ML20214T158
| ML20214T158 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/04/1987 |
| From: | Vogler B NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Bright G, Cotter B, Harbour J Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3685 OLA, NUDOCS 8706100146 | |
| Download: ML20214T158 (101) | |
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UNITED STATES j' 'i NUCLEAR REGULATORY COMMISSION wa
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_ June 4, 1987 '87 JUN -8 P4 :26 OFFIL . , , ,
00 CME W . i av rr.
B. Paul Cotter, Jr. , Chairman Glenn O. Bright, Esq.
Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry Harbour Atomic Safety and Licensing Board Panel
- U.S. Nuclear Regulatory Commission
! Washington, D.C. 20555 i
In the Matter of PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Nuclear Power Plant, Units 1 and 2)
Docket Nos. 50-275 OLA and 50-323 OLA (Spent Fuel Pool)
Dear Administrative Judges:
In accordance with this Board's Memorandum and Order of January 28, 1987, and April 9, 1987, enclosed is the "NRC Staff Testimony of Hansraj G.
Ashar, Howard M. Fishman, Giuliano Degrassi, Walter L. Brooks , 'and Amarjit Singh On Sierra Club Contentions I(A)3 and 4; I(B)2 8 and 9:
II(A)1 thru 9 and II(B)1 thru 9" as well as the "NRC Staff Testimony of Donald P. Cleary on Sierrra Club Contention I(B)7.
In addition, pursuant to the Board's direction, the Staff has enclosed its draft Proposed Findings of Fact and Conclusions of Law and a list of exhibits agreed upon by the parties.
Sincerely, 1 Of
\
D l Benjamin II. Vogler Counsel for NRC Staff
Enclosures:
As stated cc: w/ enclosures: Service List A
8706100146 870604 i(
PDH ADOCK 05000275 T PDR , ()
D
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of )
)
PACIFIC GAS AND ELECTRIC- ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA
)
, (Diablo Canyon. Nuclear Powcr Plant ) (Spent Fuel Pool)
Units 1 and 2) )
NRC STAFF TESTIMONY OF HANSRAJ G. ASHAR, HOWARD M. FISHMAN, GIULIANO DEGRASSI, WALTER L. BROOKS AND AMARJIT SINGH ON SIERRA CLUB CONTENTIONS I(A)3 AND 4; I(B)2, 8, AND 9; II(A)1-9 AND II(B)1-9 Q.1 Mr. Ashar, please state your name, affiliation, and position.
4 A.1 My name is Hansraj G. Ashar. I am a Structural Engineer in the Structural and Geosciences Branch of the Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. A statement of my professional qualifications is attached to this testimony.
Q.2 Mr. Fishman, please state your name, affiliation, and position.
A.2 My name is Howard Martin Fishman. I am Section Head of the Structural Engineering Section of the Engineering Department of the Franklin Research Center. A statement of my professional qualifiestions is attached to this testimony.
I Q.3 Mr. DeGrassi, please state your name, affiliation, and position.
A.3 My name is Giuliano DeGrassi, I am a Research Engineer in the Structural Analysis Division of the Department on Nuclear Energy, l
l
- p. .
Brookhaven National Laboratory. A statement of my professional qualifications is attached to this testimony.
Q.4 Dr. Brooks, please state your name, position and affiliation.
A.4 My name is Walter L. Brooks. I am a Nuclear Engineer in the Reactor Systems Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. A statement of my professional qualifications is attached to this testimony.
Q.5 Mr. Singh, please state your name, position and business address.
, A.5 My name is Amarjit Singh. I am a Reactor Operations Engineer, Inspections, Licensing and Research Integration Branch, Program f
Management, Policy Development and Analysis Staff, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
A statement of my _ professional qualifications is attached to this tesdmony.
l Q.6 Mr. Fishman, what is the relationship of the Franklin Research Center to the matters before the Licensing Board?
A.6 The Sta' of the Franklin Research Center (FRC), as consultants to l
the Staff of the Nuclear Regulatory Commission (NRC), prepared a l
I technical evaluation report, Evaluation of Spent Fuel Racks, Struc-tural Analysis, Pacific Gas & Electric Company, Diablo Canyon Units 1 and 2, dated April 30, 1986, and revised on May 28, 1987.
This reprt , identified as TER-C5506-625, and included as
O Attachment A 'in the NRC Safety Evaluation Report, dated play 30, .
~
1986 (Staff Exhibit No.1), will be referred to in the remainder of my testimony as the "FRC report." The object of the FRC effort was to determine the structural adequacy of the -high-density spent fuel racks and spent fuel pool proposed by the licensee, Pacific Gas
- j. and Electric Company (PG&E). The licensee's report, which will be referred to as the "Reracking Report ," is entitled Reracking of Spent Fuel Pools, Diablo Canyon Units 1 and 2 (September 1985).
! FRC also reviewed Seismic Analysis of the High Density Fuel Racks l
! for Pacific Gas & Electric for Diablo Canyon Nuclear Power Station, l . Revision 3 dated September 21, 1986 and prepared by the Joseph Oat Corporation for the Licensee. This report , which will be
- referred to as the " Seismic Report," provides analysis details summarized in the Reracking P.eport. FR0 as consultants to the NRC also reviewed and evaluated supplementary submittals by the Licensee including, Additional Information on Rack-to-Pack l
Interactions, dated April 7,1987, which will be referred to as the l "2D Report ," and Three-D mensional Studies on High Density Spent Fuel Racks (Acorn 10 and Acorn 12), dated April 23, 1987, which will be referred to as the "3 D Report. " Many other responses by the Licensee to NRC's request for additional information were reviewed by FRC. The revised FRC report (Staff Exhibit 1-A) summarizes FRC's review and evaluation of the Licensee's reports and concludes that the Licensee's structural analyses of the spent fuel rack modules and the spent fuel pool are l
l
e s
adequate and are acceptable; they indicate the rack modules and
~
pool structure to be satisfactory for high density fuel storage.
Q.7 Mr. Fishman, are you the principal author of FRC report?
A.7 No. The principal author of technical evaluation report TER-C5506-625 is Mr. R. Clyde Herrick. Mr. Herrick died July 24, 1986. I am, however, the principal author of the revised FRC report. (Staff Exhibit 1-A). In preparing it, I have thoroughly reviewed the original report and made modifications, where -
l warranted, base'd upon my evaluation of the Licensee's Reracking Report and supplementary submittals.
Q.8 Mr. Fishman, in preparing your testimony have you considered the Sierra Club's interrogatory responses prepared by Dr. Richard B.
Ferguson, dated October 3,1986 and November 6,1986?
A.8 Yes. I reviewed the technical data in the interrogatory responses prepared by Dr. Ferguson, including his analytical models, and the computer programs that he has developed, COLL 4053 and D3 SLIDE.
Q.9 Mr. DeGrassi, what is the relationship of Brookhaven National Laboratory to the matters before the Licensing Board?
A.9 The Staff of Brookhaven National Laboratory (BNL), as consultants to the NRC staff, is participating in the review of the reracking of l
l the spent fuel pool at the Byron Nuclear Plant. During the course l
of the review, BNL raised a question regarding the adequacy of the l
l analytical models of the fuel racks in predicting loads resulting from i
k wer - em p -w-- -i-yy p gmip e----Wg g y ,e---e p -y-c- - - - - - - - -
. i potential multiple rack impacts -during the Design Basis-Earthquake.
The Byron racks are of a similar free-standing design as the proposed Diablo ' Canyon racks and were seismically qualifted by similar analytical methods. In addition, the question raised by BNL~
appeared relevant to the Sierra Club Contention II (B). 'As a result, the NRC staff contracted BNL in March,1987, to investigate the safety significance of this question for Diablo Canyon. BNL assisted the NRC staff in the preparation of requests for additional t
information related to the multiple impact question and reviewed the
- results of additional analytical studies performed by PGaE in response to these requests. The results of the BNL ~ review are 4
summarized in a technical evaluation report, " Evaluation of the 1 Structural Adequacy of the Diablo Canyon High Density Spent Fuel et Racks in Accommodating Multiple Rack Impacts During the Postulated Hosgri Earthquake." The report is identified as Staff Exhibit 1-B.
Q.10 Mr. Ashar, have you been the principal NRC staff structural reviewer of the Diablo Canyon reracking proposal?
I A.10 The principal NRC staff reviewer with regard .to the structural aspects of the Diablo Canyon high density reracking proposal was Frank Rinaldi. However, due to his hospitalization, I was i designated the principal reviewer on this matter. I have reviewed the NRC Staff's Safety Evaluation (Staff Exhibit No. 1) and supplemented it by my testimony herein to reflect the results of i
additional analyses performed by the Licensee. I adopt the f
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conclusions reached in Staff Exhibit 1 and in the testimony regarding the structural integrity of the high density racks during the PbE. (Findings 1-3)
Q.11 Gentlemen, what is the purpose of your testimony?
A.11 The purpose of this testimony is to address Sierra Club Contentions 1(A)3 and 4; I(B)2, 8, and 9; II(A)1-9 and II(B)1-9.
Sierra Club Contention I(A)3 provides:
It is the contention of the Sierra Club, Santa Lucia Chapter (Sierra Club), that the report submitted to the NRC entitled Reracking of Spent Fuel Pools, Diablo Canyon Units 1 and 2 and other communications between facific Gas and Electric Company (PGaE) and the NRC, which are available to the public on the same subject (the Reports), fail to contain certain relevant data nec-
, essary for independent verification of claims made in the Reports regarding consistency of the proposed reracking with the protection of. the public health and safety, and the environment.- In particular, the Reports fail to con-tain data regarding:
eee I
( (3) the expected velocity and displacement of the spent l fuel pools (pools) as a function of time in three dimensions during the postulated Hosgri earthquake (PHE).
Q.12 Mr. Fishman, did the Reports contain data regarding the expected velocity and displacement of the spent fuel pools as a function of time in three dimensions during PHE?
A.12 No, they did not. The velocity and displacement of the pools are not used explicitly in the licensee's reracking analysis. The dy-namic input for the analysis only requires the spent fuel pool's floor acceleration time history. It is my opinion that the licensee's l
l- _ _ _ . . . . . _ . _ _ ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
4, s
. methodology is appropriate and that, for the purpose of determining rack and wall impact loads, only pool acceleration is required as an input. In simple terms , earthquakes develop inertia forces on structures. Inertia forces may be computed from the well-known relationship, force equals mass times acceleration. Accordingly, the data regarding the expected velocity and displacement of the spent fuel pools as a function of time in three dimensions was not explicitly included. (Finding 4)
Sierra Club contention I(A)4 provides:
It is the contention of the Sierra Club, Santa Lucia Chapter (Sierra Club), that the report submitted to the NRC entitled Reracking of Spent Fuel Pools, Diablo Canyon Units 1 and 2 and other __ communications between Pacific Gas and Electric Company (PGaE) and the NRC, which are available to the public on the same subject (the Reports), fail to contain certain relevant data nec-essary for independent verification of claims made in the Reports regarding consistency of the proposed reracking with the protection of the public health and safety, and the environment. In particular, the Reports fall to con-tain data regarding:
eee
- 4) the expected maximum velocity and displacement of the racks obtained from computer modeling of rack behavior during the PHE; Q.13 Mr. Fishman, did the Report contain data regarding the expected maximum velocity and displacement of the racks obtained from l
computer modeling of rack behavior during the PHE?
i A.13 The Reracking P6eport contains references to maximum displacement but did not refer to maximum velocities. It is my understanding of i
l the licensee's computer analysis, that instantaneous values of l
l
- _ = . _ . - - _ _ _ - . . . _ -
- displacement and velocity are calculated for all degrees of freedom 1 71 the licensee's model for each integration time step during _ the period of the mathematical representation of the PHE (24 seconds).
These values are used to compute design forces, but are not stored on computer printouts or on permanent disk files.
Q.14 Mr. Fishman, at one time, it was contended that the spent fuel pools could be expected to undergo large (as much as 8 feet) displacements during the PHE. Do you agree that such large
, displacements are to be expected?
A.14 No. The PHE, or any-earthquake, is usually represented, for the
. purpose of structural analysis, in two forms. The first in terms of response spectra , wherein acceleration is presented in terms of frequency. The second, where acceleration is presented as a function. of time. For a postulated earthquake the response spectrum is usually prescribed, from which an artificial acceleration time history may be mathematically derived. This artificicI accelera-tion time history is developed as the superposition of sine waves with different amplitudes, frequencies, and random phase-shifts.
Large cumulative values of acceleration, velocity, or displacement would not occur and these motion quantitics would tend to oscillate about zero because of the vibratory characteristics of a real earthquake, which are simulated by artificial time histories.
The artificial acceleration time histories for the PHE were computed by the Licensee using a modified version of the computer program
~., . . - . .- . - - . .- - - - - -
_g-SIMQKE developed at the Massachusetts Institute of Tegnology.'
The primary purpose of this computer program is to simulate earthquake motions with artificial time histories that correspond to 4
the applicable response spectra. For an appropropriate earthquake simulation, there is a branch in SIMQKE that performs a baseline correction on the acceleration time history, so that the corresponding velocity would tend to oscillate about zero. It is my ur.derstanding that the Licensee did not perform the baseline correction for the north-south and east-west PHE at the spent fuel pool elevation in the Diablo Canyon units. The Licensee provided me with the acceleration time - histories and I then corrected the acceleration time histories, applying the same baseline correction that the computer program SIMQKE can perform. I then developed, in my opinica, more appropriate time histories. The corresponding acceleration , velocity, and displacement time histories, for the t
i east-west PHE are appended to this testimony as Figures 1, 2, and
- 3. Note , that there is no significant difference between the uncorrected acceleration and the corrected ones as displayed in j
l Figure 1, which plots the uncorrected (original) acceleration and the difference between the original and corrected acceleration time histories. The largest difference for any of the 2401 acceleration i
values is 0.0013g which is 0.17% of the 0.75g postulated maximum acceleration during the east-west PHE. Also note, as can be seen i in Figure 3, that the displacement does oscillate about zero for the i
baseline corrected solution; the maximum amplitude is 16.21 inches for the east-west direction and the final displacement is -4.83 i
i l
l
~ . _ _ _ _ _ . -
_ . __ _ _ _ _ _ __. . _.. _ __ _ .__.m .
l inches as compared to the uncorrected value of 79.98 inches. It is j riiy opinion that the magnitude of the spent fuel pool displacement
~
would not significantly alter the results of the nonlinear dynamic snalysis for the racks performed by the licensee, since the rates of
~ change of both the baseline corrected and non-corrected displacements (i.e. , spent fuel pool velocity and acceleration) are nearly identical. (Findings 5-6).
Sierra Club Contention I(B)2 provides:
It is the contention. of the Sierra Club that the Reports fail to include consideration of certain relevant condi-tions, phenomena, and alternatives necessary for inde-pendent verification of claims made.in the Reports regarding consistency of the proposed reracking with the protection of the public health and safety, and the envi-ronment, and with federal law. In particular, the Re-ports fail to consider:
eee
- 2) the resonant behavior of the spent fuel assemblies in response to the PHE and the consequences of such behavior; Q.15 Mr. Fishman, did the Reports consider the resonant behavior of the spent fuel assemblies in response to the PHE and the consequences of such behavior?
- A.15 No, the concept of resonance is not applicable to the analysis of the spent fuel assemblies. The concept of resonance, in which large vibrations can be induced by a small stimulus vibrating at a natural frequency of a mechanical system, is usually applicable to linear t
systems. The interaction between a spent fuel assembly and its cell walls is modeled by the licensee with gaps, impact springs, and
hydrodynamic effects, all of which are significantly nonlinear. The license,e's model, however, can predict a phenomenon similar to res-onance, if it were to occur. In Section 6.2.1 of the Reracking Report, the mechanism of " rattling" is discussed. The possibility of a fuel assembly interacting with the cell wall and rebounding 4:
with increased impact force with each cycle was included in the model. The licensee's computations indicated that this phenomenon did not occur during the PHE cxcitation. (Finding 7)
Sierra Club Contention I(B)8 provides:
It is the ' contention of the Sierra Club that the Reports fail to include consideration of certain relevant condi-tions , phenomena, and alternatives necessary for inde-pendent verification of claims made in the Reports regarding consistency of the proposed reracking with the protection of the public health and safety, and the envi- *0 ronment, and with federal law. In particular, the Re-ports fail to consider:
e.
, 8) the use of enchors, braces, or other structural members to pre, vent rack motion and subsequent damage during the PIIE.
Q.16 Mr. Fishman, did the Reports consider the use of anchors, braces, or other structural members to prevent rack motion and subsequent damage during the PIIE?
A.16 No. The reracking analysis is based on a free-standing rack modeling configuration and thus did not consider any structural constraint to prevent rack motion. The FRC report concludes that the Reracking Report demonstrates compliance with the requirements of the codes, standards, and practices for the spent fuel pool
\.
modification. Therefore, an analysis of the use of anchors, braces or other structural members to prevent rack motion and subsequent damage during the PHE is not required. (Finding 8)
- e Sierra Club Contention II(A)1 provides
It is the contention of the Sierra Club that the proposed veracking is inconsntent with the protection of the pub-lic health and safety, and the environment, for reasons which include the following:
A) during PHE, collisions between racks and the pool walls are expected to occur, resulting in:
- 1) impact forces significantly larger than those
, estimated in the reports; Q.17 Mr. Fishman, did the Reracking Report consider any collisions be-tween racks and between racks and pool walls resulting in impact forces during the PHE?
A.17 Yes. Collisions between adjacent racks and the possibility of colli-dons between rack and wall were considered in the Licensee's Eeracking Report. In the Licensee's Seismic Report and the supple-mental 2D Report, which the Licensee prepared in response to NRC's request for additional information, collisions between adjacent racks and between rack and wall were computed.
Q.18 Is movement of the racks and possible collision of the racks with each other and the spent fuel pool walls prohibited by the NRC regulations?
A.18 No. The NRC OT position paper entitled " Review and Acceptance of Spent Fuel Storage and Handling Applications," issued April 14,
y, z -
a 1978 and idodified January 18, 1979, clearly anticipates the possibil-ity of collision of the racks with each other and with the spent fuel pool walls.Section IV(6)(b) cf this' OT positicn ' paper states that impact loading should be quantified and that sliding and tilting mo-
- tions will be contair.cd within suitable geometric constraints.
mf Q.19 In your opinion, were the impact forces underestimated in the Reracking Report as asserted by the Sierra Club contention?
A .'19 In my opinion, the- tredeling and analysis of the rack and fuel assemblies were inppropriate to conservatively estimate the impact forces on racks during the PHE. The Rerocking Report did not predict the impact forces on the pool wall, however, the Licensee's Seismic Report and 2D Report did predict rack-to-wall impact. In L any case, the Licensee did design the pool walls for impact. This was reported in PG&E Response to NRC Request for Additional Information DCL-86-019, dated January 28, 1986, which provided for their most critical wall subjected to the PHE, a stress ratio of 1.4. This stress ratic of 1.4 on a pool wall implies that the total horizontal load on the wall could be increased by 40% up to a capacity of 92 kips per foot. This capacity permits the wall design f
r , impact load to he increased by a factor of 4, since the impact is
[/ only a portion of the total horizontal load. The wall impact load calculated in the 2D Report is 2.7 times the wall design impact load; I
consequently the wall loads are less than the capacity. The analysis was based upon well-established engineering principles and acceptable modeling considerations such as:
f o The simultaneous consideration of three orthogonal seismic ac-
-- celeration time-histories (3-dimensional analysis)
- Elnstic flexibility of the rack module
- Impacts of the spent fuel assemblies oscillating in the clearance space of the rack storage cells t c The effects of impacts with an adjacent rack or the pool wall o Off-center partial fuel loadings as well as full fuel load o A documented range of friction coefficients between the mount-ing pads and the pool liner o The hydrodynamic effects of water (i.e., fluid coupling) be-tween rack _ and fuel assemblies, and between rack and adjacent racks and walls o Fluid damping between rack and assemblies, and between rack and adjacent racks, is conservatively neglected o The form drag opposing the motion of the fuel assemblies and fuel racks are neglected, in view of the above, it is my opinion that the impact forces on the racks' and pool walls are not significantly larger than those anticipated in the Licensee's Reracking Report. (Finding 9)
Sierra Club Contention II(A)2 provides:
It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the pub-lic health and safety, and the environment, for reasons which include the following:
A) during PHE, collisions between racks and the pool walls are expected to occur, resulting in:
- 2) impact forces on the racks significantly larger than those expected to damage the racks; i
. , . - - - - - , . . ~ - , . , . . , _ -- -..._-_.-----__..._----,,-..__L_-. . - _ . , .
Q.20 Mr. Fishman, in your opinion are the impact forces on the racks,*
j 1
a's a result of the PHE, significantly larger than those expected to 1
- damage the racks?
A.20 No. In my opinion, the licensee computed maximum impact forces on the racks attributable to the PHE using a range of credible assumptions. The computations, as discussed in my responses to Contention 11(A)1, were the results of the computer analysis, which I consider appropriate for the determination of impact forces on the racks. In the Reracking Report , Section 6.9, allowable impact forces were given for portions of the rack. The basis for the computation of allowable impact forces on the girdle bars is incipient plasticity, that is, the load that would cause the girdle bars that frame the top to the rack to reach the yield stress. The basis for the computation of allowable impact forces on the cell walls is plastic limit load analysis with a factor of safety of 2. In my opinion, these computed allowable impact forces are correct. The licensee then compared the maximum computed impact loads to the allowable impact forces; ample safety margins are found in all cases and the impact forces on the racks were determined not be be significantly larger. Even if the impact loads were to be increased to 150% of the maximum computed impact values , providing for modelling uncertainties, the resulting safety margins would still be greater than 1. Also, as was noted, the controlling allowable load is based i
on incipient yield of the girdic bar, which could cause small permanent deformation. Between this allowable load and the load required to cause large permanent deformation, there is a large
t i
reservoir of energy absorbing capacity in the rack modules.
(Finding 10) 4
. Sierra Club Contention ll(A)3 provide:
It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the pub-lic health and safety, and the environment, for reasons which include the following: -
A) during the PHE, collisions between the racks and the pool walls are expected to occur resulting in:
- 3) sigflificant permanent deformation and other damage to the racks and pool walls;
('.21 Mr. Fishman, in your opinion, do you believe that significant per-4 manent deformation and other damage to the racks and pool wall is likely to occur as a result of the PHE?
A.21 - No. The licensee's Heracking Report (PGaE Exhibit No. 1) addresses quantitatively the results of the impact analysis between
( a fuel assembly and cell wall as well as between an adjacent rack and/or a pool wall (Sections 6.9.1 and 6.9.2, respectively) .
Allowable impact loads were compared to the calculated maximum corresponding impact loads during postulated Hosgri earthquake (PHE). A summary of the impact analysis results as shown in Tables 6.8.1 and 6.8.2 of the Reracking Report (PG&E Exhibit No. 1) clearly indicates that in all cases no significant permanent deformation or corresponding damage at the impact locations is l
l expected (i.e., stress levels remain below the yield value). From l
Teble 6.8.2, it can be seen that the largest calculated impact force I
between storage, cell'and fuel assembly is 249,900 lbs. , which is 28%
of the allowable of 883,000 lbs. The largest calculated impact force between racks was reported in the Licensee's Seismic Report and -
not in the Reracking Report. In Table 6.3 of the Seismic Report a rack-to-rack impact force of 105,000 lbs. was reported, which is 60% of the allowable of _175,000 lbs. The supplementary 2D Report calculated a rack . impact for a two-dimensional multi-rack configuration of 107,000 lbs, 61% of the allowable. Accordingly, I do not anticipate any - significant permanent deformation or other damage to the racks or spent fuel pool walls during the PHE.
(Finding 11)
Sierra Club Contention II(A)4 provides:
It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the pub-lic health and safety, and the environment, for reasons which include the following:
A) during the PHE collisions between the racks and the pool walls are expected to occur resulting in:
l
- 4) reduction of the spacings between fuel assemblies; l
l Q.22 Mr. Fishman, in your opinion, do you believe that the spacings l
between fuel assemblies will be reduced as a result of impact forces l-I developed during the PHE?
t i
A.22 As stated in my previous response to Contention II(A)3, no signifi-l cant permanent deformation is expected at any possible impact loca-l tion. Accordingly, there is no anticipated permanent reduction of
the spacing between fuel assemblies due to impact forces. (Finding -
12)
Sierra Club Contention II(B) provides:
It is the~ contention of the Sierra Club that the proposed rerecking is inconsistent with the protection of the pub-lic health and safety, and the environment, for reasons which include the following:
ee e B) during the PHE, 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.
Q.23 Mr. Fishman, in its initial evaluation of PG&E's rerack proposal, did FRC evaluate the possibility of multi-racks impacts?
~
'A.23 Yes.
Q.24 What did FRC conclude in its initial evaluation with respect to this
- matter?
A.24 In its initial evaluation, as presented in Appendix A to the Staff's Safety Evaluation at Section 3.3.2.2 the FRC concluded that the licensee's analyses of -single racks with adjacent racks moving out-of-phase, tended to maximize computed impacts between racks.
t This conclusion was based on the fact that the licensee's three-dimensional models represented several sizes of rack modules, with ,
different fuel configurations, a documented range of friction coefficients, and generally conservative parameters.
i
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Q.25 Mr. Ashar, what was the Staff's position on this matter?
A.25 The NRC staff, in consultation with its consultant the Franklin Research Center, took a position that with the dissimilarities of racks (in geometry and stiffness) and the expected diverse responses of the racks, the possibility that two or more racks could be positioned tightly together and move in unison to damage another rack is extremely low.
Q.?6 Mr. Ashar, did the Staff ask PG&E to undertake further analyses of the multi-rack impact issue subsequent to its initial evaluation? -
A.26 Yes.
Q.27 Could you explain why such further analyses were requested?
A.27 Yes. As stated previously, during the review of the Byron reracking application the NRC consultant, Brookhaven National Laboratory , pointed out the issue of multirack impact as the one requiring acceptabla resolution. The Staff was also aware of the issue as being one raised during the spent fuel pool rerack proceeding at Diablo Canyon. Thus, because of the sensitivity of the issue and a potential for doubt about the conservatism in the calculated impact forces , the Staff decided to review the issue of multi-rack impacts for Diablo Canyon reracking application.
Q.28 Mr. DeGrassi, please explain why Brookhaven raised its concerns regarding the multi-rack impact in the connection with the Byron reracking application?
A.28 Brookhaven raised its questions on this matter because. the model used to predict seismic motion did not explicitly include provisions to simulate multiple rack impacts. It was considered possible that such impacts could occur with possibly higher impact loads than are I
obtained from a single-rack impact model as was used by the Licensee.
Q.29 Mr. DeGrassi, in your opinion, can collisions between groups of racks with each other and/or the pool walls occur during the PHE resulting in larger forces than the Licensee reported, as asserted by the Sierra Club?
'A.29 In my opinion, collisions between groups of racks with each other and/or the pool walls are likely to occur during the PHE.
However, I would not expect the multiple rack collisions to result in forces exceeding the design allowables. This opinion is based on i-my review of the design basis results and of parametric studies i
performed by the Licensee to investigate the consequences of multiple rack collisions. My evaluation is summarized in a technical evaluation report which is identiffed as Staff Exhibit 1-B.
l Although the Licensee's design basis single rack models did not explicitly account for simultaneous multiple rack impacts , they i incorporated several modeling assumptions which would be expected to provide conserystively high impact forces. They included the following:
n -
1 o Each three dimensional single rack model included planes of l symmetry midway between - the modeled rack and the surrounding adjacent racks.- These symmetry planes in conjunction with impact springs at the rack corners mathematically simulated the interaction of two identical racks colliding with equal and opposite velocities.
e The impact spring rates used in the design basis models were significantly higher than calculated values. For a given impact velocity, rack impact loads would be expected to increase with higher spring rates, a The fluid coupling coefficients used in the design basis models neglected the coupling effects of adjacent racks perpendicular to the direction of the earthquake. The lower fluid coupling forces would be expected to result in higher rack velocities and impact forces.
At the request of the NRC staff, the Licensee performed pnametric studies to investigate the adequacy of the design basis models in predicting impact lords resulting from multiple rack collisions. The parametric studies included:
! a The analysis of two-dimensional multiple rack models of typical rows of four racks utilizing realistic impact spring and fluid coupling parameters.
o The analysis of two-dimensional single rack models (for comparison with multiple rack model results) utilizing; (a) parameters consistent with design basis models , and 1
i (b) realistic parameters consistent with multiple rack models.
l 1
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l a The analysis of a three-dimensional fully loaded 10 x 11 corner
~
rack model with realistic parameters consistent with multiple
- rack models (for comparison with design basis model results).
The parametric studies demonstrated that although multiple rack collisions may occur during the PHE,- impact forces would not be significantly higher than predicted by a single rack model. The design basis models can be expected to predict conservative impact forces which, in most cases, will envelope multiple rack impact forces. Under worst conditions, the studies suggested that multiple rack impact forces' may' be as much as 20% higher than predicted by the design basis models. However, the design basis analysis indicated that the most highly loaded rack can sustain an impact load of nearly 70% above the predicted value (105 kips) before reaching its allowable load value (175 kips). Other racks have even larger safety margins.
In summary , I believe that the parametric study results coupled with the consideration of design basis safety margins have provided sufficient evidence to conclude that impact forces resulting from multiple rack collisions during the PflE can be accommodated within design allowables.
Q.30 Mr. Fishman, has FRC evaluated the recent analyses performed by
! PGaE on the multi-rack support issue?
f A.30 Yes. FRC's further evaluation is documented as a revision to the FRC's original Technical Evaluation Report (Staff Exhibit 1-A).
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Q.31 How did FRC's evaluation of PG&E's recent analyses affect your
~
earlier conclusions?
A.31 As stated on page 75 of the revised Report (Staff Exhibit 1-A):
eee In summary , it was concluded that the Licensee's structural analyses of the spent fuel rack modules and the spent fuel pool are adequate and are acceptable:
they indicate the rack modules and pool structure to be satisfactory for high density fuel storage.
Q.32 Mr. Ashar, what is the Staff's position with respect to the adequacy of the racks and the spent fuel pools in light of PG&E's recent analyses on multi-rack impacts?
4 A 32 - The Staff accepts the findings and conclusions of the two technical evaluation reports prepared by FRC and BNL (Staff Exhibits 1-A and 1-D , respectively) , and considers them as parts of its ,g evaluation.
In response to the request for specific additionalinformation related to multi-rack impacts, the Licensee performed a number of parametric analyses using multi-racks in a row and subjecting them to the east-west Hosgri earthquake considered to be the worst of the two horizontal components of the earthquake. In the analyses, i two-dimensional planar motion of the racks was considered. A total of seven cases were analyzed.
f In order to understand the sensitivity of inget loads to changes in various parameters, the Licensee was asked to perform a 3-dimensional ratalysis of the heaviest corner rack using realistic
assumptions. The results of the analysis indicated that the rack-to-rack , fuel assembly to fuel cell and rack-to-rack impact loads were within the respective allowable impact loads.
Based on its evaluation of the supplementary information provided by the Licensee, discussion with the Licensee .at meetings, and information audited by the Staff and its consultants, the Staff concludes that the Licensee's structural analyses of the spent fuel rack modules and the spent fuel pool are in compliance with the acceptance criteria set forth in the FSAR and are acceptable.
(Finding 13)
Sierra Club Contentions II(A)6, 7, 8 and 9 and II(B)6, 7, 8 and 9 provide:
II. It is the contention of the Sierra Club that proposed reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which include the following:
A) during the PHE, collisions between the racks and the pool walls are expected to occur resulting in:
- 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;
- 8) radioactive contamination of the environment in the vicinity of the nuclear power plant above the levels permitted by federal regulations; and
- 9) radioactive contamination of humans and other living things in the vicinity of the nuclear power plant above the levels permitted by fed-
, eral regulations.
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25 -
(B) during the PHE, 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.
Q.36 Dr. Brooks, has the NRC staff considered the consequences of crit-icality in the spent fuel pools at Diablo Canyon?
General Design Criterion 61 requires that fuel storage facilities A.36 No.
be designed to assure adequate safety under normal and postulated accident conditions. General Design Critierion 62 requires that criticality in fuel storage and handling systems be prevented. Be-cause compliance with these General Design Criteria is required, thereby assuring that criticality does not occur, no analysis of the consequences of a criticality event in the spent fuel pool was per-formed for the Diablo Canyon plants. My testimony in response to Sierra Club Contentions II(A)5 and II(B)5, below, does, however, address the conditions that would have to occur in the proposed Diablo Canyon spent fuel storage racks to produce criticality.
Q.37 Dr. Brooks, could you describe development of criticality in the spent fuel pool assuming that conditions in the pool support its occurrence?
A.37 Yes. If one postulates that the k-effective value of the i
fuel-rack-water combination (the system) in the pool becomes great-er than unity (i.e. becomes supercritical) the neutron population would rise at a rate which depends on the amount by which 1 k-effective is greater than unity (i.e. the reactivity of the sys-tem) . The fission rate would increase and the temperature of the 4
i
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fuel would rise. The temperature rise in the fuel would act to re-duce the k-effective of the system (i.e. will introduce negative re-activity). At some high fuel temperature the net reactivity will be zero and the fission rate increase would cease (after some over-shoot) and begin to fall. If the initial value of k-effective is greater than about 1.005, the events described above would occur before a significant amount of heat is conducted from the fuel to the surrounding water. As heat is lost from the fuel its temperature would fall and the k-effective value would begin to rise again. The cycle described above would repeat itself until enough heat has been generated and deposited in the pool water to create sufficient volds to offset that part of the initial reactivity that is not offset by the . steady state fuel temperature rise. A final state would be reached in which the power generated in the pool is just enough to maintain the void content of the water. The heat generation rate of the final state (where the heat generation rate remains constant) will depend on:
j 1. The assumed initial reactivity insertion,
- 2. The void coefficient of reactivity (i.e. what void fraction in
( the water is required at the steady state),
l i
- 3. The thermal-hydraulics characteristics of the core which deter-f mines the amount of water that must be converted to steam per unit time. Meaningful estimates of the amount of heat generat-ed are not possible. However, it is clear that with aufHcient i
initial excess reactivity (k-effective greater than 1 by a large 1
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amount) large amounts of heat, and therefore radiation ,may be
~
generated.
Q.38 What is meant by the term k(eff)?
A.38 In a multiplying system- (one which contains fissionable material, such as the loaded spent fuel storage racks) three processes in-volving neutrons may be identified. These are neutron production, neutron absorption, and neutron leakage. The sum of the neutmn absorption and neutron leakage is the neutron loss. Given an ini-tial neutron . population in the system, if the production rate is greater than the loss rate, the population will increase. Converse-ly, if the production rate is less than the loss rate the population will decrease. If the two rates are equal the population will not change and the system is said to be just critical. The k(eff) value for the system is defined as the ratio of the production rate to the loss rate. (Finding 14)
Q.39 Mr. Singh, do the Diablo Canyon spent fuel pool cooling systems for Units 1 and 2 have the capability to remove decay heat under l
maximum normal and maximum abnormal heat load conditions?
A.39 Yes. The Staff's acceptance criterion, as stated in the Standard Review Plan (SRP), NUEEG-0800 (Section 9.1.3), specifics that a
, single cooling train be able to maintain the water temperature in the pool at or below 1400 F under the " maximum normal heat load" con-dition. The " maximum normal heat load" is generated by the follow-ing spent fuel pool storage configuration: one-third of a core fully 1
4
y irradiated and decayed for 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />, and the remaining cell spaces i
filled with fully irradiated fuel from previous refuelings. The maxi-mum normal heat load was calculated by the licensee and verffled by the Staff to be 2.28 x 107 (rounded) BTU /Hr. This heat load is conservatively based on decay for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> and one-third of a core plus 12 assemblies in addition to the remaining pool spaces filled with fully irradiated fuel from previous refuelings. A normal off-load is 64 assemblies. The maximum normal heat load was based on 76 assemblies. As a result, the Ifeensee's calculations are more conservative than prescribed by the Staff's acceptance criteria. As
-stated in the Staffs Safety Evaluation, this heat load will result in a maximum bulk pool temperature of 1400 F within 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> after the transfer of the last assembly; this meets the Staff's acceptance criterion of 1400 F for the bulk pool temperature. The maximum abnormal heat load was calculated to be 4.38 x 10 Btu / hour. The maximum abnormal heat load is for the offloading of 193 fuel assem-bhe6 (i.e. , one full-core) into the pool after the last normal offload. This abnormal heat load results in a maximum bulk pool temperature of 1740 F which meets the Standard Review Plan accep-l tance criterion of no bulk pool boiling for this condition.
I i
Q.40 Do the Diablo Canyon spent fuel pool cooling systems for Units 1 I and 2 have the capability for removal of decay heat beyond the
! maximum abnormal heat load conditions?
A.40 Yes. Each of the Diablo Canyon spent fuel pool cooling systems can remove a maximum heat load of 5.9 x 107 BTU /hr, and maintain i
4
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I the water temperature in 'each pool below the boiling point.
(Finding 15)
Sierra Club Contention I(B) 9 provides:
It is the contention of the Sierra Club that the Reports fail 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 rersching with public health and safety, and the environment, with federal law.
In particular, the Reports fall to consider:
ee.
- 9) the use of "Boraflex" neutron absorbing material for all fuel racks.
Q.41 Dr. Drcoks, how do you interpret this contention?
A.41 I assume that Sierra Club contends that Boraflex should be used in the Region 2 racks as well as the Region 1 racks of Diablo Canyon spent fuel pools. Region 1 racks are designed to store fresh fuel containing up to 4.5 weight percent U-235. Region 2 racks are designed to store fuel which has achieved a minimum burnup which is dependent on the initial enrichment. The required burnup is given in Figure 3.9-2 of the proposed Diablo Canyon Technical Specifications.
i Q.42 Vihy isn't Boraflex required in the Region 2 racks of the Diablo Canyon spent fuel pools?
A.42 The Staff has no requirements for use of "Boraflex" or other neu-tron absorber in any spent fuel rack design. However, the Staff does have a requirement that the racks have a k-effective value l
1
. . ~ , . , _ . , _ _ . , - - _ , . _ ._ . _ _ .., ___ _ ,,__ ,...__ . ,___,_. - , _ _ _ _ . . . , _ . , . _ _ _ . _ _ . _ , _ , _ _ _ . . , , _ , . . - . , - , , _ .
less than or equal to 0.95. Since the Diablo Canyon Regioq 2 racks wTthout Boraflex meet this criterion when loaded with fuel meeting the burnup requirement of the proposed Technical Specification (Figurc 3.9-2), the Staff found the criticality design of these racks to be acceptabic. (Finding 16)
Sierra Club Contentions II(A) 5 and II(B) 5 provide:
It is the contention of the Sierra Club that the proposed rcracking is inconsistent with the protection of the pub-lic health and safety, and the environment, for reasons which include the following:
A) during - the PHE, collisions between the racks and the pool walls are ' expected to occur resulting in:
- 5) increase in the nuclear criticality coefficient, k(eff) above 0.95 B) during the PHE, 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.
Q.43 Dr. Brooks, what does the Staff assume regarding the integrity of spent fuel racks in conducting its review of criticality during the PHE?
A.43 The Staff assumes that by adherence to the provisions of GDC's 61 and 62 as evidenced by licensee's commitments regarding the design and construction of the racks reflected in the Reracking Report the integrity of the spent fuel rocks is assured during the PHE.
Q.44 What is meant by the integrity of the spent fuel racks?
A.44 Integrity in this context means that deformation of the racks is limited to transient oscillation with insignificant permanent
deformation. That is, . the edge to edge spacing between the sforage cells ("the water gap" 1#) of each of the racks is not permanently reduced by the PHE. The fuel assemblies remain intact and at most, may alter their positions inside the storage cells.
Q.45 Under these conditions, what is the effect of the PHE on the k-effective value for the proposed racks for both Region 1 and Region 2 of the Diablo Canyon spent fuel pool for Units 1 and 27 A.45 If credit is taken for the dissolved boron in the spent fuel pool water the k-effective value remains well below the NRC acceptance criterion of 0.95.
Q.46 What is the safety significance of meeting the NRC acceptance crite-rion of 0.95 for the value of k-effective?
A.46 When k-effective is 1.0, the system is said to be critical (the sys-tem maintains a constant neutron population). If k-effective is greater than 1.0, the system is said to be supercritical and the neutron population increases with time at a rate dependent upon the kmount by which the k-effective is greater than 1.0. If k-effective ,
is less than 1.0, the system is said to be subcritical and the neu-tron population decesses at a rate which depends upon the amount by which the k-effective is less than 1.0. To avert a criticality event all thr.t is required is that k-effective is less than 1.0. The 1/ The water gap for Region 1 racks is 1.79 inches and for Region 2 racks is 1.9 inches (Figures 4.2 and 4.3 of the Reracking Report).
.f
J NRC acceptance criterion of 0.95 provides a margin to assure that the system will remain suberitical.
Q.47 Have you considered the aspects of criticality with regard to rack-to-rack or rack-to-wall impact resulting from a PHE reducing the gsp between the cans of adjoining racks?
A.47 Yes. Both the Region 1 and Region 2 racks for Diablo Canyon are, provided with a bottom plate and upper girdle bar which prevent reduction of water gap thickness between storage cells of adjoining racks to less than 1.75 inches (Reracking Report page 4-25). Ac-cordingly, if there is an impact of adjoining racks due to the PHE the plate and bar of the racks would limit lateral movement and preclude reduction of the water gap thickness between the storage a0 cells of adjoining racks to 1.75 inches. At this spacing the k-effective value of the racks has been computed to be less than 0.95 without taking credit for boron in the pool water.
Q.48 Have you considered the consequences of large distortions of the racks beyond the bounds of the required safety analysis?
A.48 Because of adherence to the provisions of the GDC's 61 and 62 and those commitments reflected in the Reracking Report, large distor-tions of the racks are not expected to occur. Therefore, no such
! evaluation by the Staff has been performed for the Diablo Canyon racks. If, however, the postulation is made that such distortions occur some comments may be made concerning possible l consequences:
l i
l l
l t
~
. l l
- 1. Generic studies of criticality in spent fuel racks have been ;
~
- performed. One such study has been published in the pro-ceedings' of the 4th National Conference, ASME, June 19-24, 1983 at Portland, Oregon. This study contains an algorithm by which the k-effective value of a multiplying system (i.e.,
spent fuel racks with fuel) as a function of fuel enrichment, water gap thickness (space between storage cans) and boron loading (fixed boron on the racks) may be obtained. This algorithm was used by me to examine the k-effective value for the Region 1 and Region 2 racks at Diablo Canyon. If one assumes that no boron is present in the pool water (which is not the case) the algorithm predicts that for both regions crit-icality (k-effective of 1.0) would occur at a water gap thick-ness of about 0.85 inches. The design water gap thickness for Region 1 racks is 1.79 inches and for Region 2 racks is 1.9 inches. (Figures 4.2 and 4.3 of the Reracking Report).
- 2. The algorithm was derived from a data base that did not in-clude a water gap thickness less than 0.78 inches. However, a curve of k-effective as a function of gap dimension may be drawn and extrapolated to zero gap thickness. This results in a k-effective value of about 1.2 for both types of racks at zero gap thickness. Again, this for the case assuming there is no boron present in the pool water.
- 3. The effect of dissolved boron on the reactivity (k-effective) of the rack may be obtained for Region 2 racks from the Licens-ee's Heracking Report page 4-G where it is reported that
I 1
. reduction of the bcron concentration by 800 parts per million (ppm) increases ~ the k-effective value by 0.1. The boron worth in the water is thus 0.01/60 ppm. A boron con-i centration of 2000 ppm (the concentration in the pool water at '
Diablo Canyon' Unit I and Unit 2 spent fuct pools) would therefore be expected to reduce the k-effective value by 0.25 relative to the value without boron in the water. Thus, Region 2 would be expected to remain subcritical (1.2 .25 =
.95 keff) even when the storage cells are in contact (a gap of zero) if the water is assumed to be borated to 2000 ppm.
- 4. No value for boron worth is given for the Region 1 racks. It would be expected to be smaller than that for Region 2 due to the presence of the fixed boron on the racks which reduces the impact of the poisoning effect of boron in the water gap.
If the boron worth is as low as 0.01/100 ppm (which is possi-ble), then these racks would be just critical at contact in the borated water. Thus, we cannot conclude that criticality would not occur in the racks if it is postulated that the racks are distorted to contact (a gap of zero). However, as the testimony of Mr. Fishman indicates, such distortion will not occur.
Q.49 Dr. Brooks, what is your conclusion regarding Sierra Club Contentions II(A) 5 and II(B)5?
A.49 It is my conclusion that during the PHE, collisions between the racks and the pool walls and collisions between groups of racks
with each other and/or with the pool walls will not result in an in-crease in nuclear criticality coefficient (k-effective) above 0.95, assuming that the integrity of the Diablo Canyon spent fuel racks is not violated. Moreover, it is my conclusion that even giving con-sideration to permanent deformation of the racks, which goes be-yond the bounds of the required NRC safety analysis for criticality, criticality would not occur in the Diablo Canyon spent fuel pools in Region 2 even if the cells of the racks were distorted to the point of contacting each other. Only if the cells of the racks in Region 1 were distorted to the point of contacting each other is criticality a possibility at the Diablo Canyon spent fuel pools.
Q.50 Mr. Fishman, what is your opinion regarding whether or not the cells of the racks in either pool could be distorted to the point of contacting each other as a result of the PHE7 A.50 As I explained in my testimony above, there will not be any signifi-cant permanent deformation of any portion of the racks resulting from the PHE. Accordingly, there would not be any contacting of the cells of the Diablo Canyon spent fuel racks. (Findings 17-18) l I
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[- l HANSRAJ G. ASHAR -
- DIVISION OF ENGINEERING AND SYSTEMS TECHNOLOGY
, OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS My name is Hansraj G. (Hans) Ashar. I am a Structural Engineer in the Structural and Geosciences Branch of the Division of Engineering and Systems Technology, U.S. Nuclear Regulatory Commission. In my present position, I am responsible for the review of the adequacy of Seismic Category I structures.
I hold a Bachelor's Degree in Civil Engineering from the Gujarat University, India, and a Masters Degree in Civil-Structural Engineering from the University of Michigan. Prior to joint NRC (then the AEC) in 1974, I had sixteen years of experience (beyond graduate school) in design and construction of bridges, industrial buildings and nuclear power plant structures. During that period I had worked with several companies in the U.S., Canada and in West Germany. I joined the AEC in the Office of Standards Development, later merged with the Office of Nuclear Regulatory Research and stayed there until August 1986. During that period , I had developed several regulatory guides related to the design , construction and inservice inspection of nuclear power plant structures and managed the research related to the integrity of containments.
I am a fellow member of the American Concrete Institute and the l
American Society of Civil Engineers. I am a professional engineer in the State of Ohio and in the State of Maryland. I am an NRC representative on the following National Standards Committees: (1) ACI 349 Committee ,
i on Nuclear Concrete Structures (2) American Institute of Steel l
l i
. Construction Committee on Nuclear Specification; (3) American Society of Mechr$1 cal Engineers ( ASMI:) ,Section IX - Working Group on Inservice Inspection of Concrete Containments.
Papers Published:
- 1. H. Ashar and D. Naus, " Overview of the Use of Prestressed Concrete in U.S. Nuclear Power Plants" Nuclear Engineering and Design , North-Holland Publishing Co. Special Issue on SMIRT-7, August 1983.
- 2. J. Dougan, H. Ashar, " Review of Inservice Inspection of Greased Tendons in Prestressed Concrete Containments", Proceedings of Structural Mechanics in Reactor Technology-7, August 1983.
i \
/
Finite Element Methodology
- Structural Mechanics and M. ', ~
Dynamics
>/ Applied Mathematics d'
Heat Transfer
,5. ,
.',, Software Development
- t ;- . . Fluid Dynamics
'f't.
HOffARD MARTIN FISHMAN w
- I^ I' PROFESSIONAL EXPERIENCE a
Mr. Fishman, a Head of the ' Structural Engineering Section of the a ;3-Engineering' Department, jcined Franklin Research Center in 1964. He has been primarily involved in the development of the digital computer ,
programs used at FRC for the solutions of complex thermal-mechanical systems. As former head of the Computer-Aided Design Section at FRC, i
\' he has developed software for an interactive graphic modeling and display 4 of mechanical systeme. Mr. Fishman has performederes rch and provided consultation on projects requiring static, seismic, dynamic, inelastic, and thermal analysis and code evaluation for a variety of, structural systems.
These systems include, nuclear containment buildings, heat exchangers and pressure vessels , piping, valves , and supports, in addition, Mr.
. Fishman has analy::ed and developed software for cartridges and ballistic l
missiles; submarine hulls; centrifuges and motion simulators; mills, kilns, and other mining equipment; ball, roller, journal, and foil bearings;
- chemical processing machinery; and turbine rotors, hubs, blades, and l
l pedestals.
l Prior to joining 'FRC, ._Mr. Fishman performed research in the theoretical and experimental analysis of hearing dynamics and deformation, and taught mechanics of materials. He is involved in Drexel University's l
i
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e r-+vr r -=r , or-re--e*,m
Continuing Education Program, presenting seminars in finite ' element technicques,and computerized structural and piping analyses.
ACADEMIC BACKGROUND Engineering Mechanics Program, University of Pennsylvania All Ph.D. requirements except disscrtation satisfied M.S. , Mechanical Engineering Massachusetts Institute of Technology,1960 B.S. , Mechanical Engineering University of Pennsylvania,1959 PROFESSIONAL AFFILIATIONS American Society of Mechanical Engineers Member, Subgroup on Deisgn Analysis, ASME Eoiler and Pressure Vessel Committee Chairman, Working Group on Shells, ASME-B&PVC American Institute of Aeronautics and Astronautics, Member of Interactive Computer Graphics Technical Committee i PUBLICATIONS AND REPORTS
- 1. "An Experimental Determination of the Effect of Vapor Velocity on Condensation on the Outside of Horizontal Tubes ," Thesis , MIT, June 1960
- 2. " Kinematics of Four-Ball Apparatus with Generalized Configuration,"
SKF Report AL62T014,1962.
- 3. " Influence of Lubrication on Endurance of Rolling Contacts," SKF Progress Report #4, AL62TO15, September 1962.
- 4. "Effect of Contact Deflections in the Zero Spin-to-Roll Ratio Four-Ball Arrangement," SKF Report AK62TOl6,1962.
- 5. " Development of Analytical Method for Predicting Deflections at Specified Locations for a 1/2 Scale Model of SS(N)637 Engine Room Subject to External Hydrostatic Pressure," FIRL Report F-D 2314, 1966.
i
. 6. " Preliminary Design of Centering Pin Shock Band," FIRL Report I-4 2009-01, 1967.
- 7. " Userss Manual for the CRTPLS Computer Program," FIRL Report F-C1865-05, September 9,1970.
- 8. " User's Manual for the AXPLAS Computer Program," FIRL Report F-C2763-01-1.
- 9. "GENSIIS , Layered Static Shell Program, Program User's Guide ,"
FIRL Report,1970. ,
- 10. "PIPDYN, User's Manual for Three-Dimensional Piping Systems Analysis," FIRL Report PD-C2689-2,1970.
- 11. "LUMS, User's Manual for the Dynamic Response of Lumped Mass Systems Program," FIRL Report,1970.
- 12. " Automated Cartiidge Case Design and Thermal Analysis ," FIRL Report F-C2695,1971.
- 13. "A Three-Dimensional Finite-Element Computer Code for the Analysis of Complex Structures," NED, Vol. 20,1, June 1972, Co-author with Z. Zudans, M.M. Reddi, and D. Gray.
- 14. "Three-Dimensional Finite-Element Stress Analysis of the ATR Reflector Block," FIRL Report F-C3355-01,1972.
- 15. "B OXPLT Program for Plotting DOXSHL Results , Program User's Guide," F)'!L Report,1972.
- 16. "HYBOS, User's Manual," FIRL Report,1972.
- 17. "FELAP, Finite Element Computer Program, Input Description and User's Guide," FIRL Report,1972.
- 18. " Review and Analysis of an S5G Bundle Type Pressurizer," FIRL Report 31G-C2962-09,1972.
- 19. " Theory and Users Manual for EPACA -
General Purpose Elastic-Plastic-Creep Finite Element Analysis Program for Three-Dimensional Thick Shell Structures," Final Report F-C3038, June 30,1972.
- 20. " Elastic-Plastic-Creep-Analysis of High Temperature Nuclear Reactor Components," Co-author with Z. Zudans, M.M. Reddi, T.Y. Chow, and H.C. Tsai. Presented at 2nd International Conference on Structural Mechanics in Reactor Technology,1973, Berlin.
- 21. "DOXSHL, Layered Static Box Shell Program, Program User's Guide," FIRL Report,1973.
- - 22. "PIPDYN II, A Computer Program for the Complete Analysis and Ev.aluation of Piping - Systems and Three-Dimensional Frame Structures," Three Volumes, FIRL,1973
- 23. " Comprehensive Design Review of the Page Engineering Co. Model 757-374 Walking Dragline," Report F-C4000, May 1975.
- 24. " Elastic-Plastic, Finite Element Analysis of Elbows," Report F-C2570,
- 25. " Preliminary Stress Analysis of a Pipe Joint," FIRL Report F-C4318, November 1975.
- 26. " Structural Analysis of PDX Vacuum Vessel," Final Report F-C4385, May 1977.
- 27. " Thermal and Structural Analysis of 2-1/2 inch 'Y' Globe Valves for Fuel Rod Test Facility ," FIRL Final Report F-C4533, April 1977.
- 28. " Seismic Withstand Capability of Allis-Chalmers AC Induction Motor,"
FIRL Report C4845, March 1978.
- 20. " Seismic Qualification Analysis of Yarway Valves ," FIRL Report F-C4878, May 1978.
- 30. " Analysis of Nordberg Grinding Mills," FIRL Report F-C4904.
oc
- 31. " Dynamic Stress Analysis of A Reactor Vessel Closure Subjected to Pressure Transient," FRC Report 021-C5135-01, August 1979.
1 32. " Structural Analuysis of the Samarco Mill," FIRL , Inc. Report F-A5208, September 1979.
- 33. " Analysis of Line 13 4 32 Propellers," FIRL, Inc. Report F-A5208, September 1979.
- 34. " Evaluation of Aerofall and Koppers Designs of Wet Semi-autogenous Grinding Mills with Gearless Drive and Associated Equipment," FRC Report 021-A5226-01.
. 35. " Turbine Shafting Failure Analysis at Webbers Falls," FRC Report F-C5376-01 to Corps of Engineers, February 1981
- 36. " Structural Experience with Operating Reactors , A Designe* Analysts' View ," Sixth International Conference on structural Mechanics in Reactor Technology (SMIRT-6), Paris, France, August 17-21, 1981. Presented at special session,
" Operating Reactor Structural Experience." Co-authored with Z.
Zudans and G.P. Wachtell.
- 37. " Computer Simulation of Dynamic Response in Railroad Impact Test,"
Proceedings of 13th Annual Pittsburgh Modeling and Simulation Conference, April 1982. Co-authored with B.J. Sullivan, i
r
- 38. " Response Spectra and Response Spectrum Envelopes for the Salem Nuclear Generating Station ," FIRL Inc. Technical Report 402-253,0-002-9, September 7,1982.
. 39. "RESCENV - Response Spectra Curve Envelop Computer Program,"
User's Guide, FRC Technical Report 402-2530-001-10.
- 40. " Resonant Frequency Analysis for Extended Structures," Proceedings of First International Modal ' Analysis Conference, November 1982.
- 41. " Perceived Margins of Safety in Nuclear Power Plant Structures under Evolving Design Codes and Loading Criteria," Eighth International Conference on Structural Mechanics in Ractor Technology (SMIRT), Brussels , Belgium, August 20, 1985.
Co-authored with T.C. Stilwell, M. Darwish, and D. Persinki.
- 42. " Critical Design Review ot' the Model WL-50 Ducket Whell Reducing,"
FRC Technical Report F6085, October 1985, co-authored with J.E.
Sague.
- 43. "A Structural Model emonstrating Incineration Hearths Remain in Place After Many Thermal Cycles," FRC Technical Report 6059-033, January 14, 1986, co-authored with T.C. Stilwell.
- 44. " Failure Analysis of the HAB Launcher Telescopic Hydraulic Cyclinders, FRC Technical Report ," F-6144-1, April 4, 1986, co-authored with A. A. Okaily and E. Mucha.
- 45. "The Anbalysis and Design of High Performance Motion Dampers," to be presented at the ASME 1986 Winter Annual Meeting ASME Journal of Dynamic Systems, Measurement and Control, co-authored with D.J. Barrett, E. Mucha, R.C. Chow, and B.J. Sullivan.
PATENTS U.S. Patent No. 4,446,716 issued May 8, 1984, "Self Compensating Centrifuge Arm."
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b PROFESSIONAL QUALIFICATIONS GIULIANO DEGRASSI BROOKHAVEN NATIONAL LABORATORY I am currently employed by Brookhaven National Laboratory as a Research Engineer in the Structural Analysis Division of the Department of Nuclear Energy. I have held this position since February 1,1986. My primary responsibility is to provide technical assistance to the NRC staff in the review and evaluation of Licensfag submittals related to structural issues . I have been the Prinefpal BNL Structural Reviewer on the Comanche Peak Train C Conduit, HVAC support, and Seismic II/I Reevaluation Programs, the Sequoyah Cable Tray and Small Bore Piping Reevaluation Programs, the Byron High Density Fuel Rack Licensing Review, and the Point Beach Energy Absorber Piping Supports Licensing Review. In this capacity I have participated in NRC
- audits, performed confirmatory analyses and prepared technical evaluation reports.
Prior to joining ENL, I was employed by.Impell Corporation (formerly EDS Nuclear) a major consulting firm to the Nuclear Power Industry. During my seven years with Impell, I held a number of positions including Supervising Engineering Mechanics section. I worked as a technical consultant to Electric Utilities on a wide variety of projects involving ;
evaluation of Nuclear Plant structures, equipment and piping systems to design basis normal and accident load conditions. Major assignments included the development of static and dynamic finite element models of 4
building structures at Nine Mile Point Unit 1, development of seismic I
. resporise spectra for Control Room panel-mounted equipment at D.C. Cook, development, of seismic qualification rules for installation of electrical conduit and instrumentation tubing at D.C. Cook, independent review of the seismic equipment qualification program for Shoreham, evaluation of the consequences of high energy piping line breaks at Palisades, and reevaluation of plant structures to current NRC tornado wind and missile requirements at Millstone Unit 1.
My responsibilities included the development of technical procedurert.
preparation or review of design calculations, and preparation of technical reports.
Prior to joining Impell, I was employed by Combustion Engineering, Power Systems Division, for nine years. I held a number of positions including Senior Engineer in the Reactor Structural Analysis Group. In that position, I was primarily responsible for performing dynamic nonlinear finite element analyses of Reactor Internals subjected to accident load conditions including seismic and LOCA. I also held positions in the Fuel l design Group and in the Mechanical Design Development Group where I was involved with the structural design and seismic testing of nuclear fuel assemblies.
I hold a Bachelor of Engineering degree in Mechanical Engineering from the City College of New York and a Master of Science degree in Mechanical Engineering from Rensselaer Polytechnic Institute. I am a Registered Professional Engineer in the States of New York and Connecticut, and a member of the American Society of Mechanical Engineers.
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l WALTER L. BROOKS ,s
,. OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS My name is Walter L. Brooks. I am employed as a Nuclear Engineer in the Reactor Systems B ranch , Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation (NRR). In my position
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I have . primary review responsibility for the core physics aspects of applications for construction permits and operating licenses. In addition I 1
review the criticality aspects of fuel storage racks at the request of the branch having primary review responsibility. In the area of operating i
. rccctor licensing actions I have primary ' responsibility for the review of core physics and spent fuel pool criticality aspects. I have held this I .
positior for six months. I held a -similar position for six years in the previous NRR organization.
I hold a bachelors degree in mathematics from Lincoln Memorial University and masters degree and doctorate in Physics from New York University. Prior to joining NRC (then the Atomic Energy Commission) in
. 1974, I had a total of 21 years of experience beyond graduate school -
almost entirely in the nuclear field. All of my employment was with the Gulf United Corporation , Nuclear Development Corporation of America, and Nuclear Development Associates. Among my duties during my employment from 1953 to 1974 were performance and evaluation of critical experiments for light water moderated, heavy water moderated, and fast (liquid metal moderated) reactors, development of calculation methods for heavy water moderated reactors and verification and modification of a modal calculation technique for light water moderated reactors.
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AMARJIT SINGH INSPECTION, LICENSING AND RESEARCII INTEGRATION BRANCH PROGTLAM MANAGEMENT, POLICY DEVELOPMENT AND ANALYSIS STAFF OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS I am employed as a Reactor Operations Engineer in the Inspection, Licensing and Research Integration Branch (ILBR), Program Management, Policy Development and Analysis Staff, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission, Washington, D. C.
From August 1981 to the present , I have been employed by the United States Nuclear' Regulatory Commission. I have been in the Plant Systems Branch, Division of PWR Licensing - A until April 12,1987 when NRR was reorganized. I am now assigned to the ILRB , Program Management. Policy Development and Analysis Staff. My duties include developing and evaluating the integration of inspection and licensing programs for power reactors.
Prior to the reorganization my duties consisted of reviewing and ,
evaluating the associated safety considerations of nuclear power and fuel l handling systems. I was responsible for providing technical input to various documents including Safety Evaluation Reports. I was the lead l
engineer for the generic issue A-36, " Control of Heavy Loads." As j required, I prepared safety evaluations and made presentations to the Advisory Commission on Reactor Safeguards. I have reviewed applications for operating licenses, proposed Technical Specifications, and spent fuel expansions. To date , I have reviewed the design of the spent fuel Etorage facilities for seven reactor sites.
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My experience includes ten years with the Department of Energy; Naval ' Facilities - Engineering Command; Chesapeake Division; and Department of Environmental Services as Environmental Engineer engaged in diversiSed engineering work including: fossil power plants, facility surveys, engineering studies , contract administration, project engi-neering, water and waste water treatment plants.
I received a Bachelor of Science Degree in Nuclear Engineering from the Catholic University of America, Washington, D. C. in 1976. Since 1976, I have taken courses of PWR and BWR Technology. I have completed 15 credits in Master of Science in Engineering degree program at the Catholic University of America. I am a registered Professional Engineer in the State of Wisconsin (No.19779) since 1980, ec
4 -
UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
. )
PACIFIC OAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA
)
. (Diablo Canyon Nuclear Power Plant ) (Spent Fuel Pool)
Units 1 and 2) )
NRC STAFF TEbTIMONY OF DONALD P. CLEARY ON SIERRA CLUB CONTENTION I(B)7
+
Q.1 Mr. Cleary, please state your name, position and affiliation.
A.1 My name is Donald P. Cleary. I am a Senior Task Manager in the Re6ctor and Plant Safety Issues Branch, Division of Reactor and Plant Systems, Office of Nuclear Regulatory Research.
Q.2 IIave you prepared a statement of your professional qualifications?
A.2 Yes. A statement of my professional qualifications is attached to this testimony.
Q.3 What is the purpose of your testimony?
A.3 The purpose of this testimony is to address Sierra Club Contention I(B)7 which state:
Sierra Club Contention I(B)7 It is the contention of the Sierra Club that the Reports fail to include consideration of certain relevant condi-tions, phenomena and alternatives necessary for indepen-
- dent verification of claims made in the Reports regarding
- l. consistency of the proposed reracking with public health and safety, and the environment, and with federal law.
I
. In particular, the. Reports fail to consider:
- 7) alternative on-site storage facilities including:
(i) construction of new or additional storage facilities and/ ors (ii) acquisition of modular or mobile spent nu-clear fuel storage equipment, including spent nuclear fuel storage casks; Q.4 Mr. Cleary, have you reviewed the proposal of Pacific Gas and Elec-tric Company to expand the fuel pool for Unit 1 and for Unit 2 of the Diablo Canyon Nuclear Power Plant?
A ~. 4 Yes, I have reviewed that proposal with regard to alternatives to the proposal as required by the National Environmental Policy Act.
Q.5 In this review have you considered the alternatives to the proposed reracking of the Diablo Canyon spent fuel pools asserted in Sierra Club Contention I(B)7?
A.5 Yes. I have considered the alternatives to the proposed reracking of the Diablo Canyon spent fuel pool asserted in this contention.
f-Q.6 What is your conclusion with regard to the merits of the proposed reracking of the spent fuel pool relative to the asserted alternatives?
A.6 I have concluded that the proposed reracking at Diablo Canyon has both an environmental and financial advantage over the asserted al-ternatives of wet or dry, independent on-site spent fuel storage facilities. The proposed reracking will have no significant environ-mental impacts whereas the asserted alternatives will have specific, although not significant, environmental impacts. The proposed 1
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reracking also has clear financial advantages over thei hsserted alternatives. (Findings 19-20).
Q.7 How do you reach the conclusion that the proposed reracking has an environmental advantage' over the asserted alternative of wet inde-pendent on-site spent fuel storage facilities?
A.7 I have compared the licensee's proposed reracking of the existing ,
pools and the asserted independent wet storage alternative for po-tentini environmental impacts. These impacts are categorized in terms of. construction and operation, radiological and non-radiological, land use, terrestrial, aquatic, aesthetic, and physi-cal disruption of offsite human activities.
The proposed reracking will have no significant non-radiological en-vironmental impacts. Reracking will take place within the confines of the fuel pool buildings, thereby, presenting no source of non-radiological environmental impacts to the Diablo Canyon sitt and environs. There will be no significant radiological environmental impacts attributable to the proposed reracking modification. The potential for accidents having offsite consequences and the potential for radioactively contaminated wastes generated from reracking hav-ing offsite consequencer is small. Potential reracking accidents are bounded by the fuel handling accident which would have no signifi-cant environmental consequences. Radioactiveley contaminated waste generated from wet reracking will be disposed of in accordance with i 10 C.F.R. Part 71 " Packaging and Transportation of Radioactive
Material" and .10 C.F.R. Part 61 " Licensing Requirements for Land Disposal of Radioactive Waste" and therefore will have no significant impact on the environment. Operating impacts of the rerscked fuel pools on the environment were considered in the Environmental As-sessment (Staff Exhibit No.1), Section 3 for radiological impacts and Section 4 for non-radiological impacts. The primary environmental pathway associated with storage of spent fuel assemblies is Kr-85 plume shine. Incremental doses to the general public were estimated to be very small relative to doses incurred during normal operation and to natural background radiation exposure. The only source of potential non-radiological impacts is an insignificant increase (less than 0.1%) in waste heut discharged to the Pacific Ocean. No impact on aquatic biota is anticipated. (Finding 21).
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Construction of ~ either a wet or dry independent on-site spent fuel storage facility would produce environmental impacts which would not be produced by the proposed reracking. Additional land would be l used for structures and supporting utilities. A separate new spent fuel pool building with the storage capacity of the two present fuel l
pools would likely disrupt at least one acre of land plus the land required for an access roed, v:ater pipes and electric lines. If dense storage of spent fuel is not allowed there would be a require-l ment for a number of additional on-site pools over the next fifteen years. Other potential impacts of construction include errosion, dust, an increased level of traffic on local roads, noise and a de-crease in the aesthetic quality of the site. In addition, further
development of the Diablo Canyon site may be complicated by the presenee of numerous Indian burial sites in the area and the re-quirements of the National Historic Preservation Act of 1966, as well as obtaining approval of development plans by the California Coastal Commission.
The incremental environmental impacts due to operating independent on-site spent fuel pools would be greater than operating the reracked existing pools. A larger workforce would be required to operate and maintain additional facilities and to handle and move spent fuel from the original pools to the new pools. Additional pip-ing to remove waste heat would likely increase the use of chemicals to control biofouling. (Finding 22).
en Q.8 How do you reach the conclusion that the proposed reracking has an environmental advantage over the asserted alternative of dry inde-pendent on-site fuel storage facilities?
A.8 1 have used the same approach in comparing relative environmental impacts of reracking and the dry storage alternative as I used in the case of the wet storage alternative. The environmental impacts of dry storage would be less than for the new spent fuel pools but would still be greater than the proposed reracking. There are basically three -technologies which could be used for dry storage.
These are: metal storage casks, drywells (below grade), and concrete modules above grade. Pursuant to the National Waste Policy
, Act the United States Department of Energy has entered into
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cooperative agreements with Virginia Electric and Power Company to l
' demonstrate dry cask spent fuel storage technology and with Carolina Power and Light Company to demonstrate that dry cask spent fuel storage and storage in a concrete horizontal module (which receives a steel dry-shielded canister holding the fuel e assemblies) are viable storage options licensable by the NRC. The Department of Energy is considering below grade drywells for a potential federcl interim storage facility, but it is problematic that such a facility will be constructed.
In the case of' dry cask and concrete horizontal storage modules, environmental assessments were performed for their use at the Surry Power Station and the H. B. Robinson Steam Electric Plant, respec-
. tively. Both assessments resulted in a Finding of No Significant Impect. - Because of the relative simple and passive operation of these technologies their environmental impacts at the Diablo Canyon site would be slight and would not differ much from those environ-mental impacts described for Surry and H. B. Robinson. The major differences in environmental impacts would be associated with the differing topographic characteristics of the sites and their implica-tions for construction. It is likely that a dry cask storage area at
. Diablo Canyon would require at least 15 acres as was required at Surry. Additional relatively level land is limited at Diablo Canyon thus increasing the amount of excavation and complicating design and construction. Because of the additional commitment of land required with no offsetting benefits, these alternatives are considered less
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desirable than the proposed reracking of the existing pools.
(Finding 23).
Q.9 What financial advr.ntages do you see for the proposed reracking over the asserted alternatives?
A.9 Pacific Gas and Electric Company estimates that the reracking effort will cost $13 mil!1on per unit. Because the new racks have already been purchased and are c sunk cost, the incremental cost from this time forward is something less than $13 million per unit. In the absence of detailed engineering design and firm commercial commit-ments there is considerable uncertainty as to the likely cost of the asserted alternatives. Available information, however, does indicate that the asserted alternatives would be significantly more expensive than the proposed wet reracking.
4 Costs associated with reracking relative to new storage were ex-plored in an IAEA Advisory Group / Specialist Meeting, November 17-21, 1980, and reported in DOE-SR-0009, " Spent Fuel Storage Alternatives." Capitol costs for reracking a single pool were in the range of $5/kg to $15/kg, in 1980 dollars. Pacific Gas and j Electric Company's estimate of $13 million to rerack each pool repre-sents about $21/kg in 1987 dollars. Adjusting fsr escalation, this is j consistent with the 1980 estimate for reracking.
Capital cost reported in the 1980 IAEA Advisory Group / Specialist Meeting for new fuel pools for a two reactor unit was $52/kg. A
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more current but incomplete estimate of capital cost for a new pool is from the Energy Economic Data Base Program maintained by United Engineers and Constructors, Inc. for the U.S. Department of Energy. The median cost of constructing a fuel storage building in conjunction with construction of a 1139 MWe pressurized water reac-tor was $12.8 million in 1986 dollars. Construction of an indepen-dent fuel pool building would involve additional direct costs not included in the $12.8 million. These additional direct cost are for site preparation and excavation, and for separate ventilation, heat-ing, and water supply systems. There are also indirect costs which should also be included. These indirect costs are engineering and services associated with design and construction management. These would bring the 1987 capital cost to well over $13 million per pool projected for Diablo Canyon. If high density racks were not allowed in the new pools at Diablo Canyon, the additional storage capacity would be exhauwted by the mid-1990's after approximately the fifth refueling. To provide total storage capacity for 1324 fuel assemblies in on-site fuel pools comparable to the licensee's current proposal would require a multiple of $13 million.
The capital cost of providing dry on-site storage for 1324 fuel as-semblies is greater than reracking the existing fuel pools. Dry storage is in the demonstration stage and no commercial cost baseline exists. The U.S. Department of Energy has, however, made esti-mates of the likely cost of constructing and operating three types of dry storage facilities: storage cask, drywell and concrete silo. The
e 9-range of capital costs for storage capacity of about 1000 fuel assem-blies is, around $50 million, in 1983 dollars, for these three methods.
The DOE estimates are reported in DOE /S-0023, " Federal Interim Storage Fee Study for Civilian Spent Nuclear Fuel: A Technical and Econornic Analysis," July 1983. (Findings 24-25).
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DONALD P. CLEARY PROFESSIONAL QUALIFICATIONS My 'name is Donald P. Cleary. I am a Senior Task Manager in the Reactor and Plant Safety Issues Branch, Division of ' Reactor and Plant Systems , Office of Nuclear Regulatory Research, United States Nuclear Regulatory Commission (NRC). My primary responsibility is to develop a j
( l policy and regulations for reviewing licenses for nuclear power plants at !
the end of their original 40 year license. Previously, I was a Senior Task Manager in the I:ngineering Issues Branch, Office of Nuclear Reactor Regulation. My major responsibilities were in the areas of
. radiological protection and environment, and regulatory alternatives for plant life extension. Prior to that, I ' was - Acting Chief of the Site Analysis Branch and Section Leader of the Regional Impact Analysis 4 Section within that Branch. I have been with the NRC (previously Atomic Energy - Commission ) since 1973. As a technical reviewer and
, supervisor I have been responsible for various sections of environmental
, impact statements and safety evaluation reports. These include social and economic impacts, need for the project, alternatives to the project, 4
frreversible and irretrievable commitments of resources, relationships between short-term use and large-term productivity of man's environment, l
benefit cost balance, population distribution, exclusion area authority and control, and analysis of potential hazards (to safe plant operation) in site t
vicinity.
Prior to joining NRC, I was first an Industry Economist and then Staff Specialist for Program Review and Evaluation in the Office of I
Resource Utilization, National Marine Fisheries Service, National Oceanic and Atmospheric Administration, U.S. Department of Commerce.
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I received a B.S. in Economics from the University of Massachusetts in 1961 and,a M. A. in Economics from the University of Florida in 1963.
I completed course work from the Ph.D in Natural Resource Economics at the University of Michigan.
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DRAFT ,
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UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PACIFIC GAS AND ELECTRIC ) Docket Mos. 50-275 OLA COMPANY- ) 50-323 OLA
)
(Diablo Canyon Nuclear Power Plant ) (Spent Fuel Pool)
Units 1 and 2) )
NRC STAFF'S PROPCSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF AN INITIAL DECISION RELATING TO THE LICENSEE'S AMENDMENT REQUEST TO EXPAND THE SPENT FUEL POOLS i AT THE DIABLO CANYON NUCLEAR POWER PLANT I. SCOPE OF DECISION This Initial Decision addresses the contentions proposed by the Santa
! Lucia Chapter of the Sierra Club (Sierra Club) in connection - with the Pacific Gas and Electric Company's (Licensee) request for an amendment to perform a reracking of the Diablo Canyon spent fuel pools in order to increase their capacity. The Sierra Club alleged that the Licensee in its report submitted to the NRC entitled "Reracking of Spent Fuel Pools, Diablo Canyon Units 1 and 2" and in other public communications failed to l contain data .regarding the expected velocity and displacement during the postulated Hosgri earthquake (PHE) and thus significantly underestimated
- the impact forces on the spent fuel pools and the proposed racks therein.
The Sierra Club alleged that in fact, during t. PHE, collisions between the racks, groups of racks and pool walls are expected to occur causing the release of large quantities of heat and radiation resulting in the
DRAFT radioactive contamination of the nuclear plant, the environment., human and otEer living things in the vicinity thereof. In other contentions, the Sierra Club asserted that the Licensee's Reports fail to consider alternatives for new or additional on-site storage facilities or the acquisition of modular or mobile spent nuclear fuel storage equipment including spent nuclear fuel storage casks in place of the proposed reracking.
The. Board has reviewed the record compiled at the hearing on all of the Sierra Club's admitted contentions. On the basis of all of the evidence presented, the Board finds that Licensee's Report, the Staff's review thereof as set forth in its SER and related testimony accurately portray the events that may take place during the PHE and further, that no large releases of heat and/or radiation is expected to occur as alleged.
In addition, the Board finds that the Staff has reviewed the Licensee's amendment request with regard to alternatives as required by the National
- . Environmental Policy Act. The Board concludes that, with respect to those matters in controversy, it has been demonstrated that the proposed amendment complies with all applicable regulatory requirements, t
II. BACKGROUND On October 30, 1985, the Licensee requested amendments authorizing it to increase the spent fuel pool storage capacity from 270 to 1324 shrage locations for each unit, by reracking the spent fuel pools with a combination of high-density, free-standing poisoned racks and nonpoisoned racks in a two-region arrangement. On January 13,1986 the Commission published in the Federal Register its notice of " Consideration
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DRAFT of Issuance of Amendments to Facility Operating Licenses DPR-80 and DPR-82 for Diablo Canyon Power Plant, Units 1 and 2, Respectively, and Proposed No Significant Iluzards Consideration Determination and l
Opportunity for Hearing. "
51 Fed. Reg. 1451. In this notice the Commission made the following determination:
On the basis of the foregoing discussion of the elements of 10 C.F.R. 50.92 and because the proposed reracking technology has been well developed and demonstrated, the Commission proposed to determine that operation of the facility in accordance with the proposed amendment does no involve a significant hezards consideration. Id. at 1455.
In response to the above Commission notice , separate comments, requests for a hearing and petitions for leave to intervene were filed by the Sierra Club, Mothers for Peace and the Consumers Organized for Defense of Environmental Safety (CODES). An Atomic Safety and t
Licensing Board was established on February 21, 1986 to hear argument end to consider the petitions for leave to intervene.
In a Memorandum and Order issued on March 28, 1986, the Licensing Board admitted the Mothers for Peace as a party to the proceeding subject to the subsequent submission and acceptance of at least one contention. The Board therein initially denied the petitions filed by the Sierra Club and CODES subject to reconsideration upon the filing of amended petitions and the submission and acceptance of at least one contention. Thereafter, timely amended petitions were filed by the Sierra Club and CODES including proposed contentions; proposed contentions were also timely filed by the Mothers for Peace.
On May 13,1986, a prehearing conference was held in Avila Beach, California to consider the respective petitions and proposed contentions.
DRAFT I
On June 27, 1986, -
the Board issued a Memorandum and Order, LD P-86-21, 23 NRC 849 (1986), admitting both the Sierra Club and CODES as parties to the proceeding and ruling on contentions; at least
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1/ In accordance with 10 C.F.R. I 50.91, the Commission, on May 30, 1986, approved the proposed amendments on the basis of its Safety Evaluation and made them immediately effective, prior to any hearing on the proposed amendments, having made a final determination that i, the proposed action involved no significant hazards consideration. .
51 Fed. Reg. 20,725 (June 6, 7.986).
An Environmental Assessment supporting the license amendment, which found that the amendment entailed no significant environmental impacts, had also been issued i on May 21,1986, and notice thereof given in the Federal Register.
51 Fed. Reg.19,430 (May 29,1986). .
On June 16, 1986 the Intervenors Mothers for Peace and Sierra Club jointly filed an Application for a Stay of the Commission's May 30th action amending the license. Two days later, on June 18, both the Licensing Board and the Appeal Board dismissed the Intervenors' stay request. On June 19, the Commission denied Intervenors' request for expedited consideration of their stay application and set down a briefing schedule for responses. Also on June 19,1986, the ec Intervenors filed Emergency Motions and a Petition for Review before U.S. Court of Appeals for the Ninth Circuit. On July 2,1986 the Court, after - briefs and oral argument, granted a partial stay and ordered expedited consideration of the Intervenors' petition for review. On July 22. 1986, the Commission denied Intervenors' application for a stay except to the extent that it prohibited the Licensee from storing more than 270 spent fuel assemblies in either -
i of the spent fuel pools and subject to those restrictions previously
. imposed by the Court of Appeals. CLI-86-12, 24 NRC 1 (1986).
On September 11, 1986, the Court issued an Order that concluded:
l The NRC failed to comply with its own regulations in denying petitioners a hearing prior to making the Diablo Canyon reracking license amendments effective.
Accordingly, the . existing stay of those amendments is continued. PG&E shall not deposit any spent fuel rods in the pool for Unit 1 and shall not rerack the pool for i
Unit 2 until hearings have been held in compliance with the requirements of the Atomic Energy Act. 799 F.2d 1268 (9th Cir. 1986); dissent , 804 F.2d 523 (9th Cir.
1986).
(FOOTNOTE CONTINUED ON NEXT PAGE)
DRAFT one good contention was found to have been submitted by each-intervenor. ,
A complete Ifst of all contentions admitted by the Board is appended to that Memorandun, and Order as Appendix A.
On August 28, 1986, the Licensing Board issued a Memorandum and Order establishing a schedule for completing discovery and proceeding to hearing on the Licensee's spent fuel pool expansion request, setting alternate dates for the submission of prefiled testimony and commencement of the hearing to accommodate the possibility that a party might file one or more motions for summary disposition - if no motions for summary dispositen were filed by December 20, 1986, the hearing would commence on January 15, 1987 and if motions were filed, the hearing would begin on March 26, 1987. As a consequence of discovery disputes, .the schedule established in the August 28 Memorandum and Order was modified-by- the Board in a Memorandum and Order issued on December 1, 1986, to permit some additional discovery and to provide for the commencement of the hearing on February 2, 1987. 2,/
(FOOTNOTE CONTINUED FROM PREVIOUS PAGE)
. On September 16, 1986, Intervenors Sierra Club and Mothers for Peace jointly sought a further stay from the Commission.
See, Intervenors' Application for an Order Prohibiting Onsite Storage of Radioactive Spent Fuel at Unit 1, Diablo Canyon lr and for Public Hearings, dated September 16, 1986. The Commission directed that this request be treated as a petition for enforcement action pursuant to 10 C.F.R. I 2.206, to be resolved expeditiously by the Staff and declined to issue the i_ emergency stay sought. Order dated September 18, 1986 (unpublished) . This matter was appropriately resolved by i the Staff outside the hearing process, t
l 2/ On December 10, 1986, CODES filed a statement with the Board
! indicating that it would no longer participate 'in the proceeding.
I i
l l
I DRAFT i On December 15, Intervenors Mothers for Peace band the Sierra Club died a joint motion for summary disposition before the Licensing Board b alleging that, as a matter of law. .the license amendment sought ,
must be denlad because the Staff failed to file an environmental impact statement and because the amendment request failed to comply with the Commission's requirements, specifically the Standard Review Plan ,
NUREG-0800. Following the submission of answers by the Staff and the Licensee in accordance with the Board's January 2,1987 Memorandum and b the Licensing Board , in a Memorandum and Order dated Order, .'
-3/ Subsequently, on January 13, 1987 the Intervenor, Mothers for ( '
Peace filea a statement with the Board indicating that it would no longer participate the proceeding.
4
-4/ Also on December 15, 1966, Intervenors filed a Motion to Allow Filing of Summary Disposition Motion and for Reinstatement of Original Schedule, with the Atomic Safety and Licensing Appeal Board, premised on their interpretation of the Licensing Board's December 1 Memorandum and Order as foreclosing the opportunity to file a motion for summary disposition. Intervenors therein requested that they be permitted to file such motion and that the schedule originally established by the Board's August 28, 1986 Memorandum and Order be reinstated. 'In a Memorandum and Order issued on December 19 (unpublished), the Appeal Board denied Intervenors' Motion 4
- observing that there wes no reason to believe that the Licensing Board would reject their motion for summary disposition out of hand and until the Licensing Board had acted, their motion was premature.
f
~
5/ See, NRC Staff Answer in Opposition to Sierra Club / Mothers for Peice Motion for Summary Disposition, dated January 15, 1987, and, Answer of Pacific Gas and Electric Company in Opposition to Motion for Summary Disposition, dated January 14, 1987.
l
_ . _ _ _ . , _ ,_, _ . . _ . _ , . - . _ _ _ _ _ _ . _ . . . _ , _ _ _ _ _ . . ~ . _ . _ . _ _ . . _ _ . _ _ _ . . _ , , _ _ _
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DRAFT January 28, :1987, denied the motion for summary disposition pending e - '
f .. before it. 6/ -
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1 JJ In a telephone conference call ' with the Board and parties on ~
4j' 9\ '
.- ., j
- j. February 23, 1987, the Staff informed the Board that, as a consequence v -
of rehent developmerus reg'arding its evaluation of. multi-rack impacts -
(raised- initially by 1 Brookhaven National Laboratory. as' concer'ns in the 'I
, ^? '
context of the review of Commonwealth Edison Company's application to l-
,! g ,
4 h, rerack the Byron facility's spent fuel poolh it would be unable to file,its 7
4 j
y testimony on February 24, 1987 cs required and ~ would be' unable to
- s. .
4 present testimony on this matter at the hearing commencing ion March 9. . Y a
a The multi-rack impact issue (fydiscussed in more detail subsequently q . ;
the Findings of this Initial Decision. The Board agreed to delay the, start
- - t .
p
, 3 of the, hearing and to extend discovery so that the parties could co9 sider i o 3, v,
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these recent developments. Thereafter, following a conference' call among
.the Board and parties on April 8, the Licensing Board, in a Memorandum'1 ,-
4 , 4 ,
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- 1- anddor, der issued on April 9,l1987, c/ber(d discovery to'(erid #cn May 27, - >
v' % , a t and the hearing to start on guite 16, 1987. 7f - .c x
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-6/ In its Memorandum and Order the Licensing Board also accepted the
- j!i withdrawal of CODES and Mothers for Peace from the proceeding and l y dismissed their remaining contentions. The Boar'd' also granted the i j \' ' Dierra Club's January 13, 1987 motion , for continuance of the s o' ihearing, setting March 9, 1997 as .the new date . for its
- "3 if commencement. ,
y
@t 4
-7/ T he - Board also provided that ilmited appearance statements, f
.1
( yursuant to 10,C.F.R. I 2.715, would tie received on June 15,1987. '
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DRAFT A hearing on the Sierra Club's Club's contentions 8_/ was, held as ordered on June 16 _ , 1987 at Avila Beach, California.
III. FINDINGS OP FACT Introduction
- 1. To address the Sierra Club, Contentions 1(A)3, and 4; 1(B)2, 8 and 9; 11(A)1-9 and 11(B)1-9, the Staff presented the testimony of Hansraj G. Ashar, E a Structural Engineer in the Office of Nuclear
'deactor Regulation (NRR), NRC. Howard Martin Fishman, E Section Head, Structural Engineering Section, Engineering Department, Franklin
- csearch Center (FRC), Dr. Walter L. Brooks, a Nuclear Engineer in the Reactor Systems Branch, NRR, NRC, and Amarjit Singh, a Reactor Operations Engineer, Inspection, Licensing and Research Integration B ranch , Program Management, Policy Development and Analysis Staff, NRR, HEC. To address the limited area of multi-rack impacts, the Staff
-S/ Sierra Club Contentions I(A)1, I(A)2, I(A)5 and I(A)6, were voluntarily withdrawn by the Sierra Club by their Report to the Board dated August 15, 1986, and were not further considered in this proceeding.
-9/ The principal staff reviewer with regard to the structural aspects of Licensee's amendment request initially was Mr. Frank Rinaldi. Due to Mr. Rinaldi's hospitalization, Staff witness Ashar, who was assigned to replace Mr. Rinaldi, has reviewed the Staff's Safety .
Evaluation and has adopted the conclusions therein regarding the structural integrity of the high density racks during a Postulated Hoagri Earthquake.
10/ The principal author of FRC Report TER-C5506-625, Mr. R. Clyde
~~
. Herrick, is deceased. Staff witness, Mr. Fishman, who replaced Mr.
Herrick, has thoroughly reviewed the evaluations in the report and i concurs with its conclusions. Mr. Fishman is the principal author of 1 i the revisions to the FRC Report (Staff Exhibit 1-A).
I i
-.,,n - , - - y , - , . - . - . . . , , - -.
i l
DRAFT presented the testimony of Mr. Giuliano DeGrassi, a Research Engineer in the 5tructural Analysis Branch, Department on Nuclear Energy, Brookhaven National Laboratory. Messrs. Asher, Fishman, Brooks, Singh and DeGrassi Nore presented by the Staff as a single panel of witnesses, b To address the Sierra Club Contention I(B)7 concerning alternatives to the proposed amendment, the Staff presented the testimony of Donald P. Cleary, Senior Task Manager, Reactor and Plant Safety Issues Branch, Division of Reactor and Plant Systems, Office of Nuclear Regulatory Research.
The Staff's exhibits in this proceeding include:
The 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 As Related to Amendment No. 8 to Unit 1 Facility Operating License No. DPR-80 and Amendment .No. 6 to Unit 2 Facility Operating License No. DPR-82, Pacific
~ Gas and Electric Company Docket Nos. 50-275 and 50-323 (Staff Exhibit 1);
Evaluation of Spent Fuel Racks, Structural Analyses, Pacific Gas & Electric Company, Diablo Canyon Units 1 and 2, TER-C5500-625. Revised May 28, 1987 (Staff Exhibit 1-A);
Evaluation of the Structural Adequacy of the Diablo Canyon High Density Spent Fuel Racks in Accommodating Multiple Rack Impact During the Postulated Hosgri Earthquake, May 1987 (Staff Exhibit 1-B); and, The Environmental Assessment by the Office of Nuclear Reactor Regulation Relating to the Expansion of Spent Fuel Pools Facility Operating License Nos. DPR-80 and DPR-82 Pacific Gas and Electric Company, Diablo Canyon 11/ The direct prefiled testimony sponsored by this panel will be
~'-
referred to throughout these findings as "Fishman , et al. ff.
Tr. at .
l
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DRAFT Nuclear Power Plant, Unit Nos. I and 2, Docket Nos.
50-275 and 50-323 (Staff Exhibit 2).
- 2. Tl e FRC, as consultants to the Staff, prepared a technical evaluation report (TER) entitled, Evaluation of Spent Fuel Racks, Structural Analysis, Pacific Gas a Electric Company, Diablo Canyon Units 1 and 2.
This report, dated April 30, 1986, is identified as TER-C5506-625 and is Attechment A to the Staff's Safety Evaluation Report of May 30, 1986.
(Staff Exhibit 1). The purpose of the FRC Analysis and report was to determine the structural adequacy of the high density spent fuel racks and spent fuel pool as proposed by the Licensee in its report entitled Rcracking of Spent Fuel Fools Diablo Canyon Units 1 and 2, September 1985. In essence, the FRC Report supported the Licensee's amendment request for an expansion of the Diablo Canyon spent fuel pools. A e t.
revised TER was issued by FRC on May 28, 1987 to account for its further evaluation of the Licensee's multi-rack impact analyses. (Staff Exhibit 1-A). A TER was also prepared by Brookhaven National Laboratory to address this same matter. (Staff Exhibit 1-B).
- 3. The Staff's witnesses are highly qualified in their respective fields of endeavor and were of invaluable assistance in developing the record of this proceeding.
Contention I(a)3 Sierra Club Contention 1(A)3 provides:
It is the contention of the Sierra Club , Santa Lucia Chapter (Sierra Club), that the report submitted to the
DRAFT NRC entitled Reracking of Spent Fuel Pools, Diablo Canyon' Units 1 and 2 and other communications between Pacific Gas and Electric Company- (PGaE) and the NRC, wilich are available to the public on the same subject (the Reports), fail to . contain - certain relevant data necessary for independent verification of claims made in the Reports regarding consistency of the proposed reracking with the protection of the public health and safety, and the environment. In particular, the Reports fail to contain data 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 (PIIE) .
- 4. The velocity and displacement of the spent fuel pool is not used explicitly in the Licensee's reracking analysis because the dynamic input for the analysis only requires the spent fuel pool's floor acceleration time history. Earthquakes develop inertia forces on structures and these forces may be computed from the well known relationship of force equals mass times acceleration Fishman, et al., ff. Tr. at 5. Accordingly, since only pool acceleration is explicitly required for purposes of the
, Licensee's method of analysis which the Board finds acceptable, this contention is without merit.
Contention I(A)4 Sierra Club Contention I(A)4 provides:
It is the contention of the Sierra Club , Santa Lucia Chapter (Sierra Club), that the report submitted to the NRC entitled Reracking of Spent Fuel Pools, Diablo Canyon Units 1 and 2 and other communications between Pacific Gas and Electric Company (PG&E) and the NRC, which are available to the public on the same subject (the Reports) , fail to contain certain relevant data necessary for independent verification of claims made in the Reports regarding consistency of the proposed
DRAFT reracking with the protection of the public health and
_ safety, and the environment. In particular, the Reports fail to contain data regarding:
- 4) The expected maximum velocity and displacement of the racks. obtained from computer modeling of rack behavior during the PHE;
- 5. ' This contention by -the Sierra Club is not factually accurate because the Licensee's reracking report does contain references to maximum displacement. However, the report does not refer explicitly to maximum velocities. In the Licensee's computer analysis, instantaneous values of displacement and velocity are calculated for all degrees of freedom and for each integration time step during the period of mathematical representation of the PHE. These values are then used to compute design forces. Fishman , et al, ff. Tr. at 6. As noted earlier (Finding 4) velocity and displacement are directly related to acceleration and therefore the only dynamic input analysis necessary for the Licent,ee's Rerack Report is the spent fuel pools floor acceleration time history. Id. ; See also, Fishman et al. ff. Tr. at 5.
- 6. Intervenor Sierra Club's witness Dr. Richard B. Ferguson, had contended that the spent fuel pools could be expected to undergo i
displacements of up to 3 feet in the north-south direction and up to 8 feet in the east-west direction. On the basis of the evidence submitted, i
and for the reasons sent forth below , the Board finds that Dr. Ferguson's conclusions with regard to the displacement of the spent fuel pools are not valid.
For the purpose of structural analysis an earthquake, including the PIIE, is represented in two forms. The first form relates to response l
l DRAFT l i
spectra wherein acceleration is presented in terms of frequency and the second is 'where acceleration is presented as a function of time. For a postulated earthquake, such as the PHE, the response spectrum is usually prescribed from which an artificial time history may be mathematically derived. The artificial time history is developed as the superposition of sine waves with different amplitudes, frequencies and random phase-shifts. The vibratory characteristics of an earthquake which are simulated by these artificial time histories do not allow the development of large cumulative values of acceleration, velocity or displacement as these e
motion quantities tend to oscillate about zero. See, Fishman et al. ,
ff. Tr. at 7. '
t The artificial acceleration time histories for the PHE were computed by the Licensee using a modified version of the computer program SIMQKE. The primary purpose of SIMQKE is to simulate earthquake motions with artificial time histories that correspond to the applicable response spectra. For an appropriate earthquake simulation there is a branch of SIMQKE that performs a baseline correction on the i
i acceleration time history so that the corresponding velocity would tend to oscillate about zero, thus representing the vibratory characteristics of a
- real earthquake. Using the acceleration time histories provided by the i Licensee, Staff witness Mr. Fishman performed the baseline corrections in accordance with SIMQKE and developed acceleration velocity and displacement time histories. The Board agrees with Mr. Fishman's position concerning acceleration, velocity and displacement time histories f which he considered more appropriate. It is concluded therefore, that there is no significant difference between original and corrected
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DRAFT acceleration time histories and that displacement oscillates about, gero for the ba'seline corrected solution. Fishman et al. , ff. Tr. ; See, Figures 1, 2 and 3.
Using the figures attached to Mr. Fishman's testimony, it can be .seen that the final displacement from PHE would be - 4.83 inches in the east-west direction (Figure 3) as compared to Dr. Ferguson's un-corrected value of 79.98 inches; the maximum displacement found by Mr. Fishman would be 16.21 inches at 16.1 seconds. Based upon Mr. Fishman's calculations, this Board concludes that since the rates of change for both the baseline corrected and ncn-corrected displacements are nearly identical, the magnitude of the spent fuel pool displacement would not significantly alter the results of the nonlinear dynamic analysis for the racks performed by the Licensee. See, Fishman, et al. , ff. Tr.
et 7-9.
I Contention I(B)2 Sierra Club Contention I(B)2 provides:
It is the contention of the Sierra Club that the Reports fail to include consideration of certain relevant conditions , phenomena, and alternatives necessary for independent verification of claims made in the Reports regarding consistency of the proposed rcracking with the protection of the public health and safety, and the environment, and with federal law. In particular, the Reports fail to consider:
eee 1
- 2) the resonant behavior of the spent fuel assemblies in response to the PHE and the consequences of such behavior; 4
- 7. While it is true that the Licensee's Reracking Report does not consider resonant behavior of the spent fuel assemblies, the Board finds
~
DRAFT for the reasons set forth below, that the concept of resonance is not applicable to the Licensee's analysis of its spent fuel assemblies.
The concept of resonance in which large vibrations are induced by a small stimulus vibrating at a natural frequency is generally applicable to linear systems. The interaction between a spent fuel assembly and its cell walls as modeled by the Licensee with gaps, impact springs and hydro-dynamic coupling are all nonlinear. Further, in Section 6.2.1 of Licensee's rerack analysis the mechanism of "rettling" is discussed. The possibility of the interaction of a fuel assembly and a cell wall and rebounding with increased _ impact force with each cycle is appropriately considered in the Licensee's analysis. The Licensee's analysis shows that this phenomenon (resonance behavior) does not occur during a PHE. Fishman, et al. , ff.
Tr. at 9-10; Licensee's Herack Report, Section 6.2.1.
Contention I(B)8 Sierra Club Contention I(B)8 provides:
It is the contention of the Sierra Club that the Reports fail to include consideration of certain relevant l conditions, phenomena, and - alternatives necessary for independent verification of claims made in the Reports regarding consistency of the proposed reracking with the
[ protection of the public health and safety , and the environment, and with federal law. In particular, the Reports fail to consider:
l eee
- 8) the use of anchors, braces , or other structural l members to prevent rack motion and subsequent l
damage during the PHE.
- 8. The Licensee's reracking analysis is based on a free-standing configuration and does not consider any structural constraints to prevent rack motion. In this regard, the Board agrees with the conclusions of I
- ~ . . - - . _ . _ , _ . _ _ , - . , _ _ _ _ . . . _ , _ _ , . _ _ _ , _ _ _ _ _ _ _ _ _ _ , , _ _ _ _ . _ _ . _ . _ , . . _ _ _ _ _, ,_.
DRAFT the Franklin Research Center Report that the Licensee's Rerack Report demonstrates compliance with the requirements of the codes, standards and practices for the spent fuel pool modifications. Fishman et al. , ff.
Tr. at 11, Table 1. Therefore, the Board concludes that an snalysis by the Licensee of the use anchors, braces or other structural members to prevent rack motion during a Pile is not necessary in order to demonstrate compliance with the applicable codes, standards and l requirements or to prevent rack motion and subsequent damage during the PIIE.
Contention II(A)1 Sierra Club Contention II(A)1 provides:
It is the contention of the Sierra Club that the proposed re scking is inconsistent with the protection of the ,e puolic health and safety, and the environment, for reasons which include the following:
A) during PHE, collisions between racks and the pool walls are expected to occur, resulting in:
- 1) impset forces significantly larger than those
- estimated in the reports
- 9. Based upon all the evidence submitted on this aspect of the Sierra Club's Contention, the Board finds that collisions between adjacent racks and between rack and wall were appropriately considered l by the Licensee and further, that the analysis was based upon well i
established engineering principles that included the following modeling I
considerations:
- The simultaneous consideration of three orthogonal seismic acceleration time-histories (3-dimensional analysis) o Elastic flexibility of the rack module l
l
DRAFT' o impacts of the spent fuel assemblies oscillating in the clearance
- space of the rack storage cells o THe effects of impacts with an adjacent rack or the pool wall o Off-center partial fuel loadings as well as full fuel load o A documented. range of friction coefficients between the mounting pads and the pool liner o The hydrodynamic effects of water (i.e., fluid coupling) betwcen rack and fuel assemblies, anDetween rack and adjacent racks and walls o Fluid - damping between rack and assemblics, and between rack -
and adjacent racks, is conservatively neglected o The form drag opposing the motion of the fuel assemblies and fuel racks are neglected. Fishman et al. , ff. Tr. at 12-13.
In view thereof, the Board concludes that impact forces were not underestimated by the Licensee in its Reracking Report and subsequent related communications.
Contention II(A)2 Sierra Club Contention II(A)2 provides:
It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which include the following:
A) during PHE, collisions between racks and the pool walls are expected to occur, resulting in:
- eee
- 2) impact forces on the racks significantly Icrger than those expected to damage the racks;
, 10. . The Board finds this contention to be without merit. The Licensee and staff witness Mr. Fishman have reviewed this matter using conservative assumptions and the computations set forth in our Finding 9 above. In addition, the basis for the computations of allowable impact
DRAFT l l
l forces on the girdle bars is incipient plasticity. Fishman et al. , ff. Tr.
at 13-11; Licensee Rerack Report; Section 6.9. Therefore, in the opinion of the Board, when the Licensee's maximum computed impacts loads are compared to the allowable impact forces, ample safety margins are found in all cases. Id.
Contention II(A)3 Sierra Club Contention II(A)3 provides:
-It is the contention of the Sierra Club that the proposed veracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which include the following:
A) during the PHE, collisions between the racks and the pool walls are expected to occur resulting in:
eee
- 3) significant permanent deformation and other damage to the racks and pool walls;
- 11. A review of the testimony and evidence submitted clearly indicates that the contention is incorrect. The Board believes that I significant, permanent deformation and other damage to the racks and i
f walls will not occur as a result of the PHE. The basis for this conclusion is based upon the testimony of Staff's Mr. Fishman and the Licensee's Reracking Report, Sections 6.9.1 and 6.9.2, including Tables 6.8.1 and 6.8.2. Allowable impact loads were compared to the calculated maximum corresponding impact loads during the PHE, and the evidence submitted clearly indicates that in all cases no significant permanent deformation or corresponding damage at tiie impact locations was shown. From Licensee's Table 6.8.2, it can be determined that the largest calculated impact force between a storage cell and a fuel assembly 249,900 lbs. or 28 percent of
f ,
DRAFT 4 l
the allowable 883,000 lbs. Similarly, the maximum calculated impact force between racks is 105,000 lbs. , which is 60 perc9nt of the allowable 175,000 lbs. Fishman et al., ff. Tr. at 14-15; Licensee Rerack Report, Secticne 6.9.1 and 6.9.2, Tables 6.8.1 and 6.8.2.
Contention II(A)4 Sierra Club Contention II(A)4 provides:
It is the con cation of the Sierra Club that the proposed reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which include the follo. ng:
A) during the PHE collisions between the racks and the pool walls are expected to occur resulting in:
eee
- 4) reduction of the spacings between fuel assemblies:
- 12. For the reasons set forth in our Finding 11 supra, that no significant permanent deformation at any impact location will occur, the Board is of the opinion that there will be no permanent reduction in spacing between fuel assemblies as the result of impact computed forces.
Id. , See also, Fishman et al. , ff. Tr. at 16.
Contention II(B)
Sierra Club Contention II(B) provides:
It is the contention of the Sierra Club that the proposed
- reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which include the following
ee*
l B) during the PIIE, collisions between groups of racks with each other and/or with the pool walls are
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f l DRAFT expected to occur with results similar to those
- descrioed in II(.A) bove.
- 13. It' appears that the Sierra Club's main concern in this contention is that despite random excitation during the PHE several fuel racks could mcve in unison and collide with another_ rack or the spent fuel pool wall. The Sierra Club maintains that basic physical principles predict that the forces generated in a collision with two racks would be twice se large as for single racks, three times for three racks etc. In its initial evaluation (Staff Exhibit 1) the Staff concluded that the probability of multiple racks making contact with each other without rebounding and then sliding as a single unit towards another rack or the spent fuel pool wall during the PHE would be extremely low because of the variations in the size, mass and stiffness of each individual rack as well as the spacing and friction. Thereafter, as a result of questions raised by the Brookhaven National Laboratory in the context of its review of the Commonwealth Edison Company application to rerack the Bryon spent fuel pool, the Licensee was requested by the Staff to perform a number of analyses to demnstrate the conservatism of its single rack model. In particular, the Staff was concerned that the impact forces due to multi-rack impacts could exceed the forces computed by use of the single rack model. Fishman, et al. , ff. Tr. at ).
The Licensee submitted additional analyses. (Licensee Exhibits
_ , _. ) These analyses were reviewed by the Staff and its consultants FRC and DNL, as reflected in their respective TERs. (Staff Exhibits 1-A and 1-B). The Staff concluded, on the basis of its review, that the rack-to-rack, fuel assembly-to-rack and rack-to-wall impact loads were within the respective allowable impact loads. The Board finds that I . __ _ _ _ _ _ _ _ _ _ _ _ _ _ . - - . _ _ _ _ _ _ _ , _ _ . _ _ _
DRAFT the Staff's review confirms the acceptability of the proposed rack design.
~
Fishman et al. , ff. Tr. at _ ).
Contentions II(A)6, 7, 8 and 9: II(B)6, 7, 8 and 9 Sierra Club Contentions II(A)6, 7, 8 and 9 and II(B)6, 7, 8 and 9 provide: ,
It is the contention of the Sierra Club that proposed reracking is inconsistent wata the protection of the public health and safety, and the environment, for reasons which include the following:
A) during the PHE, collisions between the racks and the poo! walls are expected to occur resulting in:
- 6) release of large quantities of heat and radiation:
- 7) radioactive contamination of the nuclear power plant and its employees above the levels permitted by federal regulations;
- 8) radioactive contamination of the environment in the vicinity of the nuclear power plant above the levels permitted by federal regulations; and i 9) radioactive contamination of humans and other
- living things in the vicinity of the nuclear i
power plant above the levels permitted by federal regulations.
[ (B) during the PHE, collisions between groups of racks with each other and/or_ with the pool walls are expected to occur with results similar to those described in 11(A) above.
- 14. The Board finds that the consequences of criticality in the spent fuel pools at Diablo Canyon need not be specifically considered l
because General Design Criterion (GDC) 61 requires that fuel storage facilities be designed so that adequate safety margins under normal and l postulated accident conditions is assured. Further, GDC 62 requires that i
DRAFT criticality in fuel storage and handling systems be prevented. Because compliance with these General Design Criteria is required, the Board agrees with the testimony of Staff witness Dr. Brooks and concludes that no analysis of the consequences of a criticality event in the spent fuel pool is required. Fishman, et al. , ff. Tr. . at 18-19. In order for the parties to better understand the development of criticality in a spent fuel pool, the Board refers to the testimony of staff witness Dr. Brooks, who was asked to assume that conditions in the spent fuel pool support its occurrence. Dr. Brooks advised:
If one postulates that the k-effective value of the l fuel-rack-water combination (the system) in the pool l becomes greater than unity (i.e., becomes supercritical) l the neutron population wouTd- rise at a rate which L depends on the amount by which k-effective is greater l
than unity (i.e. , the reactivity of the system). The fission rate would increase and the temperature of the fuel would rise. The temperature rise in the fuel would e (:
act to reduce the k-effective of the system (i.e., will introduce negative reactivity) . At some filgE fuel temperature the net reactivity will be zero and the fission rate increase would cease (after some over-shoot) and begin to fall. If the initial value of the k-effective is greater than about 1.005, the events described above would occur before a significant amount of heat is conducted from the fuel to the surrounding water. As heat is lost from the fuel its temperature would fall and the k-effective value would begin to rise again. The cycle described above would repeat itself until enough heat has been generated and depos ted in the pool water to create sufficient voids to offset that part of the initial reactivity that is not offset by the steady state fuel temperature rise. A final state would be reached in which the power generated in the pool is just enough to maintain the void content of the water. The heat generation rate of the final state (where the heat generation rate remains constant) will depend on:
- 1. The assumed initial reactivity insertion,
- 2. The void coefficient of reactivity (i . e . what void fraction in the water is required at the steady state),
h 1 l
DRAFT
- 3. The thermal-hydraulics characteristics of the core which determines the amount of water that must be converted to steam per unit time. Meaningful
, estimates of the amount of heat generated are not possible. However, it is clear that with sufficient initial excass reactivity (k-effective greater than 1 by a large amount) large amcunts of heat, and therefore, radiation may be generated. Fishman et al. of ff. Tr. at 19-20.
In explaining the term k(eff) Dr. Brooks advised:
In a multiplying system (one which contains fissionable material, such as the loaded spent fuel storage racks) three processes involving neutrons may be identified. These are neutron production, neutron absorption, and neutron leakage. The sum of the neutron absorption and neutron leakage is the neutron loss. Given an initial neutron population in the system, if the production rate is greater than the loss rate, the population will increase. Conversely, if the production rate is less than the loss rete the population will decrease. If the two rates are equal the population will not change and the system is said to be just critical.
The k(eff) value for the system is defined as the ratio of the production rate to the loss rate. Id.
at 20-21.
The Board agrees with the above explanations of Dr. Brooks.
- 15. Based upon the testimony of Staff witness Amarjit Singh and the information contained in the Staff's Safety Evaluation (Staff Exhibit 1) at , the Board concludes that the Diablo Canyon spent fuel cooling systems for both units have the capability to remove decay heat under both maximum normal and maximum abnormal heat load conditions.
Standard Review Plan (SRP), HUREG-0800 (Section 9.1.3) specifles that a single cooling train be able to maintain water temperature in the pool at or below 140*F. This calculated maximum normal heat load was determined by the Licensee and verified by the Staff t; be 2.28 x 107 (rounded)
BTU /HR. The Board finds that the Licensee's calculations are more i
i o
. _ , , . _ - , - _. , . . . . ~ _ _ , . -
-.w., - _ , _ _ , . , , . , _ . , . _ _ . , _ , _ _ . - _ ,__-...._r . _ . _
DRAFT conservative than the Staff's acceptance criteria expressed above. With regard -to abnormal heat load conditions, the Licensee calculated, and the Staff has verified, such conditions to be 4.38 x 10 BTU /HR. This abnormal heat load results in a maximum pool temperature of 174cF which meets the SRP acceptance criteria of no bulk pool boiling for this condition. In addition, each of the Diablo Canyon spent fuel pool cooling systems can remove a maximum heat load. of 5.9x10 BTU /hr. and maintain the water temperature in each pool below the boiling point.
Therefore, the Board finds that each of the Diablo Canyon spent fuel pool cooling systems have the capability of removing decay heat beyond the maximum normal and maximum abnormal heat load conditions. Fishman et al. , ff. Tr. at 21-22. (need more cites)
Contention I(B)9 Sierra Club Contention I(B)9 provides:
It is the contention of the Sierra Club that the Reports fall to include consideration of certain relevant conditions , phenomena and alternatives necessary for independent verification of claims made in the Reports
- regarding consistency of the proposed reracking with public health and safety, and the environment, with federal law.
In particular, the Reports fall to consider: '
eee the use of "Boraflex" neutron absorbing material for all fuel racks.
- 16. In this contention the Board assumes the Sierra Club contends i that Boraflex should be used in the Region 2 racks as well as those in ,
l Region 1. Because the Region 1 racks are designed to store fresh fuel containing up to 4.5 percent of U-235 by weight, the fuel assemblies
.__.--7_ ,-_,,,.__,.,-__-%,,,,,.___....,y y ,, ,m.,_,, -,.-.,.,_,__,,-,,_,.m__._ -.w.,- - _ _ . - -
DRAFT contain Boraflex. Ilowever, the Region 2 racks do not contain Boraflex and the' Board finds it is not required. The Staff has no requirements for the use of Boraflex, however the Staff does require that spent fuel storage racks have a k(eff) value of 0.95 or less. Because the Diablo Canyon Region 2 racks without Boraflex meet this requirement, the Board finds the criticality design of these racks to be acceptable.
. Therefore, this contention urging the use of Boraflex for all racks is without merit. Fishman, et al. , ff. Tr. _ at 22-23.
Contention II(A)5 and II(B)5 Sierra Club Contenticns II(A)5 and II(B)5 provide:
It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which include the following:
i A) during the PHE, collisions between the racks and j the pool walls are expected to occur resulting in:
i 5) increase in the nuclear criticality coefficient,
! k(eff) above 0.95 B) during the PHE, collisions between groups of racks l with each other and/or with the pool walls are
- expected to occur with results similar to those mescribed in 11(A) above.
l
- 17. As noted earlier in Finding 14, by adherence 'to GDC's 61 and 62 the integrity of the spent fuel racks is assured during the PHE.
That is, deformation of the racks is limited to transient oscillation with l
insignificant permanent deformation. In this situation, the edge-to-edge spacing between the storage cells of each of the racks is not permanently reduced and the fuel assemblies remain intact. Under these conditions, if credit is taken for dissolved boron in the water the k(eff) value remains
I DRAFT well below the NRC acceptance criterion of 0.95 and the k(eff) sy, stem is suberitfcal. In connection with our analysis and conclusions regarding l these two contentions, the Board refers to and incorporates herein its findings and conclusion set forth in Finding 14 supra, wherein the k(eff) values of spent fuel pool water is explained. See, especially, the testimony of Staff witness, Dr. Brooks. Based upon the information contained in these Findings, the Board concludes that in the event of a PHE there will not be an increase in the nuclear criticality coefficient k(eff) above 0.95. Fishman, et al. , ff. Tr. at 19-21, 24-26, 29.
4 The Board further finds , based on the testimony of Staff witness Dr. Brooks, that even if there were permanent deformation of the ,
racks during the PHE, a condition the Board does not expect to occur, and goes beyond the bounds of the required NRC safety analysis, criticality would not occur in Region 2 of the Diablo Canyon spent fuel pools even if the fuel cells were distorted to the point of contact with l cach other. The Board further finds that only if the fuel cells in the racks of Region 1 were . distorted to the
- point of contact would criticality -
i be a possibility and then only in this Region. In this regard, Dr. Brooks' reasoning, which the Board hereby adopts, is as follows:
- 1. Generic studies of criticality in spent fuel racks have been performed. One such study has been published in
!~ the proceedings of the 4th National Conference, ASME, 3
June 19-24, 1983 at Portland, Oregon. '1his study contains an algorithm by which the k-effective value of a multiplying system (i.e. , spent fuel racks with fuel) as a function of fuel enrichment, water gap thickness (space between storage cans) and baron loading (fixed boron on the racks) may be obtained. This algorithm
- - was used by me to examine the k-effective value for the Region 1 and Region 2 racks at Diablo Canyon. If one assumes that no boron is present in the pool water (which is not the case) the algorithm predicts that for both regions criticality (k-effective of 1.0) would occur 4
, , , , , . - - - n - ,-,,- ,-,-n. ,n-,n, .-.,,..,n,...-,,.---,.,---n-,-, , , . . . - , , - - , , , , - , . , - - - - , . _ , - , , - , , - , , , , - ,
DRAFT at a water gap thickness of about 0.85 inches. The design water gap thickness for Region 1 racks is 1.79 inches and for Region 2 racks is 1.9 inches.
(Figures 4.2 and 4.3 of the Reracking Report).
- 2. The algorithm was derived from a data base that did not include c water gap thickness less than 0.78 inches.
Ilowever, a curve of k-effective as a function of gap-dimension may be drawn and extrapolated to zero gap thickness. This results in a k-effective value of about 1.2 for both types of racks at zero gap thickness.
A gain , this for the case assuming there is no boron present in the pool water (which is not the case).
- 3. The effect of dissolved boron on the reactivity (k-effective) of the rack may be obtained for Region 2 racks from the Licensee's Reracking Report page 4-6 where it is , reported that reduction of the boron concentration by 800 parts per million (ppm) increases the k-effective value by 0.1. The boron worth in the water is thus- 0.01/80 ppm. A boron concentration of 2000 ppm (the concentration in the pool weter at Diablo Canyon Unit 1 and Unit 2 spent fuel pools) would therefore be expected to reduce the k-effective value by 0.25 relative to the value without boron in the water.
Thus, Region 2 would be expected to remain subcritical (1.2 .25 = .95 keff) even when the storage cells are in contact (a gap of zero) if the water is assumed to be borated to 2000 ppm.
- 4. No value for boron worth is given for the Region 1 rachs. It would be expected to be smaller than that for Region 2 due to the presence of the fixed boron on the racks which reduces the impset of the poisonfr.g effect of boron in the water gap. If the boron worth is as low as 0.01/100 ppm (which is possible) , then these racks would be just critical at contact in the borated water.
Thus, we cannot conclude that criticality would not occur in the racks if it is postulated that the racks are distorted to contact (a gap of zero). However, as the testimony of Mr. Fishman indicates, such distortion will not occur. See, Fishman, et al., ff. Tr. at 26-28.
- 18. As noted throughout these Findings, the Board does not anticipate that there will be any significant permanent deformation of any portion of the racks resulting from the PILE. Therefore, there will not be any contacting of the fuel cells of the Diablo Canyon spent fuel racks L_
DRAFT as alleged. See, g, Fishman, et al. , ff. Tr. at 14-17, 24-26, 28 and 29.'
Contention I(B)7 Sierra Club Contention f(B)7 provides:
It is the contention of the Sierra Club that the Reports fail 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.
In particular, the Reports fail to consider:
- 7) alternative on-site rtorage facilities including:
(i) construction of new or additional storage facilities and/or; (ii) acquisition of modular or mobile spent nuclear fuel storage equipment, including spent ,e nuclear fuel storage casks;
- 19. As previously noted, an Environmental Assessment (EA), which, among other matters , evaluated both the impacts attributable to the proposed action and alternatives to it , was prepared and issued. $
12/ A notice of no significant impact was also prepared and published in the Federal Register. 51 Fed. Reg.19,430 (May 29,1986). There is i no admitted contention that directly challenges the finding of no i
significant impact, the only admitted environmental contention going to the adequacy of the consideration given to alternatives. The evidence regarding this matter that was presented by the Staff in the context of its consideration of alternatives was uncontroverted.
The Board, not finding any serious environmental matter which
, would otherwise warrant further inquiry see,10 C.F.R. I 2.760a, or give reason to modify the finding of no significant impact, therefore affirms this finding. The finding of no significant impact previously published thus is final. See, 51 C.F.R. I 51.34(b). The Staff is directed to prepare a Federal Register notice conslutent with the l foregoing for issuance by the Board.
L
DRAFT (Staff Exhibit 2). The EA fully complies with the requirements of 10 C.F.7. I 51.30. On the basis of all the evidence submitted, the Board finds that the NRC staff has reviewed the Licensee's spent fuel pool amendment with regard to alternatives as required by the National Environmental Policy Act (NEPA). Testimony of Donald P. Cleary , ff.
Tr. ,_ st 2 (hercinafter "Cleary if. Tr. at ").
- 20. On the basis of the evidence submitted, the Board also finds that the proposed rcracking of the spent fuel pools at the Diablo Canyon Nuclear Power Plant has both an environmental and a financial advantage over the asserted alternatives of wet or dry, independent on-site spent fuel facilities. As noted below, the Licensee's proposed reracking will have no significant environmental impacts, whereas the Sierra Club's asserted siternatives will have specific, although not significant, environmental impacts. The Licensee's proposed reracking also has clear financini advantages over the asserted alternatives.
- 21. The Board concludes that the proposed reracking will have no significant non-radiological environmental impacts because the reracking will take place within the confines of the fuel poc! buildings, thereby presenting no source of non-radiological environmental impacts to the Diablo Canyon site and environs. Further, there will be no significant radiological environmental impacts attributable to the proposed reracking modification because the potential for accidents having offsite consequences and the potential for radioactively contaminated wastes generated from reracking having offsite consequences is small. Potential reracking accidents are bounded by the fuel handling accident which would have no significant environmental consequences. Radioactiveley
1 DRAFT contaminated waste generated from wet reracking will be disposed of in accordaince with 10 C.F.R. Part 71 " Packaging and Transportation of Radioactive Ibaterial" and 10 C.F.R. Part 61 " Licensing Requirements for Land Disposal of Radioactive Waste" and therefore will have no sign 111 cant impact on the environment. Operating impacts of the reracked fuel pools on the environment were considered in the Environmental Assessment (Staff Exhibit 2, Section 3 for radiological impacts and Section 4 for non-radiological impacts.) The primary environmental pathway associated with storage of spent fuel assemblies is Kr-85 plume shine. Incremental doecs to the general public were estimated to be very small relative to doses incurred during normal operation and to natural background radiation exposure. The only source of potential non-radiological impacts is an insignificant increase (less than 0.1%) in waste heat discharged to the Pacific Ocean. No impact on aquatic biota is anticipated. Cleary; ff.
Tr. at 3-4.
- 22. On the other hand, the Board finds -u! construction of either of the asserted alternatives, that is construction of a wet or dry independent on-site spent fuel storage facility would produce environmental impacts that would not be produced by the Licensee's proposed reracking. First, additional land would be needed for the structures and supporting utilities. In addition, a separate new spent fuel pool building with the storage capacity of the two present fuel pools would disrupt at least one acre of land plus the additional land required for an access road, water pipes and electric lines. Further, if dense storage regions of spent fuel is not allowed there will be an additional requirement for a number of on-site spent fuel pools over the next fifteen
DRAFT years. Other potential impacts of such construction include erosion, dust, iIncreased traffic over local roads, noise and a decrease in the aesthetic quality of the site. In addition, further development of the Diablo Canyon site may be complicated by the presence of numerous Indian burial sites in the area and the requirements of the National IIIstoric Preservation Act of 1966. Approval of development plans by the California Coastal Commission will also be required.
Finally, a larger workforce would be required to operate and nr.intain additional facilities and to handle and move spent fuel from the criginal pcols to the new pools requiring additional piping to remove waste ,
heat, increased use of chemicals to control biofouling would also be necessary. Therefore, incremental environmental impacts due to operating independent on-site spent fuel pools would be greater than operating the reracked existing pools. Cleary ff. Tr. at 4-5,
- 23. With regard to the dry reracking proposal, the same approach has been used to compare the relative environmental impacts of reracking for the dry storage alternative as it used in the case of the wet storage alternative discussed above. The Board finds the cuvironmental impacts of dry storage would be less than for the now apent fuel pools but wculd still be greater than the Licensee's proposed reracking. There are basically three technologies which could be used for dry storage. These are: (1) metal storage casks; (2) drywells (below grade); and (3) concrete modules above ground. The Board notes that pursuant to the National Waste Policy Act, the United States Department of Energy has entered into cooperative agreements with Virginia Power Company to demonstrate dry cask spent fuel storage technology and with Carolina
DRAFT Power and Light Company to demonstrate that dry cask spent fuel, storage and storage in a concrete horizontal module, are viable storage options that are licen' sable by the NRC.
In the case of dry cask and concrete horizontal storage modules, environmental assessments were performed for their use at the 4
Surry Power Station and the H. B. Robinson Steam Electric Plant, respectively. Both assessments resulted in a Finding of No Significant Impact. Because of the relative simple and passive operation of these technologies, their environmental impacts at the Diablo Canyon site would be slight and in the Board's opinion, would not differ much from those environmental impacts described for Surry and H. B. Robinson.
l The Doard finds that the major differences in environmental impacts would be associated with the differing topographic characteristics of the sites and their implications for construction. The Board concludes that it is likely that a dry cask storage area at Diablo Canyon would require at least 15 additional acres as was required at Surry. Because additional relatively level land is limited at Diablo Canyon the amount of excavation will be increased, complicating the design and construction.
Because of the additional commitment of land required with no offsetting benefits, these alternatives are considered by the Board to be less desirable than the proposed reracking of the existing pools. Cleary, ff.
Tr. at 5-6.
- 24. The Licensee estimates that the reracking effort will cost $13 million per unit. Because the new racks have already been purchased and are a sunk cost, the incremental cost from this time forward is something less than $13 million per unit. In the absence of detailed
a DRAFT engineering design and firm commercial commitments there is considerable uncertainty as to the likely cost of any of the asserted alternatives.
From available information however, the Board finds that the asserted alternatives would be significantly more expensive than the proposed wet reracking.
Costs associated with reracking relative to new storage were explored in an IAEA Advisory Group / Specialist Meeting, November 17-21, 1980, and reported in DOE-SR-0009, " Spent . Fuel Storage Alternatives."
Capitol costs for reracking a single pool were in the range of $5/kg to
$15/kg, in 1980 dollars. Pacific Gas and Electric Company's estimate of
$13 million to rerack each pool represents about $21/kg in 19.87 dollars.
The Board finds that adjusting for escalation, this is consistent with the 1980 estimate for reracking.
In addition, capital cost reported in the 1980 IAEA Advisory Group / Specialist Meeting for new fuel pools for a two reactor unit was
$52/kg. A more current but incomplete estimate of capital cost for a new pool is from the Energy Economic Data Base Program maintained by United Engineers and Constructors, Inc. for the U.S. Department of Energy.
I
- The median cost of constructing a fuel storage building in conjunction l with construction of a 1139 MWe pressurized water reactor was $12.8 l
million in 1986 dollars. Cleary, ff. Tr. at 7-8.
- 25. In view of the foregoing, the Board finds that construction of j an independent fuel pool building would involve additional direct costs not f included in the $12.8 million. These additional direct cost are for site preparation and excavation, and for separate ventilation, heating, and I
water supply systems. There are also indirect costs which should also be i
l I
DRAFT included. - These indirect costs are engineering and services associated
~
with design and construction management. These would bring the 1987 capital cost to well over $13 million per pool projected for Diablo Canyon.
If high density racks were not allowed in the new pools at Diablo Canyon, the additional storage capacity would be exhausted by the mid-1990's after approximately the fifth refueling. To provide total storage capacity for 1324 fuel assemblies in on-site fuel pools comparable to the licensee's current proposal would require a multiple of $13 million. Cleary, ff.
Tr. at 8.
Finally, the Board concludes that the capital cost of providing dry on-site storage for 1324 fuel assemblies is greater than reracking the existing fuel pools. Dry storage is in the demonstration stage and no commercial cost baseline exists. The Board notes that the U.S.
et Department of Energy has, however, made estimates of the likely cost of constructing and operating three types of dry storage facilities: storage cask, drywell and concrete silo. The range of capital costs for storage capacity of about 1000 fuel assemblies is around $50 million, in 1983 dollars , for these three methods. The DOE estimates are reported in DOE /S-0023, " Federal Interim Storage Fee Study for Civilian Spent Nuclear Fuel: A Technical and Economic Analysis," July 1983. Cleary, ff. Tr. at 8-0.
CONCLUSION
- 26. Based on the evidentiary record before us, this Board concludes that the Licensee's proposed amendment requests to expand its spent fuel pools by reracking at the Diablo Canyon Nuclear Power Plant,
DRAFT with respect to those matters in controversy, complies with all of the Commission's requirements.
IV. CONCLUSIONS OF LAW In reaching this decision, the Board has considered all the evidence of the parties and the entire record of this proceeding including all proposed findings of fact and conclusions of law presented by the parties. All issues, arguments to or proposed findings presented by the parties but not addressed in this decision have been found to be without merit or unnecessary to this decision. Based upon a review of that record and the foregoing Findings of Fact, which are supported by reliable, probative and substantial evidence, the Board, with respect to the issues in controversy before us, reaches the following conclusions pursuant to 10 C.F.R. I 2.760a:
The Licensee's proposed amendment request to expand its spent fuel pools by reracking at its Diablo Canyon Nuclear Power Plant, with respect to those matters in controversy,
- complies with all of the Commission's requirements; with respect to these matters there is reasonable assurance that the facility can be operated without endangering the public health and safety; and, upon making those findings necessary with respect to matters not in controversy, the Director, Office of Nuclear Reactor Regulation may issue the license amendments requested.
DRAFT V. ORDER Wi[EREFORE, in accordance with the Atomic Energy Act of 1954, as amended, and the Rules of Practice of the Commission, and based on the foregoing Findings of Fact and Conclusions of Law, IT IS ORDERED that:
Pursuant to 10 C.F.R. I 2.760(a) of the Commission's Rules of Practice, this Initial Decision will constitute the final decision of the Commission forty-five (45) days from the date of issuance, unless an appeal is taken in accordance with 10 C.F.R. I 2.762 or the Commission directs otherwise. See also 10 C.F.R. El 2.764, 2.785 and 2.786.
Any party may take an appeal from this decision by filing a Notice of Appeal within ten (10) days after the service of this decision. Each appellant must file a brief supporting its position on appeal within thirty (30) days after filing its Notice of Appeal (for ty (40) days if the Staff is the appellant). Within thirty (30) days after the period had expired for the filing and service of the briefs of all appellants (forty (40) days in the case of the Staff), a party who is not an appellant may file a brief in support of or in opposition to the appeal of any other party. A responding party shall file a single , responsive brief regardless
DRAFT of the number of appellant briefs filed. See 10 C.F.R.
C 2.7G2(c).
THE ATOMIC SAFETY AND LICENSING BOARD B. Paul Cotter, Jr. , Chairman ADMINISTRATIVE JUDGE Glen O. Bright ADMINISTRATIVE JUDGE Jerry liarbour ADMINISTRATIVE JUDGE Dated at Dethesda, Maryland this day of , 1987
,s s i
, EXHIBITS i
Licensee List of Licensee Exhibits ,
PGandE Letter DCL-85-333, October 30, 1985; License 1.
Amendment Request 85-13 Reracking of Spent Fuel Pools.
PGandE Letter DCL-85-306, September 19, 1985 Reracking 2.
Report.
PGandE Letter DCL-86-019, January 28, 1985; Additional 3.
Information - Spent Fuel Pool Reracking.
PGandE Letter DCL-86-067, March 11,1986; Response 4.
to Questions on Spent Fuel Racks.
PGandE Letter DCL-87-022, February 6,1987; Rack 5.
Interaction Studies.
PGandE Letter DCL-87-072, April 9,1987; Additional 6.
Information on Rack-to-Rack Interactions (Proprietary ,c and Nonproprietary).
PGr.ndE Letter DCL-87-082, April 33,1987; Three-Dimen- 7.
sional Studies.
8.
PGandE Letter DCL-87-115, May 18,1987, Additional Information on Heracking Analyses.
9.
Seismic Analysis Report, Rev. 3, September 3,1986.
10.
NRC Standard Review Plan, Section 9.1.2, NUREG-0800.
11.
NRC Standard Review Plan, Section 3.8.4, Appendix D, NUREG-0800.
12.
NRC OT Position for Review and Acceptance of Spent Fuel Storage and llandling Applications April 14, 1978 (Supplemented January 18, 1979).
NRC Staff Exhibits _ M Exhibit 1 Safety Evaluation By the Office of Nuclear Reactor Regulation Relating to the Heracking of the Spent Fuel Pools Amendment No. 8 to Unit 1 Facility Operating License No. DPR-80 k
p i*
Amendment No. 6 t'n Unit 2 Facility Operating License DPR-82, i Pacific Gas and Electric Company, Docket Nos. 50-275- and l 50-323.
m Evaluation of Spent Fuel Racks, Structural Analysis, Pacine Exhibit 1-A Gas & Electric Company, Dicblo Canyon Units 1 and 2, Ter-C5506-625, Revised May 28, 1987.
Evaluation of the Structural Adequacy of the Diablo Canyon Exhibit 1-B High Density Spent Fuel Racks in Accomodating Multiple Fuel Rack Impacts During the Postulated Hosgri Earhquake, May,1987 Environmental Assessment by.the Office of Nuclear Reactor Exhibit 2 Regulation Relatir.g to the Expansion of Spent Fuel Pools Facility Operating License Nos. DPR-80 and DPR-82 PaciSc Gas and Electric Company, Diablo Canyon Units 1 and 2, Docket Nos. 50-275- and 50-323.
Sierra Club Exhib)tr
[to be submitted under separate cover}
1 B
i l
I I
f
_