ML20214T069

Proposed Findings of Fact & Conclusions of Law.* Replacement of Current Spent Fuel Storage Racks W/New,High Density Storage Racks Discussed.Proof of Svc Encl

ML20214T069
Person / Time
Site:	Diablo Canyon
Issue date:	06/03/1987
From:	Lowry E GRUENEICH, D.M. (FORMERLY GRUENEICH & LOWRY), Sierra Club
To:
References
CON-#287-3680 OLA, NUDOCS 8706100109
Download: ML20214T069 (10)

Text

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i 'Edwin F. Lowr,, 00CKETED Dian M. Grueniich

• GRUENEICH & LOWRY 380 Hayes Street, Suite 4 San Francisco, California 94102

~87 JJN -8 P3 :20

'(415) 861-6930 i;re ~

Attorneys for'The Sierra Club #

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

' ' ) ^

In he'MatEia[of:' ) Docket Nos.

. ) 50-275 and 50-323 OLA PACIFIC GAS & ELECTRIC COMPANY )

)

(Diablo Canyon Nuclear Power )

Plant,-Units 1 and 2) )

)

PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW

1. Pacific Gas and Electric Company seeks to increase the spent fuel storage capacity at Diablo Canyon Units 1 and 2 by replacement of the current spent fuel storage racks with new, high density storage racks. The capacity of each pool will increase from 270 to 1324 spent fuel assembly spaces.

2. Diablo Canyon Units 1 and 2 are generating waste fuel at a rate which will exhaust current storage capacity long before the expected life of the reactors. The original license contemplated that spent fuel would be moved from the spent fuel storage pools to an intermediate or long term storage facility.

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, 3. There is no interim or long term designated storage

f. facility for spent nuclear fuel from civilian nuclear reactors;

! L / f! i' (d u nor can any ro'asonably be' expected to be built during the life of

$ l7 the reactor.

[ , 4. .The Diablo Canyon Nuclear Power Plant is built in close y

proximity to the Hosgri _ Fault. It must be designed to meet the highest seismic safety standards of any existing nuclear power 1- p1' ant.

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5. The applicant must demonstrate ' that any alternative selected. for, storage . of spent- fuel poses no risk of a nuclear accident to the surrounding population.

6. A seismic event of the magnitude of the " safe shutdown earthquake" at Diablo Canyon could result in demage to the spent fuel racks.

7. Damage to the racks could result in an increase of the criticality constant above accepted levels with a concomitant generation of excessive amounts of heat and radiation.

8. Seismic damage to the racks could result in the release of unacceptable amounts of radioactive material into the environment and pose a threat to the public health and safety.

, 9. In order to approve the applicant's proposed license l

amendments to increase storage at the reactor site, the l

l Commission must determine that the amendment is consistent with the views of the population surrounding Diablo Canyon.

10. The proposed licensing amendments with respect to spent fuel storage are not consistent with the views of the population i

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surrounding Diablo Canyon.

11. PG&E did not attempt to ascertain the views of the population surrounding the reactor regarding spent fuel storage at Diablo Canyon.

12. The Diablo Canyon reracking license amendment requires compliance with the National Environmental Policy Act of 1969

("NEPA") 42 U.S.C. SS 4321 et seq.

13. No environmental impact statement ("EIS") has been prepared for the Diablo Canyon Spent Fuel Reracking.

_, 14. An EIS is required under NEPA before approval of the licensing amendment-application.

15. A generic EIS was prepared in 1970 for spent fuel rerackings. This EIS was not site-specific and assumed facts that differ substantially from those at Diablo Canyon.

16. An Environmental Assessment was prepared for the reracking application. That Environmental Assessment assumed facts which were at substantial variance with the conditions and proposal for the Diablo Canyon reracking, and is therefore inadequate under NEPA.

17. The Environmental Assessment does not obviate the requirement that an EIS be prepared for the Diablo Canyon reracking.

18. The Environmental Assessment does not meet the NEPA requirements for a full environmental inquiry.

19. There were no public meetings or hearings designed to meet the public notice and input requirements of NEPA.

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20. Alternatives which must be considered, in addition to that proposed by the applicant, include (a) construction of new facilities at the site of the reactor; and

. (b) Acquisition of modular or mobile spent nuclear fuel storage equipment, including spent fuel casks.

21. The alternative of spent fuel cask storage has not been adequately examined by the applicant.

22. Alternative on-site storage methods have not been given serious consideration.

23. No calculations have been done to ascertain the capacity of the existing spent fuel pools using high-density rack modules spaced widely enough so as to preclude impacts between racks and between rack modules and the walls of the pools.

24. No serious consideration has been given to dry cask storage.

25. There has been no attempt to show that the proposed reracking represents the safest of all reasonable on-site storage strategies.

26. The proposed high density racks are designed to be free standing in the spent fuel pools.

27. In response to the safe shutdown earthquake at Diablo Canyon (also known as the Postulated Hosgri Event, or PHE), the i proposed high density racks are expected to:

a. undergo gross sliding and tilting motions;

b. attain amplitudes of sliding motion which are not 4

minimal; and

c. undergo sliding and tilting motions which will not be contained within suitable geometric constraints.

28. In response to the safe shutdown earthquake at Diablo Canyon, impact between adjacent rack modules and between a rack module and the pool walls is not prevented.

29. The proposed high density racks are likely to undergo simultaneous collisions with each other during a PHE.

30. The Licensing Report does not discuss, and assumes that the racks will not hit the pool walls during a PHE.

31. The Licensing Report cites tables with a maximum impact value (for a single corner) of 71,400 lb, (page 6-27) although calculations had been done indicating maximum impacts of 105,000 lbs. and up to 125,000 lbs.

32. No mention is made in the Licensing Report of rack-wall impacts, although such impacts had been predicted.

33. As late as November 21, 1985, J.K.McCall of PG&E Civil Engineering claimed that " Joseph Oats [ sic] should address and verify that the actual displacement of these and other peripheral modules is such that there is no impact to the pool walls."

34. The single rack model used in the licensing report is overly simplified and is not expected to accurately represent the response of a fuel rack to seismic excitation of the postulated Hosgri event.

35. There has been no three-dimensional analysis of multi-rack effects performed to verify the conservatism of the 5

single rack models used in the licensing report.

36. The two-dimensional analysis of multi-rack effects which has recently been done is inadequate to verify the conservatism of the single rack models used in the licensing report.

37. There has been no testing of the spent fuel racks to ascertain whether or not the rack parameters used for analysis (spring constants, maximum allowable forces, etc.,) accurately represent the proposed racks.

38. Different experts hold - different opinions as to what.

constitutes adequate analysis.

39. As recently as March, 1987, experts (Degrassi, Ashar) had serious unresolved technical questions, even though a no significant hazards determination and an operating license amendment had been issued May or June 1986.

40. The Standard Review Plan ("SRP"), NUREG -

0800, i

provides-that spent fuel racks must remain functional during an earthquake.

41. The SRP requires that the spent fuel racks be designed to prohibit sliding and overturning.

42. Under the Acceptance Criteria in the OT Position paper, collisions between racks are still prohibited, although minimal sliding and tilting motions are permissible.

43. The high density racks as proposed violate the acceptance criteria as contained in the OT Position Paper.

44. No new acceptance criteria has been proposed by PG&E or 6

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the NRC to apply to the proposed high density racks.

45. Additional analysis was requested by the NRC staff in February and March, 1987 concerning rack-to-rack and rack-wall collisions during a PHE.

46. The applicant responded to the request for additional analysis by doing further modeling, including the development of new fluid coupling modeling by the Holtec Company (hereinafter "Diablo Studies.")

47. The accuracy of the Diablo Studies and therefore the safety of the proposed storage system depends on the validity and accuracy of the fluid coupling modeling and the theories employed in the analysis.

48. Sound engineering practice demands experimental verification of theories used in critical analyses.

49. R.J. Fritz performed experiments to verify the theories which form the basis of the theoretical analysis of the Diablo Studies.

50. No experiments have been performed to validate the fluid coupling theories for systems comparable to the rack modules or fuel elements in the Diablo Studies.

51. The authors of the Diablo Studies did not expect their fluid coupling theories to be accepted by the scientific community until experimental verification had been achieved.

52. Non-linear (gap closure) effects may be important to the fluid coupling analysis, yet have not been thoroughly studied. Soler and Singh indicated only that "there is some 7

preliminary evidence that the neglect of the effects may be conservative." The neglect may not be conservative.

53. The fuel elements have been modelled as solid units, with all the water in the element moving in unison with it. Given the open structure of a fuel element and the relatively low velocities of the fuel elements, a significant amount of water is expected to move through the element. The neglect of this phenomenon in the fluid coupling theory is expected to be non-conservative.

54. The use :of fluid coupling theories _ for rack analysis has been applied to increasingly complicated aspects of the problem:

1) Initially it was intended to describe only the motion of the rattling fuel;

2) It was then extended to include non-linear (gap closure) effects (Soler and Singh '82);

3) Non-linear effects have since been ignored, but the theory has been used for large amplitude vibrations, even though Fritz's basis was derived and tested only for small amplitudes (Soler and Singh '84);

4) It was extended to describe the movement of entire racks

[ (Soler and Singh '84);

! 5) It was further embellished to describe the effects of wedge-shaped gaps (2D analysis);

6) It was further embellished to describe the effects of l motions of neighboring rows of racks on the effective gaps 8

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-(Paul).

None of these modifications has been : subjected to experimental

' tests.

55. The Diablo studies' fluid coupling modeling has not been subjected to public professional and academic scrutiny.

56. The fluid _ coupling modeling should not be used as a

basis to approve the license amendments in the absence of-(a) academic scr.utiny (b) academic acceptance (c) _ experimental-verification --

57. The proposed spent fuel racks have been treated as rigid for the purposes of analysis, and rack distortions have been ignored. No evidence has been presented to . show that the analysis which ignored rack deformations is conservative.

58. The fluid coupling theory used in the rack analysis is highly sensitive to the spacing between fuel racks. The flexibility of the fuel racks is expected to have a significant effect on this spacing and therefore on the behavior of the racks in response to seismic excitation.

59. It cannot be concluded that the proposed high density racks are safe.

60. The license amendment is denied.

Dated: June 3, 1987 Respectfully submitted, GRUENEICH & LOWRY By -

, , C Edwin F. Lowry (,

Attorneys for Sier N Club 9

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l nC?EIE PROOF OF SERVICE JOH i

I, Deborah M. Hunt, declare that on June 4, 1987, I 4t,g p3 gj copies of the attached Proposed Findings of Fact and Concl i M Law in the United States mail with postage thereon fully prepaid and addressed to the parties listed below: fy,u .- Ma '

Dr. Jerry Harbour 00CM W ',.) "

Mr. Leland M. Gustafson, BRAh'-

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. :760 Alisal Street l Office of the Exec. Legal Dir. San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Ms. Laurie McDermott, j .

Coordinator Atomic Safety E Licensing C.O.D.E.S.

Board Panel 731 Pacific Street, Suite 42 U.S. Nuclear Regulatory Comm. San Luis Obispo, CA 93401 i Washington, D.C. 20555 Mrs. Jecquelyn Wheeler B. Paul Cotter, Jr., Chairman 2455 Leona Street Administrative Judge San Luis O' lspo, 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 i Atomic Safety & Licensing Crecton, CA 93432 Appeal PcAal

U.S. Nuclear Regulatory Comm. Ms. Nancy Culver Washington, D.C. 20555 192 Luneta Street San Luis Obispo, CA 93401 1

Bruce Norton, Esq.

Pacific Gas G Electric Company i P.O. Box 7442

( San Francisco, CA 94120 i

I am, and was at the time of the service of the attached l

paper, over the age of 18 and not a party to the proceeding.

I declare under penalty of perjury that the foregoing is true and correct.

(

)f Deborah M. Hunt N.

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