ML19029A559

Licensee'S Answer to Lower Alloways Creek Township'S Further Specification of Contention 8

ML19029A559
Person / Time
Site:	Salem
Issue date:	06/30/1978
From:	Wetterhahn M Conner, Moore & Corber, Public Service Electric & Gas Co
To:	Office of Nuclear Reactor Regulation
References
Download: ML19029A559 (7)

Text

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,,,_. e &/3e}1f1 e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

PUBLIC SERVICE ELECTRIC & GAS ) Docket No. 50-272 COMPANY, et al. ) (Proposed Issuance

) of Amendment to (Salem Nuclear Generating ) Facility Operating Station, Unit 1) * ) License No. DPR-70)

LICENSE~'S ANSWER TO LOWER ALLOWAYS CREEK TOWNSHIP'S FURTHER SPECIFICATION OF CONTENTION 8 By letter dated June 22, l97B, counsel for Lower

. 1 I Alloways Creek Township ("LACT"),- an intervenor in the captioned proceeding, informed the presiding Atomic Safety and Licensing Board ("Licensing Board") that LACT had rejected a settlement off~r made by Public Service Electric & Gas Company, Licensee in the captioned pro-ceeding. The letter also informed the Licensing Board that LACT had abandoned Contention 7 and contained the following suggested language for Contention 8:

Under the proposed modification, there will be increased reliance on the Residual Heat Removal Sys-tem. The increased reliance and probability of overload will les~

sen the ability of. the system to perform its safety back-up function.

The probability and consequences of failure under increased load.should be determined.

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~/ Accompanying the letter was a Notice of Appearance *\

for Carl Valore, Jr. on behalf of Lower Alloways Creek Township.

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As discussed below, Licensee submits that LACT has still not given sufficient specificity to proposed Contention 8 and i t should not be admitted as an issue in the pro-ceeding.

The Licensing Board's Order Following Special Pre-hearing Conference dated May 24, 1978 at 4, stated that 11 the Township shall submit

• the language of its Contentions 7 and 8 in final form for decision." The Licensing Board's Memorandum and Order of April 21, 1978 at 4, stated:

• Contentions 7 and 8 appear to contain subject matter which could possibly serve as the basis for a valid con-tention if developed and clarified.

In view of the specificity of the Licensee's description of the pro-posed cooling system, it is not reasonable to contend that the Li~

censee has 'failed to consider' the impact on that system of the addi-tional spent fuel. If the Petitioner objects to some.aspect of the pro-posed cooling system, it should so inform the Board. The Board has a similar view with respect to Con-tention 8.

As originally drafted by LACT, Contention 8 reads as follows:

The Licensee has failed to demon-strate that increased reliance

-1 on the Residual Heat Removal Sys-tem to provide coolant for the spent fuel under the proposed modi-fication would not lessen the

• ability of that;. system to perform .

its safety functions while serving as a backup heat sink for the spent fuel.

Intervenor has failed to remedy the defects which the Board found in the original statement of Contention 8 and, thus, it should not be admitted as an issue.

Initially, the contention is factually incorrect and bears no relationship to tl:le design of the Salem 2 I Nuclear Generating Station, Unit l.~ The Residual Heat Removal ("RHR") System does not serve as a backup heat sink for the.spent fuel. LACT does not give any specificity regarding its assertion that .the RHR system performance would somehow be affected. The spent fuel cooling system utilizes its own heat exchangers which reject heat to the component cooling water system and there is no direct connection to the Residual Heat Removal System. Thus there cannot be "increased reliance on that system" as asserted by LACT.

Moreover, because of the design of the spent fuel cooling system for Salem Nuclear Generating Station Unit 1, it was analyzed without reliance on even the component cooling water system:

~/ *see Iowa Electric Light & Power Company et al. (Duane Arnold Energy Center), ALAB-108, 6 AEC 195, 196 (1973) for an example of the Atomic Safety and Licensing Ap-peal Board's affirmance of a decision rejecting con-tentions "which were lifted indiscriminately from petitions filed in other proceedings, since they are

• wholly inapplicable to the facility under consideration**

here." *

~ ..

• Since the cooling system is designed

• as a non-seismic Category I system, the applicants have provided re-dundant pool makeup water sources to ensure a reliable supply of.makeup water, i.e., four different sys-tems are available. However, to.

further ensure reliability, the following additional measures were taken. Valves were installed on existing spare nozzles on the re-fueling water storage tank for *

• bQth units. A portable pump will be provided with the capability to deliver 100 gallons per minute makeup water flow from one of the refueling water storage tanks di-rectly to the spent fuel pool.

The valves installed on the tank will be locked closed and capped, and will be under administrative control. The portable p:ump and hose will also be under *adminis-trative control to ensure constant and timely availability.

We have reviewed the system design, component classifications, and design codes for the spent fuel pool cooling system and find them acceptable.-1_/

The spent fuel cooling system design basis is un-ch~ged by the Spent fuel rack modification. The Descrip-.

tion and Safety Analyses, Spent Fuel Storage Rack Replace-ment, No. 1 Unit, evaluates fuel rod clad temperatures under the same design basis, hypothetical loss of forced

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coolant circulation conditions. Thus, should there be an instance where the Residual Heat Removal System be

_1_/ Safety Evaluation of the Salem Nuclear Generating Station, Units 1 and _2, dated October 11, 1974 at 9-7.

See also Response to NRC Questions 9.10 and 9.48 con-tained in Volume 7 of the Final Safety Analysis Report.

~/ See pp. 26-29.

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• required in case of an accident, because. the spent fuel I!

pool has been analyzed as not ~eguiring outside heat ex-

_,.-* 1 change, there would be, in that case, no interaction with i

the RHR system.

For these reasons, revised Contention 8 should not be admitted as an issue in this proceeding.

Respectfully submitted, Mark J.

Coun*sel

• Of Counsel:

Richard Fryling, Jr., Esq.

June* 30, 1978

UNITED. STATES OF AMERICA NUCLEAR REGUµATORY COMMISSION r Before the Atomic Safety and Licensing Board In the Matter of )

)

PUBLIC SERVICE ELECTRIC AND GAS ) Docket No. 50-272 COMPANY, et al. )

)

(Salem Nuclear. Generating )

• Station, unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of "Licensee's Answer to Lower Alloways Creek Township's Further Specification of Contention 8," dated June 30, 1978, in the captioned matter, have been served upon the following by deposit in the United States mail this 30th day of June, 1978:

• Gary L. Milhollin, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety . Licensing Board Panel and Licensing Board U.S. Nuclear Regulatory 1815 Jefferson Street Commission

• Madison, Wisconsin 53711 Washington, o.c. 20555 Mr. Glenn O. Bright Barry Smith, Esq.

Member, Atomic Safety and Office of the Executive Licensing Board Panel Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. James c. Lamb, III Mark L. First, .Esq.

Member, Atomic Safety and Deputy Attorney General Licensing Board Panel _Department of Law and 313 Woodhaven Road

• Public Safety Chapel Hill, N.C. 27514 Environmental Protection Section Chairman, Atomic Safety and 36 West State Street Licensing Appeal Board Panel Trenton, N.J. 08625 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Richard Fryling, Jr., Esq. Carl Valqre, Jr., Esq ..

Assistant General Solicitor Valore, McAllister, Aron Public Service Electric & Westmoreland

& Gas Company Mainland Professional Plaza 80 Park Place P. O.* *Box 17.§ Newark, N.J. 07101 Northfield, N.J~ 08225 R. William Potter, Esq. Office of the Secretary Assistant Deputy Public Advocate Doqketing and Service Section Department* of the Public Advocate U.S. Nuclear Regulatory

• Division of Public Interest Commission

• *Advocacy Washington, D.C.

Post Off ice Box 141 Trenton, New Jersey 08601 June D. MacArtor, Esq.

Deputy Attorney General Tatnall Building, P.O. Box 1401 Dover., Delaware 19901