

a. above,

c. Identify which of the above persons or any other person i you may call as witnesses on these contentions.

i

_ = . . ,

2-2. Provide summaries of the views , positions or proposed testimony on Contentions I and II of all persons named in response to Interrogatory 2-1, that you intend to present as witnesses during this proceeding.

2-3. State the specific bases and references to any documents upon which the persons named in response to Interroga-tory No. 2-1 rely to substantiate their views regarding Contentions I and II.

2-4. With regard to Contentions I and II, identify all docu-mentary or other material that you intend to use during 4

this proceeding to support these contentions and that you may offer as exhibits on these contentions or refer to during your cross-examination of witnesses presented by the Licensee and/or the NRC staff.

2-5. With regard to Contention II(A)(6), identify the specific source and cause of the "large quantities of heat and radiation".

2-6. Provide a detailed description including the assumptions you used for the analyses based on the THM model re-ferred to in your report entitled " Technical Details of the Proposed High Density Heracking at Diablo Canyon the Seismic Problem", dated October 3,1986 (hereinafter the " Report").

2-7. Provide the values of all the parameters used in the COLL 4050 computer program for each run of the TMH model. Indicate any logic change to the computer pro-gram for each run.

2-8. With regard to impact forces between rack and wall as reported on pege 13 and depicted in Figures 1, 2 and 3 of your Report, what are the impact forces between the fuel assembly and cell wall as a . function of time.

2-9. Describe the phenomenon of " double impact" depicted in Figures 2 and 3 of your Report noting in particular the relationship of the forces and positions of the rack to wall and the fuel ossembly to rack over the entire time period depicted in figures 2 and 3 (0 through 150 milliseconds) .

2-10. Describe your analysis and the basis thereof which pre-diets maximum speed for a free rack to be of the order of 24 in/sec.

2-11. Por the analyses identified in Interrogatory 2-6 for

, which you used the PHE as input motion, what portion of i

1

the PHE time history record and in which direction of the carthquake motion were used?

2-12. With respect to the statements made in the third para-graph of page 12 of the Report:

a. Describe how the convergence of the THM model was checked. Was the check performed for the 2

non-linear seismic response?

b. Provide the justifications for bench marking the THM analysis against an analytical solution assuming a rigid rack, zero friction, and constant accelera-tion, when the true behavior of the racks involves clastically and non-elastically connected rack compo-nents, non-linear frictional elements and non-constant randomly varying accelerations.

2-13. Although the Introduction, which precedes the Report, indicates that Dr. Ferguson is solely responsible for the contents of the Report, it is clear that the analysis in-volved the efforts of other persons. The Report states for example , "our work" (page 13); "[w]e see" (page 14); "our impression" (page 17; "[w]e have nr-gued" (page 20). Identify the person or persons you relied upon or who contributed in any way to the Report itself or the analyses described in the Report, indicating for each person identifled his or her professional qualifi-cations and position regarding Contentions I and II, and whether or not you may call such person as a witness in this proceeding.

Respectfully subnitted, i

nry J. h rren AW M Counsel for MC Staff Dated at Bethesda, Maryland this 20th day of October,1986

o conatsvonutncu COLKETED usNHC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 860CT 21 P3 :16 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFILL b W t"'

00CXETING A SiPV!l.!-

4 In the Matter of ) BRANc"

)

PACIFIC CAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA

) (Spent Fuel Pool)

, (Diablo Canyon Nuclear Power Plant .)

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF SECOND SET OF INTERROGATO-1 RIES AND REQUEST FOR DOCUMENTS FROM CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY REGARDING CONTENTION 14", "NRC STAFF SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM SAN LUIS OBISPO MOTHERS FOR PEACE", and "NRC STAFF SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM THE SIERRA CLUB, SANTA LUCIA CIIAPTER" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulato-4 ry Commission's internal mail system, this 20th day of October,1986:

B. Paul Cotter, Jr. , Chairman Druce Norton, Esq.

! Administrative Judge e/o P. A. Crane, Jr. , Esq.

Atomic Safety and Licensing Board Panel Pacific Gas and Electric Co.

U.S. Nuclear Regulatory Commission P.O. Box 7442 4

Washington, D.C. 20555* San Francisco, CA 94120 Glenn O. Bright, Esq. Nancy Culver Administrative Judge 192 Luneta Street Atomic Safety and Licensing Board Panel San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission Washington, D.C. 20555' i Mrs. Jacquelin Wheeler Dr. Jerry liarbour 2455 Leona Street Administrative Judge San Luis Obispo, CA 93401 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555' i

i.

i

Richard E. Blankenburg Philip A. Crane, Jr. , Esq.

Co-publisher (77 Beale Street, 31st Floor)

Wayne A. Soroyan, News Reporter P.O. BOX 7442 South County Publishing Company San Francisco, CA 94120 (94106)

P.O. Box 460 Arroyo Grande, CA 93420 Docketing and Service Section Mr. Lee M. Gustafson Office of the Secretary Pacific Gas and Electric Co.

U.S. Nuclear Regulatory Commission Suite 1100 Washington, D.C. 20555* 1726 M Street, N.W.

Washington, D.C. 20036-4502 Atomic Safety and Licensing Dr. Richard Ferguson Board Panel Vice-Chairman U.S. Nuclear Regulatory Commission Sierra Club Washington, D.C. 20555* Rocky Canyon Star Route Creston, CA 93432 Atomic Safety and Licensing Appeal Board Panel Laurie McDermott, Co-ordinator U.S. Nuclear Regulatory Commission C.O.D.E.S Washington, D.C. 20555* 731 Pacific Street Suite #42 Managing Editor San Luis Obispo, CA 93401 San Luis Obispo County J

Telegram-Tribune Dian M. Grueneich, Esq.

1321 Johnson Avenue Edwin F. Lowry P.O. Box 112 Grueneich & Lowry San Luis Obispo, CA 93406 345 Franklin Street San Francisco, CA 94102 f! \

Joseph ]Lutbert Depy Assistant Gener il Counsel II

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