ML19320B325

Intervenor Colemans Proposed Findings of Fact & Conclusions of Law on Contentions 2 & 6,Board Question 5 & away-from- Reactor Alternatives in Accordance W/Board 800509 Order & 10CFR2.754 & 2.710

ML19320B325
Person / Time
Site:	Salem
Issue date:	06/26/1980
From:	Van Ness S NEW JERSEY, STATE OF
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ML18082A697	List: ML18082A696 ML19320B325
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NUDOCS 8007100178
Download: ML19320B325 (20)

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\,j UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION

- Before the Atomic Safety and Licensing Board In the Matter of ) Docket No. 50-272

)

PUBLIC SERVICE ELECTRIC ) (Proposed Issuance of AND GAS COMPANY, et al. , ) Amendment to Facility

) Operating License No.

(Salem Nuclear Generating ) DPR-70)

Station, Unit 1) )

INTERVENORS-COLEMANS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON THEIR CONTENTIONS 2 AND 6, BOARD QUESTION 5 AND AWAY-FROM-REACTOR ALTERNATIVES Intervenors-Colemans hereby submit the attached proposed findings of fact and conclusions of law in accordance with the Board's Order of May 9, 1980 and 10 C.F.R. 82.754, S2.710.

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n k g Respectfully submitted, Q IJ3NRO - STANLEY C. VAN NESS, PUBLIC ADVOCATE F M30E>

-1 Off;ce cf tne Seatt.7 0;deti. g & Seni;e p C) Bran I -e BY: . ,cLt.cv i LJLiM.S, Cn L' SAU"..A T. AYRES 4 ASSISTANT DEPUTY PUBLIC ADVOCATE On the Pleadings:

Sandra T. Ayres, Assistant Deputy Public Advocate Menasha Tausner, Deputy Public Advocate Dated: June 25, 1980 80.07010/7F

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, -- i INTERVENORS-COLEMANS' PROPOS$D  !

FINDINGS OF FACT _AND CONCLUSIONS .

OF LAW ON THEIR CONTENTIONS 2 AND 6, BOARD QUESTION 5 AND AWAY-

'FROM-REACTOR ALTERNATIVES I. Proposed Findings of Fact .,

A. Introduction

1. Public Service Electric and Gas Company (herein-after " Licensee"), on its own behalf and as agent for Atlantic City Electric Company, Delmarva Power and Light Company, and Philadelphia Electric Company, seeks an amendment of its Facility Operating License No. DPR-70 for Salem Nuclear l Generating Station, Unit No. 1 located in Salem County, New Jersey. The proposed amendment would allow installation of new racks in the Generating Station's on-site Spent Fuel Pool (hereinafter "SFF"). This modification, or reracking, would i

expand the STP 's present storage capacity of 264 spent fuel l

f assemblies to a capacity of 1170 assemblies, by increasing the I density of storage.1

2. The proposed new racks would be a modular stainless steel structure, with open-ended, box-like individual storage ce'lls for each spent fuel assembly. Whereas the existing r&ck design has a center-to-center spacing between storage cells of 21 inches,. the proposed racks would decrease that spacing to _

10.5 inches. The four walls of each new storage cell would l Exhibit 6B, at 1-1

.; s consist of an inner shroud of stainless sceel, type 304, a

• center Boral sheet (boron carbide, B4C, in an aluminum matrix) and an outer stainless steel shroud, again type 304. The Boral would provide for neutron absorption.

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B. Re: Colemans' Contentions 2 and 6

1. Eleanor B. and Alfred C. Coleman, Jr., were granted permission to intervene in these proceedings,3 taising the following, among other, con ten tions : 4

2. The Licensee has given inadecuate consideration to the occurrence of accidental criticality due to the in-creased density or compaction of the spent fuel assemblies. Additional consideration of criticality is required due to the following :

A. deterioration of the neutron absorption material provided by the Boral plates located between the spent fuel bundles; B. deterioration of the rack structure leading to f ailure of the ,

rack and consequent dislodging of '

spent fuel bundles. l

6. The Licensee has given inadecuate consideration to qualification and testing of Boral material in the environment of protracted asso~ciation I with spent nuclear fuel, in order to validate its continued properties for i radioactivity control and integrity.

2 Exhibit 6B, at 1-1, 2-1, 2-10, 2-13 3

Order Follewing Special Prehearing Conference, dated May 24, 1978.

4 0ther contentions were dismissed as a resrlt of the Licensec's i motion for summar, disposition (See Order, dated April 30, 1979). l

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2. Brooks and Perkins, Inc., manufacture poison ,

materials and, in this case, has supplied the'Boral material.5 The Lackenby manufacturing firm is under contract to Exxon

. Nuclear Company (hereinaf ter " Exxon") to assemble the finished racks.6 Exxon, in turn, will supply the racks to ,

the Licensee, and was responsible for their design, engineering analyses and quality control during fabrication.7 Exxon also did the testing and criticality calculations in support of the integrity of the racking system.8 The Licensee has done no independent studies.9

3. Exxon's criticality analvsis, submitted with the Licensee's applicatior. concluded that K eff l0 is lower than the .95 criteria accepted by the Nuclear Regulatory Commission (hereinafter "NRC") for spent fuel storage in high density racks. Those calculations, however, and the NRC Staff's accord with their conclusions, were credicated upon the intecrity of the Boral in the proposed racks. According to the Staff, the Keff of .95 in relation to the reracking of 5 Exhibit 63, at 2-13; Tr 545 l 67 ; 347 1 1

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Tr 602 i

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See Exhibit 5; Exhibit 63, at 2-1 1 9:7 581 10 Ke 5 or K affective is the measure of the approach toward criticality. For criticality to occur, Keff must ecual 1.0.

(Exhibit 6B, fn at 2-1)

- the Salem StP is a function of how much Eoron is in the racks.ll In short, as a Staf f witness pointed out, "[t]here has to be f

a minimum amount of boron in those racks to maintain the ef f ective below .95."12 Given the increased density of the new storage array, that minimally required areal density of boron between f uel assemblies is the 2.41 x 1021 boron-10

atoms per square centimeter created by the two Boral sheets.13 Thus, irrespective of any boron in the pool water,14 from a criticality standpoint it is imperative that there be no impeachment of the Boral material during the intended useful life of the modified SFP.

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4. Yet, Boral, like all poison materials is subject 4 to degradation depending upon its environment.15 The relevant i

llExhibit 6B, at 2-1, 2-2 l

12Tr 658 5 13Id.; Exhibit 6B, at 2-1, 2-2 14The Salem SFp water is borated with borid acid to a concentra- l tion of approximately 2000 ppm in order to be compatible with, and not dilute the reactor cooling water which it contacts during refueling. (Tr 445) At the hearings, Exxon suggested that ,

because of the boron in the SFP water, all Boral might be lost without criticality occurring. (Tr 557) However, no calculations, or c:her verifications appear in the record in support of this .

anomolcus position, which does not logically flow from the NRC Staff analysis cited above. Indeed, Exxon admitted that it did not account for affect on criticality resulting from the presence of boron in the SFp water in'the calculations submitted by the .

Licensee for NRC review. (tr 550)

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Moreover, and in stark contra- l diction, the same Exxon witness admitted at one point that if all or part of the Boral is lost, this "certainly would have a j serious impact. on criticality. " (Tr 556) '

15 Tr 624 1

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environment in this case is the borated SFP water.16 Corrosion occurs when Boral is exposed to a boric acid SFP environment.

, This problem, not " fully expected" in the words of Exxon,17 came to. light recently at the Monticello Nuclear Generating Plant SFP.

In summary, leaks developed in a number of the storage cells at Monticelle, and when the Boral was exposed to the borated pool water aluminum oxidation and corrosion resulted.18

5. According to Exxon, the welding procedures used during fabrication of the racks proposed for the Salem SFP make them ' leak-tight' , and overcome the Monticello problem. Upon closer examination, E :xon's precise, and less extravagant, claim is that there is a 95% leaktightness with a 95% confidence level.19 When pressed further by the Board, Exxon interpreted this to mean, leaks in up to 30 cells could be anticipated. 20 And, even this claim is questionable whare it is based upon only one helium check of the completed cells,21 and obviously not on experience.

In short, if the proposed reracking proceeds, corrosion will vccur in ap to 3 0, and perhaps more, of the storage cells.

'16 Tr 448; see fn .4, supra.

17 Tr 628; In fact, the problems were "new."

(Tr 626-627)

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Exhibit 63, at 2-13 19 Tr 458, 493, 599; see also Exhibit 63, at 2-13 '

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20Tr 770 71

-Tr 493

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Moreover, the corrosion will most likelv extend to all four Boaral'olates in the walls of each affected cell.22

, 6. It is sienificant to realize that the use of stainless steel clad Boral in a boric acid SFP environment for an extended oeriod of time, and in coniunction with a still relatively novel high density storace arrav,23 is essentially experimen tal. This is obvious from the record. None of the longer term uses of Boral mentioned by the Licensee, Exxon or the NRC Staff involved borated SFP water.24 Furthermore, past experience with Boral in an unborated environment has not even come close to the 40 year time-frame .being addressed in this case.25

7. Clearly, the impacts of an " experiment" with Boral use over an extended period and in the f ace of real corrosion problems, as proposed in this case, are highly speculative and shrouded with doubt. The full, longer term results of the Monticello incident are not yet in. And, the Licensee's con-l clusion that the occurrence of corrosion will have little or  !

no affect on the Boral's neutron absorbing capacity for the next 40 years is based soley upon Exxon's brief one-year corrosion study, and extropolation of its necessarily limited 22 Tr 617, 613 23 Tr 1062, 1064 24 Exhibit 6B, at 2-2; Tr 592, 603, 680 25 Compare Tr 680 with Tr 417, 418, 866 through 873

findings to a 40 year period.26 The magnitude of the difference between the study period and the tine-frame in which the study -

findings are predicted to apply, alone destroys confidence in i

the conclusion by extropolation. Indeed, in response to questioning by the Board on a related matter, an Exxon withness '[

admitted (during an obviously evasive dialogue with the Board) i

. that it would not be " judicious" to rely upon Exxon's corrosion report and the mere one-year study it reflected, to conclude i that there would be no problem in the long run if the Boral  ;

sheets in the storage cells were indiscriminate 1y exposed to l the boric acid pool environment.27 At one point he went so

l far as to state

I'm saying based on our one-year test

. program I cannot conclusively say that every single possible effect due to noralperformanceinaboricacig8 environment has been identified.

At other points he noted that corrosion arablems had not been Co. Tale telv out to rest bv the one-vear studv and that unknown cuestions remained as to the 30 or 40 year oerformance of

- Boral ex=osed to borated pool water.29 1

l 26 Exhibit 5: Tr 582, 680 .

l 27 Tr 619 throuch 630 l l

28 ~

Tr 630 29 .

Id. '

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8. The proponents of reracking invalidly insist that -

when corrosion occurs it should be considered only as an occasional inconvenience to be resolved by venting. This ignores the obvious lbuitations of Exxon's leak and corrosion tests described above. It focuses only on the immediate, descrete problem of eliminating the swelling caused by gas pressure within the storage cell walls,30 and fail to recognize the legitimate concerns with the integrity of the Boral, particularly over the long term, after the leak and venting have exposed it to the boric acid environment and corrosion. This short-sichtedness , and resultinc failure to deal with the most critical question of continued Boral oerformance, is exemolified by the Licensee's position with recard to use of corrosion damaged storage cells. While cells damaged before spent fuel has been inserted purportedly will not be used thereaf ter, the Licensee would not say that such use was impossible, and inadviseable.32 Most significant 30 The oxidation of aluminum at Monticello generated hydrogen gas, and cressure from the gas build-up caused sewlling in the storace cell wall. This was relieved by venting the gas. (Exhibit 63, at 2-13) 31 The ventinc crocedure also has risk implications where it con temolates activity, including use of tools which might be droceed, in close orcximity to stored fuel assemblies. In fact, because of the risks of periodic venting af ter the racks are in use, one NF.C Staff witness would pref er venting all cells before installation. (Tr 719,. 720) 32 Tr 684 is the L'icensee's clear intention to leave in place spent fuel ,;

assemblies stored in corrosion damaged storage cells,33 possibly i

for more- than 30 years depending upon the economic advantages 4

to the Licensee. This is patently unacceptable in the face of legitimate questions as to the continued integrity of Boral

.1 once exposed to the borated pool waster.

9. The Licensee's proposed surveillance and monitoring l program is similarly infirm. Because of the Licensee's failure l l

to acknowledge the potential risks of Boral use in borated SFP

. water, the program is fundamentally defective. Only fifty i

poison coupc.is would be depicyed in the SFE, to test for corrosion effects by visual observation and weiching, a year after the racks are installed and every two years thereafter. Such a program is clearly designed as an extension of Exxon's experiments, not to detect and protect against Boral failure in individual cells.35 Specific storage cells will be-tested,'with a dummy assembly, only at the time fuel assemblies are to be inserted, and only to see whether swellinc in cell walls will crevent insertion.36 Swelline will be detected in storage cells already housing scent fuel only when an attemot 33 Tr 496, 497 34 Tr'417, 418, 866 through 873 -

35 Tr 513, 586 36 Tr-580 3

o to remove an assembly fails. In short, as adcitted by the ..

Licensee, no one will know if there is a corrosion problem in

cellswherehualassembliesarelocated, and possibly impeach-4 ment of the Boral's capacity to absorb neutrons, until removal is attempted.37 And, as noted above, it is possible under the proposed licensing amendment that this awareness will not occur for 30 to 40 years. Finally, the Licensee has no standards for, or plan of action- if coupon specimens indicate that boron particles are being dislodged, nor clear procedures, indeed direc tion, f or noticing the NRC, C. Re

Board Question 5

1. During the course of the hearings, the Board posed the following question:

In the event of a gross loss of water i frcm the storage pool, what would be the dif f erence in consequences between these occasioned by the pool with i expanded storage and those occasioned by the present pool?

2. The record to date is inadequate to provide a satisfa :: 7. answer to this question. The missing element, identified in the April evidentiary hearings, is a calculation i which could be done fairly easily and within a time-frame which is-manifestly reasonable. All of the anlyses presented during the hearings on the above question involved the propogation of a 37 Tr-761 i

38 Tr 512-513, 516, 684 4

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" zirconium fire" as an intermediate step tbward potentially i untoward consequences.39 As Dr. Benjamin, an NRC Staff witness, Pointed out,'there are uncertainties as to the effect of the i i'

? proposed SFP configuration on propogation of a zirconium fire.40 {

After summarizing bases for such doubts,41 he indicated that a calculation to resolve them, one way or another, could be done by one person in a few months.42

3. It would be inappropriate to finesse a finding on ,

the issue of a zirconium fire through legalistic hair-splitting, l using terms like "significant possibility" to ind'; ate degrees of probability. 43 Dr. Benjamin eloquently responded to such  !

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an attempt by the Board, and indicated that the missing calcu-latica is indeed warranted. His testimony in this regard was the following:

_ believe that the possibility of this [

phenomenological occurence happening is i significant enough to warrant its inclusion i in a consideration of what the consequences {

micht be. t i,

et me restate what I just said. I think that the possibility of this occurrence of  ;

clad o.s:idation propogation is significant +

encugh to warrant its consideration in de- {

termining whether there is a dif f erence  !

be: ween one special { (sic) spatial] geome try ]

i 3C'For brevity, the term " zirconium fire" is used herein, as in l

Mr. pasedag's prepared testimony, to refer to a class of situa-tions, not all of which would be fires in a technical physio -

l chemical sense.

44r 1481 through 14 91 41 Tr. 14 85 42 Tr 142 2-14 83 43 See Tr 148 6-14 87

.... s e

and another. Scientifically we were  :

to ~ { (sic) wouldi approach it this way.

I would not say whether the probability of this occurring is greater than or

' less than 50 percent because it is not a [ stochastic] process - it is a process which has an answer and we need to find the answer before we can say what it is but I would say that it would ce ,

scientifically correct to include as a conservative possibility in evaluating the difference between fuel pools the possibility that this would occur.

Although another Staf f witness, Mr. Pasedag, f elt that further study is unnecessary, his testimony was based only upon a few days of reviewing litera ture,45 whereas Dr. Benjamin is an expert working in the field. In any event, the f'act that they were in disagreement over the existing data can lead to only one reasonable conclusien vir., more specific data is needed.

D. Re: Away-From-Reactor Alternatives (See Lower Alloways Creek Contention)

1. The design of the present Salem SFP rack allows for discharge cf spent fuel assemblies equal to 1/ 2 of the core upon annual refue'ing, plus a full core, 19 3 assemblies, if necessary for-core main enance operations.46 This limited capacity 44 Tr 14 EE-14 69 (emphasis added )

4 Tr 1533-1539 E

Ixhibit 6C, at 2; Tr 1062; The Licensee maintains that the re-servation of storage capacity for a full core discharge is not a saf ety measure, but merely expedient if a core maintenance opera-tion becomes necessary. (Tr E66) We do not agree that saf ety is not involved with regard to the reservation of such cacacitv.

If a core maintenance operation is called for, yet there' is n'o immedia tely available capacity in the SFP to house the f uel j assemblies in the core, this surely has safety implications. For I this reason, we fully support' reserved capacity for a full core, I and urge the NRC to require it. l l

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is' clearly premised upon the SFP at the reactor site being  ;

used primarily to store approximately 65 spent fuel assemblies in a11essJdense array for an initial and temporary decay period i

- of about a year or less before shipment of f-site. At most, if full core discharge capacity is ignored, only 2 64 spent fuel assemblies could be accommodated before the SFP reaches -

capacity in'approximately 4 years. 47 1 The Licensee' claims that if the existing rack configuration is maintained, at its 5th annual refueling date m

the Salem Generating Station would have to close down. 48 This is predicted because there has been no provision as yet for final, off-site disposition of the spent fuel.

Nor, according to the NRC Staff, is it foreseeable that such capacity,or alternative away-from-reactor storage facilities, will be available in time to meet the Licensee's spent fuel needs. 49

- Therefore, in contrast with the present design, the proposed reracking would permit higher density storage of spent fuel at the SFP at least until (i) about 1996 with a capacity for full core discharge; or (ii) about 1999 without capability af ter 199 7 to.s

Ore an additional full core. (1170 fuel assemblies in total) 50

3. I: should be'noted, however, that relevant federal Exhibit 6P,_at 1-1

• 4L_ r 10 26, 1030' 49 Exhibit L 6C, at 15-16

_50Tr ' 1105 4

e

,-3 - - c .s.-%,r.- u- *. + v

agencies are predicting interim away-from-reactor storage capacity by 1983 or 1984, and final depository could be available between 1988 and 1993.51 If these facilities proceed as forecast, there would be a considerable overlap with -

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remaining capacity in the Salem SFP if modified. Moreover, 4 k

according to the Licensee, the proposed licensing amendmen*

i t

would allow the higher density storage of 1170 spent fuel )

i assemblies at the on-site Salem GFP up to the 40 year life [

t span of its original operating license -- at the Licensee's (

I discretion which would be exercised primarily on the basis of its own economic advantage.52 Apparently then, despite the. ,

availability of off-site facilities, including final depository, the Licensee would nonetheless be at liberty to decide for

. e economic reasons alone to ship-off-site only sufficient numbers of fuel assemblies to maintain available cells for discharge of 1/3 of the core during annual refueling, and keep over 1000 [

assemblies at the reactor site. And, this would be irrespective of any crerriding benefits of away-from-reactor facilities from an encir:r. mental and safety standpoint.

4. The factors set forth above signal what should be rhe very limited purpose and scope of the proposed license amendment, and NRC's consideration thereof. The reracking 51 Exhibit 6C, at 15-15 52 Tr 517, 518, 866 through 873 1

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. proposal cannot be viewed as anything more than an alleged l expedient solution to a perceived need for interim spent fuel storage space at the reactor site pending nore appropriate away-from-reactor facilities. Thus, the Licensee's burden '

includes a showing that off-site alternatives are not feasible.53  ;

And, amendment approval, if at all, should be narrowly l

_ conditioned to meet only the need shown. It should not, as the Licensee would have it, stand for a blanket sanction of continued on-site, high-density storage for 40 years or so at the economic will of the Licensee, and irrespective of off-  :

i site alternatives should they become available and prove more -

appropriate-protection of the public health and welfare. ,

I[. PP.CPCSED CONCLUSIONS OF LAW A. Standards

1. In order to rule affirmatively on the proposed amendment to the Licensee's operating license, the following conclusions of law must be made:

- (a) that there is a need to expand the Saler SFP to meet the spent fuel needs of the Licensee which needs cannot be more appropriately met by away-f rom-reactor facilities; (b) that there is reasonable assurance 1

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53 C1., Exhibit 6C, at 15-16

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that the' activities authorized can be ..

conducted without endangering the health and safety of the public; and (c) . that the issuance of the requested ,

amendment will not be inimical to the -

health and safety of the public.

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2. In addition to the above, it is incumbent upon [

t this Board in considering the request for increased on-site i storage capacity at the Salem SFP to weigh, balance and apply

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the five factors listed in the NRC " Notice of Intent to i Prepare Generic Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel," including facters: (2) concerning the likelihood of amendment approval constitutinga commitment or resources which would tend to foreclose alternatives; and (5) with regard to the likelihood that-deferral or severe restrictions on licensing would result in substantial har.7 to the public interest.54 54 40 F.R. 42301,-September 16, 1975; This NRC policy l

directi:n was to provide the guidelines for review of specific SFp expansic applications pending generic consideration of the industry-wide problem of spent fuel disposition in the noticed envircnmental impact statement. While it is true that the

" Final Generic' Impact Statement on Handling and Storage of Spent Light Water power Reactor Fuel" (NUREG-0575) was released in August of 1979, the policy in the Notice of Intent has not yet been modified. Therefore, contrary to the Licensee's arguments, that policy remains in effect and is applicable to this Board's review of the instant amendment acclication. In the' Matter of Commonwealth Edison Comenny (Zion Station, Units I 1 and 2), February 14, 1980, slip opinion, at 11. l i o.

1 B. Amendment Denial .

1. The requested license amendment should be denied as i a matter of law. Based upon the existing record, there is no reasonable assurance'that the activities proposed can be conducted without endangering the health and safety of the public, or sufficient proofs that issuance of the proposed amendment will not be inimical to the health and safety of the public. This is so because:

(a) there has been inadequate testing of l the Boral material in a boric acid SFP environment and compacted storage array in order to validate its continued ability to absorb neutrons throughout the antici-pated life of the modified Salem SFP and protect against criticality; 1

(b) there has been inadequate consideration  !

cf the potential for criticality due to B:ral cerrosion and deterioration of its )

neutron absorbing capacity during the i

anticipated life of the modified Salem SFP; (c) the Licensee's proposed monitoring and surveillance program will provide inadequate i l

protection against criticality due to Boral -

l deterioration and inability to absorb l

neutronsin individual storage cells, particu-larly those which house spent fuel assemblies; and

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,a ...

i (d) there has been inadequate consideration -l 1

of the potential-for propogation of a l

" zirconium fire" in the compacted storage

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array proposed for the Salem SFP and, thus, I inadequate consideration of the consequences of such an incident.

2. In addition, the requested license amendment should  :

i be denied as a matter of law because: i (a) as proposed the amendment would permit a ,

modification of the at-the-reactor Salem SFP l I

which would result in a commitment of resources tending to foreclose the alternative of shipping spent fuel-assemblies from the Salem facility s

to away-from-reactor facilities, interim or final \

depository, once such facilities become available r

! and if they prove to be the more appropriate

! alternative from an environmental and safety standpoint; 1 i

{ (b) the Licensee has not shown, and in light of j i i the present storage capacity at~the Salem SFP l i cannot show, that denial of the requested amend--  !

t ment at this time, in order to further study tne  ;

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use of Boral and the matter of propogation of.a 1 circonium' fire, would result in substantial harm I r

to the public interest. ,

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4 C. Conditional Approval .

1. Although we oppose such action, if this Board is inclined to rule ~ affirmatively on the proposed license amendment, e

it clearly 'cannot pretend to reach the conclusions of law necessary to such a ruling without the following express conditions in the Order:

(a) the Licensee shall, in addition to its presently intended monitoring and surveillance program, develop for NRC approval a procedure for testing each individual storage cell periodically, particularly those cells which are housing spent fuel, to detect signs of corrosion and any deteriorarion of the Boral's capacity to absorb neutrons; (b) upon detection of a leak, corrosion or Soral deterioration in a particular s.torage cell wall, the Licensee shall report the incident to the NRC and not thereafter use the cell for st: rage of spent' fuel; (c) upon detection of a leak, corrosion or Boral deterioration in a particular storage cell housing a spent fuel assembly, the Licensee shall remove the assembly according to procedures .

approved by the NRC; (d) so long as other storage cells are available, the Licensee shall avoid use of cells adjacent to one where a leak, corrosion or Boral deterioration has been detected;

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e. ,

(e) the Licensee shall maintain throughout

-_the life of the modified SFP, capacity for }

t

. discharge of a full core, unless, upon I i

application by the Licensee, the NRC for good  !

i cause authorizes otherwise; I

(f) the NRC, shall perform the calculations necessary to de.termine any increased potential i

for orepogation of a zirconium fire created by the ccmpacted storage array and these hearings shall be reopened to pursue the matter of s

consecuences where such calculatiens show an

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increase in potential; and (g) this Order is expressely ccnditioned upon the reservation of authority in the NRC to reopen the licensing amendment whenever away-frcm-reactor ~ capacity to handle spent fuel beccmes available, and to order that spent fuel frcm the Salen Generating Station, Unit 1 be sent to such a facility or facilities upon evidence that the 4

away-frcm-reactor alternative is more appropriate than centinued, longer term high-density ~s torage at the Salem SFP frer an environmental and safety

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standpoint.

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