ML20212C312
| ML20212C312 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/22/1986 |
| From: | Lowry E FRIENDS PEACE EXCHANGE (FORMERLY MOTHERS FOR PEACE), GRUENEICH, D.M. (FORMERLY GRUENEICH & LOWRY), SAN LUIS OBISPO MOTHERS FOR PEACE, Sierra Club |
| To: | |
| References | |
| CON-#486-1975 86-523-03-LA, 86-523-3-LA, OLA, NUDOCS 8612300011 | |
| Download: ML20212C312 (7) | |
Text
_ _ _ _ _ _ _ _ _ _ _
]W UNITED STATES OF AMERICA ggtgETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC ~ SAFETY AND LICENSING BOARD
'86 DEC 23 Pl252
)
In the Matter of:
)
Docket Nos. 50-275-OLA 1
)
and 50-32MOLAk N
>O.
).
i.e. ;L
- PACIFIC GAS AND ELECTRIC COMPANY
)
)
ASLBP No.86-523-03-LA
)
(Diablo Canyon Nuclear Power Plant,
)
Units 1 and 2)
)
)
INFORMATION CONCERNING THE DIRECT CASE TO BE PRESENTED BY THE l
SIERRA CLUB AND MOTHERS FOR PEACE I
l Pursuant to the order issued December 1,
- 1986, by the Honorable B. Paul Cotter, Jr. for the Atomic Safety and Licens!ng Board in the above captioned proceeding, the Sierra Club and Mothers for Peace files this stateme concerning their direct case to be presented at hearings.
According to the December 1 order, all parties were in-l structed to file and exchange information concerning their direct r
case as follows:
- 1) Witnesses who will testify on their behalf;
- 2) Lists of exhibits they intend to introduce;
- 3) Documents upon which the witnesses will rely;
- 4) List of documents the parties intend to use on cross-examination (unless disclosure would compromise the cross-examination); and
- 5) A brief description for all witnesses listed (no longer than two pages per witness) of the views and position on the 1
8612300011 861222 PDR ADOCK 05000275 0
eon g3
issues about which they will testify.
RESPONSE TO THE DECEMBER 1 ORDER:
-1) Testimony on behalf of the Sierra Club and Mothers for Peace will be presented by Dr. Richard B.
Ferguson.
- 2) The Sierra Club and Mothers for Peace intend to introduce as exhibits various drawings and sketches as may be useful for the understanding of questions asked by the Club on cross-examination. These materials would depict the fuel racks or parts thereof, the spent fuel pools, the arrangement and relationship between racks and so forth. The documents listed below under the response in paragraph 4 may also be introduced as exhibits.
- 3) Documents on which Dr. Ferguson will rely are as follows:
a) Safety Evaluation By the Office of Nuclear Reactor Regulation Relating to the Reracking of the Spent Fuel Pools At the Diablo Canyon Nuclear Power Plant, Units 1 and 2...,
- USNRC, May, 1986.
b) Reracking of Spent Fuel Pools Diablo Canyon Units 1 and 2, Pacific Gas and Electric Company, September, 1985.
c) USNRC Standard Review Plan, NUREG-0800 (1981).
)
d)
R.J.
- Fritz, "The Effects of Liquids on the Dynamic Motions of Immersed Solids", Journal of Engineering for Industry, Trans. of the ASME, February, 1972, pp 167-172.
e) A.I.
Soler and K.P. Singh, " Dynamic Coupling in a Closely Spaced Two-Body System Vibrating in Liquid Medium: The Case of Fuel Racks", 3rd International Conference on Nuclear Power and Safety, Keswick, England, May, 1982.
2 l
e f)-A.I.
Soler and K.P.
Singh, " Seismic Response of a Free Standing Fuel Rack Construction to 3-D Floor Motion", Nuclear Engineering and Design 80'(1984) 315-329 g)
Joseph Oat Corp.,
" Responses to Group I
Comments / Questions" (also Group II and Group III), undated.
h) Meeting Summary, Meeting of December 5,
1985,
Subject:
Diablo Canyon Power Plant - Spent Fuel Pool Reracking, USNRC and PGGE.
- 1) Meeting Notes, Meeting of February 20, 1986,
Subject:
Diablo Canyon Power Plant - Spent Fuel Pool Reracking, USNRC and PGGE.
j)
K.P.
Singh and T.
Lee-Ng,. " Planning Study for Experi-mental Measurements and Analytical Correlations of Fluid Drag of Fuel Assemblies in Fuel Rack Storage Locations", EPRI Project No.
RP2124, Oat Project No. J-7030, November, 1982.
k) A.I.
Soler, " Seismic Analysis of High Density Fuel Racks for Pacific Gas and Electrac for Diablo Canyon Nuclear Power Station", TM Report #779, Oat Job J-2473, four - versions, dated January 1986 through September 1986.
- 1) Computer Printouts, " Program DYNAHIS", authors unknown, various dates.
m) Computer Programs, COLL 4050 and D3 Slide, by R.
B.
Ferguson, 1986.
n)
" Study on Significant Hazards,"
Report by Nuclear Regulatory Commission, August 15, 1983.
o) " Friction Coefficient Value for High-Density Fuel Storage 3
r Systems," Ernest Rabinowitz, Nov. 23, 1977, to General Electric Nuclear Energy Programs Division, (GE Report No.
G.E.P.O.
529-CCO84X).
- 4) Documents which the Sierra Club and Mothers for Peace
-intend to use on' cross-examination include:
a) the documents listed above in paragraph 3; b) other documents. supplied to the Sierra Club and Mothers for Peace under discovery including various meeting summaries, telephone message summaries, etc.;
c) Affidavits of William H. White, Stanley E.
Turner, Mohsin Kahn and Shankar Bhattacharya, Respondent-Intervenor's Brief, San Luis Obispo Mothers for Peace and the Sierra Club vs. USNRC, Ninth Circuit Court of Appeals, July, 1986 d) Affidavit of R.
Clyde Herrick, NRC Staff Response to Request for a Stay by Sierra Club and Mothers for Peace, USNRC, June, 1986.
- 5) Dr. Ferguson will testify that:
a) The analysis of the response of the proposed high density spent fuel racks to seismic activity as reported in documents made available to intervenors and relied upon by PG&E and the NRC is incorrect.
b) Several of the assumptions used by those responsible for rack analysis are unreasonable and lead to incorrect conclusions regarding the safety of the proposed high-density racks.
c) Several factors important to the understanding of rack behavior and integrity have been ignored in the analysis by PGGE 4
g and the NRC.
'd)
Rack behavior as described in available documents I
violates NRC structural acceptance criteria for spent fuel
~
storage systems.
e) The so-called " worst case" collision scenario used in the rack analysis performed by the NRC underestimates forces on the racks which may reasonably be expected to occur.
f) Significant damage to the fuel racks would be expected to occur during an earthquake like the postulated Hosgri event.
g) Alternatives to the proposed reracking exist which have received inadequate study but which may be significantly safer than the proposed reracking.
Dr. Ferguson's testimony will be supported by an analysis of various technical issues.
This analysis will include:
a) The likelihood of collisions involving more than two L
racks and the probable consequences of such collisions.
b) The likelihood of collisions involving two or more racks with the walls of the pools and the probable consequences thereof.
c) The fluid coupling models used in rack analysis and the effects of fluid forces on the racks.
d) The effect of rack spacing on fluid coupling models.
e) The effect of rack irregularities on model predictions.
5 1
f) The effect of rack tilting on the rack support surfaces.
g)
The structural acceptance criteria governing rack analysis.
Dated:
December 22, 1986 Respectfully submitted, GRUENEICH & LOWRY m
so T,.D L'W1i l
Edwin F.
Lowry
( j Attorneys for Mothers for Peace and the Sierra' Club I
i I
i 6
i i
s._--,.
m
____.,_____.,.,______,_,,.,_,_,._,.,._......-___,,.,.__.._.7...
._.__,,y,,, -,
r a e - e PROOF OF SERVICE Cou[a:
s 5W 1,
Deborah M.
- Hunt, declare that on December 22,
- 1986, I
deposited copies of the attached Information conc g i e Direct Case to be Presented by the Sierra Club and MothWs PEEc52in the United States mail with postage thereon fully prepaid and addressed to the parties listed below:
gnu,
DOCKE Tr%
Gustalko(nyg pg Dr. Jerry Harbour Mr. Leland M.
Administrative Judge Federal Relations Manager Atomic Safety & Licensing Board Pacific Gas & Electric Co.
U.S.
Nuclear Regulatory Comm.
1726 "M"
Street, NW, Suite 1100 Washington, D.C.
20555 Washington, D.C.
20036-4502 Glenn O.
Bright Philip A.
- Crane, Jr.,
Esq.
Administrative Judge Pacific Gas & Electric Co.
Atomic Safety & Licensing Board P.O.
Box 7442 U.S.
Nuclear Regulatory Comm.
San Francisco, CA 94120 Washington, D.C.
20555 Mr. Gordon A.
Silver Henry J.
McGurren, Esq.
Ms. Sandra A.
Silver Lawrence J.
Chandler, Esq.
1760 Alisal Street Office of the Exec. Legal Dir.
San Luis Obispo, CA 93401 U.S.
Nuclear Regulatory Comm.
Washington, D.C.
20555 Ms. Laurie McDermott, Coordinator Atomic Safety & Licensing C.O.D.E.S.
Board Panel 731 Pacific Street, Suite 42 U.S.
Nuclear Regulatory Comm.
San Luis Obispo, CA 93401 Washington, D.C.
20555 Mrs. Jacquelyn Wheeler B.
Paul Cotter, Jr.,
Chairman 2455 Leona Street Administrative Judge San Luis Obispo, CA 93400 Atomic Safety & Licensing Board U.S.
Nuclear Regulatory Comm.
Dr.
R.B.
Ferguson Washington, D.C.
20555 Sierra Club / Santa Lucia Chapter Rocky Canyon Star Route Atomic Safety & Licensing Creston, CA 93432 Appeal Panel U.S.
Nuclear Regulatory Comm.
Ms. Nancy Culver Washington, D.C.
20555 192 Luneta Street San Luis Obispo, CA 93401 Bruce Norton, Esq.
NORTON, BURKE, BERRY & FRENCH P.O.
Box 10569 Phoenix, AZ 85064 I am, and was at the time of the service of the attached paper, over the age of 18 and not a party to the proceeding.
1 I declare under penalty of perjury that the foregoing is true and correct.
f
- /(
W,
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Lfd/
Deborah M.
Hunt