ML20235S009

Affidavit of Jd Shiffer.* Explains Util Planned Expansion of Facility Spent Fuel Storage Capacity & Why Delay in Reracking Schedule,Such as Would Be Occassioned by Stay,Will Cause Substantial Harm to Util.Certificate of Svc List Encl

ML20235S009
Person / Time
Site:	Diablo Canyon
Issue date:	10/02/1987
From:	Shiffer J PACIFIC GAS & ELECTRIC CO.
To:
Shared Package
ML20235R964	List: ML20235R961 ML20235S009
References
OLA, NUDOCS 8710080267
Download: ML20235S009 (8)

Text

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UNITED STATES OF AMERICA I

NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 3

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) Docket No. 50-275 OLA In the Matter of ) 50-323 OLA 5

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6 PACIFIC GAS AND ELECTRIC COMPANY ) (Spent Fuel Pool Reracking)

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(Diablo Canyon Nuclear Power )

7 Plant Units 1 and 2) )

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AFFIDAVIT OF JAMES D. SHIFFER 10

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James D. Shiffer, being first duly sworn, states as follows:

I am Vice President, Nuclear Power Generation of Pacific Gas and Electric Company ("PGandE"). PGandE owns and operates the Diablo Canyon Nuclear Power Plant Units 1 and 2 ("Diablo Canyon"); both units are in commercial operation. In my capacity as Vice President, Nuclear Power Generation. I am responsible for the operation and maintenance and related construction activities at Diablo Canyon.

I have more than 25 years of experience in the nuclear power industry and am particularly familiar with Diablo Canyon as a result of my involvement with the plant since its inception. Furthermore, I have overall 21 responsibility for the activities described in this affidavit. Accordingly, I can testify from personal knowledge to the matters set forth herein.

22 The purpose of my affidavit is to set forth PGandE's planned 23 activities (and those which it is now undertaking), which have been approved 24 by the Atomic Safety and Licensing Board ("ASLB") and the NRC Staff, to expand 25 the spent fuel storage capacity at Diablo Canyon. I will also explain why any 26 8710080267 871002 PDR ADDCK 0500 5 l

'd 3 delay in PGandE's reracking schedule, such as would be occasioned by a stay, 2 will cause substantial harm to PGandE.

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1. There are two separate spent fuel storage pools at Diablo 4 Canyon Units 1 and 2, one for each unit. The original storage racks currently 5 in each pool are capable of storing 270 fuel assemblies. PGandE is planning 6 to replace the original racks with new high density storage racks which can 7 store up to 1324 fuel assemblies in each pool. This work was originally 8 approved by the NRC in May 1986 and performed by PGandE for Unit l' during 9

June-August 198! '1 a dry, uncontaminated environment prior to the first 10 refueling outage. However, as a result of a decision issued in September 1986 3j by the Ninth Circuft Court of Appeals, which reversed the NRC approval until 12 completion of public hearings, the high density racks were removed and 13 replaced with the original storage racks. The hearings were held by the NRC 14 in June 1987, and an initial decision authorizing the Director of Nuclear 15 Reactor Regulation to issue the reauested license amendments was issued by the 16 ASLB on September 11, 1987.

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2. Each unit at Diablo Canyon operates on approximately a 12- to 18 18-m nth operational cycle after which refueling occurs. Once a nuclear unit 39 reaches the end of an operating cycle, it cannot continue to operate at fuli 20 capacity due to reduced reactivity of the fuel and limitations on fuel burn-up. It must curtail operation and shut down for refueling. At each 21 22 refueling, typically one-third of the total of 193 fuel assemblies in the reactor Core are removed and placed in storage racks in the spent fuel pool.

g The capacity of the existing racks in each pool is sufficient to store the 25 spe t fuel discharged from approximately five years of reactor operation.

Diablo Canyon Unit 1 started commercial operation in May 1985 and refueled for

j the first time in the fall of 1986. The Unit 1 pool currently contains 68 2 spent fuel assemblies. The Unit 1 second refueling outage is scheduled to 3 begin in early March 1988. Unit 2 started commercial operation in March 1986 4 and completed its first refueling outage in July 1987. There are 68 spent 5 fuel assemblies currently stored in the Unit 2 pool. The Unit 2 second 6 refueling outage is scheduled for the fall of 1988.

7 3. In order for the high density racks to be used for the second 8 refueling outage of Unit 1 the reracking work must be completed by 9 mid-January 1988, to allow a period of approximately six weeks following 10 reracking which is required for shipment, receipt, and inspection of new fuel jj prior to the outage. Rack replacement ectivities are scheduled to begin with 12 removal of the first spent fuel rack from the Unit 1 pool on j3 November 1, 1987. Reracking work for Unit 2 will commence after completion of 14 the Unit I refueling outage.

15 4. For several reasons, it is particularly importart that PGandE 16 complete the reracking as scheduled before spent fuel from the second 37 refueling outage is stored in the Unit 1 spent fuel pool.

18 a. An additional refueling prior to reracking would result in j9 an increase in the contamination level of the spent fuel pool, thereby 20 increasing the level of radiation workers would be exposed to during the rack 21 replacement activities. The storage of additional spent fuel in the pool 22 would also complicate reracking by requiring increased fuel handling.

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b. The storage of additional spent fuel in the pool and the 24 concomitant increase in fuel handling also will adversely affect diving f

25 perations which are necessary to accomplish the reracking work. The rack 26 replacement sequence requires relocation of spent fuel stored in the pool to I

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f j an area of the pool away from diving operations necessary for rack removal and 2 replacement. With twice as much spent fuel in the pool, it will not be 3 possible to provide as much physical separation between the spent fuel and the 4 underwater work activities. This increases the level of radiation to which 5 divers will be exposed.

6 c. Het reracking after the second refueling outage for Unit 1 7 would mean that, for a period of time after the outage until the high density g racks are installed, the plant would be operating without a full core 9

discharge capability. Full core discharge capability means that the fuel from 10 the entire reactor core (193 assemblies) can be discharged to the spent fuel jj pool for storage. Currently, the spent fuel pool contains 68 spent fuel 12 assemblies with approximately 200 open storage spaces. Following the second 13 outage, there would be approximately 140 stored spent fuel assemblies and 14 approximately 130 open spaces. Since the reactor contains 193 assemblies, the 15 entire core could not be acconrnodated in the pool if a full core discharge is 16 desired. Full core discharge capability is not an NRC requirement; however, 17 for many years it has been a common practice throughout the nuclear industry.

18 PGandE would like to maintr.in such a capability during plant operations, jg d. The NRC's regulations in 10 CFR 20.1(c) provide, in l 20 pertinent part, that licensees engaged in activities under licenses issued by 21 the Commission should, in addition to complying with the specific requirements of 10 CFR 20, 22 23 "make every reasonable effort to maintain radiation exposures ... as low as is reasonably 24 achievable (ALARA). The term "as low as is reasonably achievable" means as low as is 25 reasonably achievable taking into account the state of technology, and the economics of g improvements in relation to benefits to the o_____________ _  !

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I public health and safety, and other societal and socioeconomic considerations, and in relation to 2

the utilization of atomic energy in the public

. interest."

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'4 Consistent with these considerations, PGandE's radiation 5

protection policies require the establishment and implementation of a formal 6

ALARA program. In general, the radiation protection measures to be used for-7 the Diablo Canyon reracking work are part of the standard program for 8 maintaining occupational exposures ALARA and will apply to teracking 9

activities. Performing the reracking work prior to the second outage will 10 minimize the total occupational exposures, which is consistent with ALARA

); principles.

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e. Undertaking reracking activities after the Unit I second 13 refueling outage would increase the amount of time required to complete the 34 reracking work by approximately four weeks and increase the total cost of the 15 reracking work by approximately $3,500,000.

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I swear that the foregoing is true and correct to the best of my 2

Dated lC :L 7) 3 ,

4 O " -%

5 JAMESD.$HIFFERj//

7 Subscribed and sworn to before me [L'~~''oiiic'i.d' sib<'

this 2nd day of October 1987 j, ' , -

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Cynthia Neal-Madison 10 Notary Public in and for the City and County of San Francisco, II State of California My commission expires on October 16, 1990.

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DOLKETEu UNITED STATES OF AMERICA U5NFC NUCLEAR REGULATORY COMMISSION W DCT ~5 p3 sp 1

) Docket Nos. 50-275,40 1 In the Matter of ) 50-323, nhk PACIFIC GAS AND ELECTRIC COMPANY ) (Spent Fuel Pool Reracking) )

) 4

-(Diablo Canyon Nuclear Power )

Plant Units 1 and 2) )

)

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CERTIFICATE OF SERVICE j i

I hereby certify that on October 2,1987, copies of the following l document in the above-captioned proceeding have been served on the following i by deposit in the United States mail, first class, or as indicated by an asterisk through delivery by Federal Express: PACIFIC GAS AND ELECTRIC COMPANY'S ANSHER IN OPPOSITION TO INTERVENOR'S APPLICATION FOR A STAY.

B. Paul Cotter. Jr., Chairman

• Docketing and Service Branch Administrative Judge Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington DC 20555 I U.S. Nuclear Regulatory Commission (1 original plus 3 copies) l 4350 East West highway 4th Ficor '

Bethesda MD 20814 Glenn O. Bright

• Benjamin H. Vogler, Esq.* 4 Administrative Judge Office of Executive Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Maryland National Bank Building U.S. Nuclear Regulatory Commission Room 9604 4350 East West Highway 4th Floor 7735 Old Georgetown Road Bethesda MD 20814 Bethesda MD 20814 Dr. Jerry Harbour

• Regional Counsel l Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Region V Board Panel 1450 Maria Lane, Suite 210 4 U.S. Nuclear Regulatory Commission Halnut Creek CA 94596 l 4350 East West Highway 4th Floor 1 Bethesda MD 20814 I Atomic Safety and Licensing Marcia Preston, Esq.*

Board Panel Law Office of Dian M. Grueneich U.S. Nuclear Regulatory Commission 380 Hayes Street, Suite 4 Washington DC 20555 San Francisco CA 94102

Atomic Safety and Licensing Managing Editor Appeal Board Panel (3 copies)* . San Luis Obisoo County U.S. Nuclear Regulatory Commission Telearam-Tribune )

Washington DC 20555 1321 Johnson Avenue l San Luis Obispo CA 93406 Mr. Lee M. Gustafson Richard E. Blankenburg Pacific Gas and Electric Cc6mpany Co-publisher 1726 M Street NH Suite 1100 Hayne A. Soroyan, News Reporter Washington DC 20036-4502 South County Publishing Company P. O. Box 460 Arroyo Grande CA 93420 Janice E. Kerr, Esq. Samuel J. Chilk, Secretary

• Public Utilities Commission U.S. Nuclear Regulatory Commission 5246 State Building 1717 H Street NH, MS 1149 350 McAllister Street Washington DC 20555 San Francisco CA 94102 Dr. Richard B. Ferguson Hilliam C. Parler, Esq.* l Sierra Club / Santa Lucia Chapter General Counsel Rocky Canyon Star Route U.S. Nuclear Regulatory Commission Creston CA 93432 1717 H Street NH, MS 1035 Hashington DC 20555 1

Richard F. Locke Pacific Gas and Electric Company 77 Beale Street, 27th Floor L San Francisco, CA 94106 Dated at San Francisco, California, this 2nd day of October 1987.  !

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