ML20244D436

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Rebuttal Testimony of Gordon Thompson.* Discusses Environ Contention 3.W/G Thompson Resume.Related Correspondence
ML20244D436
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 06/09/1989
From: Thompson G
NEW ENGLAND COALITION ON NUCLEAR POLLUTION
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OLA, NUDOCS 8906190057
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June 9, 1989 ggCK [0 U5tsr UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~69 JTJ 12 PS :04 WvL '

) l In the Matter-of )

)

Vermont Yankee Nuclear )

Power Corporation ) Docket No. 50-271-OLA

) (Spent Fuel Pool)

(Vermont Yankee Nuclear )

Power Station) )

)

REBUTTAL TESTIMONY OF GORDON THOMPSON I. Purpose of Testimony The purpose of this rebuttal testimony is to respond to a number of factual issues ~ raised in the briefs and supporting affidavit and testimony filed by the NRC Staff and Vermont Yankee regarding NECNP's Environmental Contention 3, and to address fac-tual questions raised in the Licensing Board's Memorandum of May 25, 1989.

II. Benefits of Dry Cask Storage A. Severe-accident considerations In its Memorandum of May 25, 1989, the Board asked if NECNP's claim concerning the environmental superiority of dry-cask storage rests solely on severe-accident considerations. The answer to that question is no. While severe accident risk is a primary consideration, it is not the only one.

It is important to begin the answer to this question with a precise definition of " severe accident." The Severe Accident Policy Statement defines a severe accident as one in which "sub-8906190057 890609 PDR T ADOCK 05000271 PDR

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l stantial damage is donelto the reactor. core whether or not there  ;

i are serious offsite consequences." 50 Fed. Reg. 32,138 (August -j 1

8, 1985). These core melt accidents are.also characterized as J

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"beyond design basis." Id. )

'l It is possible that a zircaloy cladding fire _in the VY spent j l

fuel pool would be accompanied by.a core melt accident. However, J l

the. proposed spent fuel expansion also poses the risk of acci- )

.i dents that do not involve severe core damage,.but which could 'l q

nevertheless involve contamination of the reactor, increased-

] i worker exposures and cleanup costs, and-serious offsite con- q 1

1 sequences.

In my testimony, I discussed'several potential causative mechanisms for loss of cooling water from the spent fuel pool:

core melt accident, an accident during refueling, an earthquake ~

exceeding the SSE of_0.14g, drop of a shipping cask, and sabotage.1 -Obviously, a-core melt accident would'be properly classified as a severe accident. However,.the other potential l accident initiators would not necessarily result in core damage.

For instance, a cask drop could lead to a spent fuel pool _acci-dent without an accompanying severe core damage event.2 Thus, I dispute the assertion, made at page 11 of the Staff's Environmen-1 Eeg Testimony of Gordon Thompson at 8-9.

2 Note.that a cask drop was included under Class 7, " Accidents to Spent Fuel Outside Containment", of the accident classifica-  ;

tion scheme established in 1971 under 10 C.F.R. Part 51. Under j I

this classification scheme, it appears that only' Class 9 covered I what are now described as severe accidents.

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l l tal Assessment, that a zircaloy cladding fire is an event beyond I

the design basis. 1 I

I also dispute the Staff's general assertion that a zircaloy I cladding fire initiated by a beyond design basis accident is not I A cladding fire could be  !

a " reasonably foreseeable" event.

initiated by several mechanisms, whose probability is uncertain but is comparable to probabilities of severe core accidents which I-have motivated the NRC to alter-its regulations in areas such as emergency planning, hydrogen contr.ol, and equipment qualifica-tion.

In summary, a zircaloy cladding fire at VY could result from a range of reasonably foreseeable accident initiators encompass-ing design basis events, beyond design' basis events, and severe accidents. The consequences of a such cladding fire could range 1

from fuel damage, increased worker exposures, and contamination l of the reactor building, to catastrophic contamination of a large portion of New England.3 Avoidance of this risk should be a pri-mary consideration in weighing the proposed reracking alternative  ;

1 against the alternative of dry cask storage.

B. Other Benefits of Dry Cask Storage In evaluating the weight of the environmental benefits con-ferred by dry cask storage, accident risk avoidance is by far the 3 A fire severe enough to release long-lived radioactivity  ;

from the spent fuel pool to the atmosphere could also be accompanied by a core melt with its own attendant releases. How-ever, it should be noted that a substantial radioactive release from the spent fuel pool could occur without damage to the core.

Eeg Testimony of Gordon Thompson at 9.

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. . I most important factor.4 However, dry cask storage also has other q environmental advantages. As discussed in the NRC's recently l

proposed dry cask storage rule, one of the benefits of dry cask q d

storage is that it decreases reliance on active cooling systems. j In addition, "the potential for corrosion of the fuel cladding and reaction with the fuel is reduced, because an inert atmo-sphere is expected to be maintained inside dry spent fuel storage casks." 54 Fed. Reg. 19,379, 19,380 Col. 3 (May 5, 1989). Of l

course, both of these operational advantages nave environmental I

benefits in that they result in a reduced potential for occupa-tional exposures.

Aside from the relatively uncertain potential under the wet j

! 1 l storage alternative for increased occupational exposures due to 1'

malfunction of spent fuel cooling systems or fuel cladding corro-sion, I agree with Vermont Yankee's experts that over the l lifetime of Vermont Yankee, total occupational exposure would be approximately equal for the alternatives of dry cask storage and spent fuel reracking.5 Both measures require initial placement l of spent fuel in the pool, storage for a number of years, and ultimate transfer to casks, either for storage or shipment offsite. If Vermont Yankee implemented the dry cask option, it would presumably transfer the oldest and most decayed spent fuel 4 I emphasize here that the alternative that I propose -- a combination of dry cask and low-density pool storage -- would completely eliminate the risk of an autocatalytic zirconium reac-tion in the spent fuel pool.

5 San Testimony of Donald A. Reid, et al., at 13.

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v to the casks, thereby minimizing _ occupational' exposures.and maxi-

.mizing the amount.of fuel that could be placed in-each cask. In addition, the NRC has encouraged cask vendors to design. casks

that will also be suitable:for shipping, thereby eliminating the need to make an additional transfer of the fuel for-transport

. purposes. 54 Fed'. Reg. at 19,382, Col. 1 In its testimony, Vermont Yankee lists a number of. environ-

-mental costs associated with dry cask storage, namely the increased use of steel, concrete, water, and land. None of these environmental costs is significant. Moreover, Vermont Yankee has not suggested, nor is it evide t, that the dry cask storage facility could not be constructed within the' confines of the.Ver-mont Yankee site.-

III. Timing of Design and Review In explaining its rejection the dry cask alternative, the NRC Staff stated that "there is little likelihood" that design, construction and licensing of a-dry cask facility'could be com-pleted in time to meet the need for additional capacity.

Affidavit of Frederick C. Sturz at 9. Vermont Yankee postulated a time frame of between four and eight years for implementation of the dry cask alternative. Testimony of Donald A. Reid, et al., at 11-12.

1. I am aware of no fundamental reasons, nor have'NRC Staff and VY given any, why'the process of designing, licensing, and installing a dry cask storage facility should take any more time than a year. Unlike many other aspects of nuclear power plant

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design, which typically involve the interaction of complex sys- ]

1 tems, dry cask storage is a relatively simple technology. More-over, as demonstrated by the recent proposed rule, the NRC is now ]

ready to give generic approval for use of approved cask designs.

i 54 Fed. Reg. 19,379. Even if that rule were not in place at the j 1

time'of licensing review, individual review of a cask design i

should not be very time-consuming, given the fact that the NRC is 1 I

already familiar with a number of designs. According to the NRC Staff's responses of March 14, 1989 to NECNP's First Set of 1

Interrogatories (p. 12), the NRC has completed its review of at  !

least one cask designed specifically for BWR fuel. The design of l

a concrete pad and shelter to house and possibly shield the casks i is a simple engineering task which should not be difficult for the NRC to review.  !

In short, with some sense of urgency and cooperation between the licensee and the NRC Staff, the design and approval of dry cask storage could be accomplished in a few months. Construction of the facil'ity could be accomplished'. in a few additional months.  ;

Casks could be procured in a phased program extending over the remainder of the plant's operating life. There is no reason why the implementation of dry cask storage should drag on for years, as forecast by the NRC Staff and VY.

IV. Environmental Impacts of Reracking In its Memorandum, the Board asked whether it was required to consider the impacts of reracking de novo, rather than merely the incremental impacts yet to be experienced. As discussed

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i extensively in Section V of my Testimony, the racks.themselves 1

have a potential for environmental' impact that ik-independent of  ;

the potential for environmental impacts which arises from the i addition of 870 spent fuel assemblies to the pool. Even if VY 1 i

stores only 2,000 or fewer assemblies in the pool, the new racks l

significantly. impede the circulation of air or steam-following 1 water loss from the pool, thus increasing the risk of a cladding i

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fire. With the addition of 870 assemblies, however, that risk would be exacerbated.  ;

The Board also asked whether the preferred model of low- l density racks conforms to the racks at Vermont Yankee immediately prior to the current application, or the original racks for 600 assemblies. While I am not in possession of the design of the i

original racks or the racks approved in :1977, I believe that-the original racks were probably similar to one of the BWR rack i designs shown in Exhibits 3 and 4 to my direct testimony. Using ]

these or other racks, it is likely that 600 assemblies can'be accommodated without risk of a cladding fire in the. event of total or partial-water loss.6 On the other. hand, the racks designed to hold 2,000 spent fuel assemblies were probably of a

" closed" design, and probably had essentially the same safety i

disadvantages as the closed racks described in my testimony.

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6 Detailed analysis, supplemented by testing, could determine the. quantity of spent fuel which could be accommodated, given'a particular rack design, without risk of a cladding fire.  !

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AFFIRMATION AND OATH <

I declare, . under' penalty. of , perjury, that the - foregoing testimony-is true and correct to'the best of.my knowledge.~

~Gordon Thompson ,

Signed-and-sworn to.before me.this day.of-June, 1989 Notary Public 1

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l-Resume for

. Gordon Thompson December 1988 Professional Excertise Consulting scientist on energy, environment, and international security issues.

Education

  • PhD in Applied Mathematics, Oxford University,- 1973.
  • BE in Mechanical Engineering, University of New South Wales, Sydney, Australia,1967.

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  • BS in Mathematics and Physics, University of New South Wales,1966.-

l Current ADoolntments l

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  • Executive Director, institute for Resource & Security Studies ( IRSS ),

Cambridge, MA.

  • Coordinator, Proliferation Reform Project ( an IRSS project ).
  • Principal Investigator (1 of 3), Three Mlle Island Emergency Planning Study, Center for Technology, Environment and Development, Clark University, Worcester, MA.
  • Principal Investigator (1 of 3), NAT0 0ptions Study (a joint project of IRSS and the Institute for Peace and International Security).
  • Member, Board of Directors, Political Ecology Research Group, Oxford, UK.
  • Member, Advisory Board, Gruppe Okologie, Hannover, FRG.

Consultina Exoerience ( selected )

  • Greenpeace International, Lewes, UK,- 1988-present: review of probabilistic l

risk assessment for nuclear power plants.

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  • Ontario Nuclear' Safety Review, Toronto, Ontario,1987: review of safety aspects of CANDU reactors.
  • Washington Department of Ecology, Olympia, WA,1987: analysis of risk aspects of a proposed radioactive waste repository at Hanford.

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  • Lakes Environmental Association, Bridgton, ME,1986': analysis of federal 1

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2 regulations for disposal of radioactive waste. ,

  • Greenpeace, Hamburg, FRG,1986 : participation in an international study on

.the hazards of nuclear power plants.

  • Three Mile Island Public Health Fund, Philadelphia, PA,1983-present :

studies related to the Three Mile island nuclear plant.

  • Attorney General, Commonwealth of Massachusetts, Boston, MA,1984-  ;'

prescot : analyses of the safety of the.Seabrook nuclea? plant.

  • Union of Concerned Scientists, Cambridge, MA, 1980-1985 : studies on energy demand and supply, nuclear arms control, and the safety of nuclear installations. i
  • Conservation Law Foundation of New England, Boston, MA,1985 : l preparation of testimony on cogeneration potential at tne Maine f acilities of j Great Northern Paper Company.- l
  • Town & Country Planning Association, London, UK, 1982-1984 : coordination -l and conduct of a study on safety and radioactive waste implications of the j proposed Sizewell nuclear plant. ]

assessment of the cleanup of Three Mile Island Unit 2 nuclear plant.  !

  • Center for Energy & Environmental Studies, Princeton University, Princeton, NJ,1979-1980 : studies on the potentials of various renewable energy j sources. j
  • Government of Lower Saxony, Hannover, FRG, 1978-1979 : coordination and

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conduct of studies on safety aspects of the proposed Gorleben nuclear fuel j center. I i

Other Exoerience ( selected )

  • Co-leadership ( with Paul Walker ) of a study group on nuclear weapons l l

proliferation, institute of Politics, Harvard University,1981.

  • Foundation ( with others ) of an ecological political movement in Oxford, UK, l which contested the 1979 Parliamentary election.

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  • Conduct of cross-examination and presentation of evidence, on behalf of the Political Ecology Research Group, at the 1977 Public inquiry into proposed expansion of the reprocessing plant at Windscale, UK.
  • Conduct of research on plasma theory ( while a PhD candidate ), as an associate staff member, Culham Laboratory, UK Atomic Energy Authority, 1969-1973.
  • Service as a design engineer on coal plants, New South Wales Electricity Commission, Sydney, Australia,1968.

3 Publications ( selected )

  • New Directions for NATO (written with Paul Walker and Pam Solo), published jointly by the Institute for Resource and Security Studies and the Institute for Peace and International Security (both of Cambridge, MA), December 1988.
  • " Verifying a Halt to the Nuclear Arms Race", in F. Barnaby (ed), Verification Handbook. MacMillan Press, UK (in press).
  • " Verification of a Cutoff in the Production of Fissile Material", in F. Barnaby (ed), Verification Handbook. MacMillan Press, UK (in press).
  • " Severe Accident Potential of CANDU Reactors", Consultant's Report in The Safety of Ontario's Nuclear Power Reactors. Ontario Nuclear Safety Review, Toronto, February 1988.
  • Nuclear-Free Zones ( edited with David Pitt ), Croom Helm Ltd, Beckenham, UK,1987.
  • Risk Assessment Review For the Socioeconomic Imoact Assessment of the ProDosed High-level Nuclear Waste Recositorv at Hanford Site. Washington (edited; written with five other authors), prepared for the Washington Department of Ecology, December 1987.
  • The Nuclear Freeze Revisited ( written with Andrew Haines ),

Nuclear Freeze and Arms Control Research Project, Bristol, UK, November 1986. Variants of the same paper have appeared: as Working Paper No.18, Peace Research Centre, Australian National University, Canberra, February 1987; and in ADIU Reoort. Jan/Feb 1987, pp 6-9, University of Sussex, Brighton, UK.

  • International Nuclear Reactor Hazard Study ( written with fif teen other authors ), Greenpeace, Hamburg, FRG ( 2 volumes ), September 1986.

" "What happened at Reactor Four" ( the Chernobyl reactor accident ), Bulletin of the Atomic Scientists. August / September 1986, pp 26-31.

( written with Steven Sholly ), Union of Concerned Scientists, >

Cambridge, MA, January 1986.

  • " Checks on the spread" ( a review of three books on nuclear proliferation ),  ;

Nature.14 November 1985, pp 127-128. l

  • Editing of perspectives on Proliferation. Volume 1, August 1985, published by the Proliferation Reform Project, institute for Resource and Security Stu'Jies, Cambridge, MA.
  • "A Turning Point for the NPT 7" ADIU Recort., Nov/Dec 1984, pp 1-4, University of Sussex, Brighton, UK.
  • " Energy Economics", in J Dennis (ed), The Nuclear Almanac. Addison-Wesley, Reading, MA,1984

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  • 'The Genesis of Nuclear Power", l'n J Tirman (ed), The Militarization of High Ighnology. Ballinger, Cambridge, MA,1984.

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  • A Second Chance New Hamoshire's Electricity Future as a Model for tt)g .

Nation ( written with Linzee Weld ), Union of Concerned Scientists, Cambridge, MA,1983.

  • Safety and Waste Manaaement Implications of the S_izewell PWR ( prepared with the help of 6 consultants ), a report to the Town & Country Planning Association, London, UK,1983.
  • Utility-Scale Electrical Storaae in the USA : The Prosoects of Pumoed Hydro.

Comoressed Air. and Batteries. Princeton University report PU/ CEES "120, 1981,

  • The Prosoects for Wind and Wave Power in North America. Princeton University report PU/ CEES " 117,1981.
  • PJvdroelectric Power in the USA : Evolving to Meet New Needs. Princeton University report PU/ CEES " 11S,1981.
  • Editing and part authorship of " Potential Accidents & Their Effects", Chapter ll1 of Reoort of the Gorleben International Review. Dublished in German by the Government of Lower Saxony, FRG,1979 -- Chapter ill available in English from the Political Ecology Research Group, Oxford, UK.
  • A Study of the Consequences to the Pubile of a Severe Accident at a Commercial FBR located at Kalkar. West Germany. Political Ecology Research 3 Group report RR-1,1978.

Exoert Testimony ( selected )

  • US Department of Energy, EIS scoping hearing, Columbia, SC,1988: .

Appropriate scope of an EIS for new production reactor capacity.- j

  • International Physicians for the Prevention of Nuclear War,6th and 7th j Annual Congresses, Koln, FRG,1986 and Moscow, USSR,1987: Relationships I between nuclear power and the threat of nuclear war. .l
  • ' County Council, Richland County, SC,1987 : Implications of Severe Reactor j Accidents at the Savannah River Plant. _
  • Maine Land Use Regulation Commission,1985 : Cogeneration potential at facilities of Great Northern Paper Company.  !

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  • Interf aith Hearings on Nuclear issues, Toronto, Ontario,1984 : Options for Canada's nuclear trade and Canada's involvement in nuclear arms control. j
  • Sizewell Public inquiry, UK,1984 : Safety and radioactive waste  ;

implications of the proposed Sizewell nuclear plant.

  • Atomic Safety & Licensing Board, Dockets 50-247-SP & S0-286-SP, US l

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5 Nuclear Regulatory Commission,1983 : Use of filtered venting at the Indian Point nuclear plants.

  • US National Advisory Committee on Oceans and Atmosphere,1982 :

Implications of. ocean disposal of radioactive waste..

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  • Environmental & Energy Study Conference, US Congress,1982 : Implications of radioactive waste management.'

i Miscellaneous -

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  • Australian citizen.
  • Married, two children.
  • Resident of USA,1979.to present; of UK, 1969-1979. 1 l
  • Extensive experience of public speaking before professional and lay l audiences.

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  • Auther of numerous newspaper, newsletter, and magazine articles and book ' 'l re/lews. i l
  • Has received many interviews from print and electronic media.

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