ML19029A510

Intervenor'S Response to NRC Staff'S Interrogatories

ML19029A510
Person / Time
Site:	Salem
Issue date:	08/11/1978
From:	-Neednewvalue MHB Technical Associates, State of NJ, Public Advocate
To:	Office of Nuclear Reactor Regulation
References
Download: ML19029A510 (13)

Text

L UNITED STATES OF AMERICA

'NUCLEAR REGULATORY COMMISSION IN THE MA'fTER OF Public Service Electric ) Docket No. 5~.12.._

and Gas c*ompany (Salem ) Proposed Issuance of Nuclear Generating Station, ) Amendment .to Facility Unit No. *l) * ) Operating License No.

DPR-70 INTERVENOR'S RESPONSES TO NRC STAFF'S INTERROGATORIES I. The following responses to the NRC Staff's first set of interrogatories, dated June 22, 1978, have been prepared by Gregory C. Minor of MHB Technical Associates, serving as technical advisors to the intervenor's counsel, and R. William Potter, attorney for the Public Advocate of New Jersey. The contentions referred to are the Coleman Contentions as documented in the Amended Petition to Intervene, dated May 11, 1978 by R. William Potter in behalf of Alfred and Eleanor Colem.an, ("the Colemans ") .

II. Coleman Contention 2 Interrogatory 1. Please define "deterioration" as used in Coleman Contention 2.

Response

As used here, "deterioration" relates to the degradation, alteration, and reduction (either gradual or rapid) of

the original quality or characteristics of the materials, components, or structures in question.

Interrogatory 2. Utilizing the definition given in Inter~ogatory 1 above, state how you believe that this "deterioration" will lead to accidental criticality in the spent fuel pool.

Response

The Licensee does not appear to have adequately con-sidered the possibility of degradation or deterioration of the poison material which is relied upon to permit the dense spacing of spent fuel bundles without ex-periencing criticality. Recent experience.with physical and mechanical degradation of Baral plates (e.g., Monticello and Connecticut*Yankee spent fuel racks) shows that the racks are vulnerable to deterio-ration despite the claims of quality contror and certi. f.ication.

. . (1)

The Licensee has not shown the possible effect on criticality of a depletion of the Boron Carbide material in several adjacent cells. These effects could occur gradually over the life of the plant.

1. Description and Safety Analysis, Attachment 1 to 11/18 letter, F. Librizzi (PSE&G) to G. Lear (NRC) pgs. 22-24 .

... 2-

.e Interrogatory 3. a. Using .the responses to Inter-rogatories* 1 and 2, please state if you believe the K~effective will be changed."

b. If the answer to (a) is yes, please state the .change in the K effective a:na~why you

• believe this change is significant.

Response: The Licensee's criticality analysis states that it considers a variance in boron loadings within the Baral Plates(Z), but the actual analysis appears to assurrie only the minimum value( 3 ) per specification. It is possible for local changes in boron density in de-graded cell structures to reach values below these assumed minimums and thus change the value of K eff.

Interrogatory 4. a, Are there any other factors which you believe the Staff or Licensee. has not given adequate consideration to in determining accidental criticality in the spent fuel pool?

b. If the answer to (a) is yes, please identify those factors and state the reasons for your asse~tion that consideration was inadequat~.

2. Description and Safety Analysis, Attachment 1 to 11/18 letter, F. Librizzi (PSE&G) to G. Lear (NRC) pg~ 13.

3. *Ibid., pgs. 14 and 43 show two different minimum values of* Boron density.

.,3-

Response: The Licensee has not adequately described the sensitivity to variation in parameters which impact K-eff and thus accidental criticality. Possibilities are:

e Minimum Boron density to cause K eff = .1.0.

e Effect on K ef f of upper grid spacer damage

. \ which would permit minimum separation of cells (i. e ~, center to center spacing of 9" in a local region) .

o Effect of .missile impact producing reduced spacing of cells and/or shearing off upper extensions allowing damaged cells to settle together. (The ~icensee's descrip~ion and drawings are inadequate to determine the po-tential consequences of this hypothesized failure.)

o The effect on K eff of 2 or more fuel bundles failing to be inserted f~lly into the cells due to distortion or swelling of the cell walls.

e The accidental lifting and/or tipping of a module with the handling crane.

• The effect of analysis mentioned but not yet completed (e.g., seismic analysis and bundle.

drop accident) .< 4 ).

III. Coleman Contention 6 Interrogatory 5. a. Please define the term "qualifi-cation" as used in Contention 6.

4. Descripti~m and Safety AnaI"ysis .. Attachmen*t 1 to 11/18 letter, _F. Librizzi (PSE&G) to G. *Lear (NRC) pgs. 34 & 36.

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b. Please define the term "testing" as used in Contention 6.

Response: In this context, "-qualification" may be taken to mean verification and demonstration of the ability of a material, component, system, or concept to comply with the full range of conditions required for a given application. As used here, "testing" implies the physical demonstration that a material, component, system, or.concept is qualified.

Interrogatory 6. Identify the areas where the Licensee and Staff have not given adequate consideration to the qualifications of B'oral material in an environment of protracted associ~tion with ~pent nuclear fuel.

Response: The Licensee's safety analysis speaks of discharging 18 years of spent fuel into the new spent fuel racks and the life of the plant may be '30-40 years.

But there is insufficient experience or testing with Boral plate in a spent fuel environment to show that it is qualified for this long-term application in this environment.

Interrogatory 7. Identify the areas where the Licensee and Staff have not given adequate consideration to the testing of Boral material in an environment o'f protracted association with spent nuclear fuel.

Response: Present experience with hi.gh exposure spent fuel storage in pools is less than 15 years(S) and this is not in a high density configuration. Per-haps after 30-40 years of observation of the in-pool specimens( 6 ) it will be possible to draw conclusions on the qt1alification of spent fuel materials and construction. Presently the materials have not been fully tested for this application.

Interrogato~. Please s.tate what you believe to be adequate "testing" of the Baral material as it relates to Contention 6.

Response: The absence of long-term *data on Baral ma-terial in a spent fuel environment can be corrected through experimental tests over a_long period of time.

It may be creating a problem by making the test bed be dozens of rtuclear reactors with denser storage pools under the premise of solving the problem of where to send the spent fuel. If a generic problem with aged Boral plates was later discovered, the many pools in-volved would have to be at least partially emptied.

This would create an even more difficult problem of where. to ship the spent fuel.

5. A.B. Johnson, Utility Spent Fuel* Storage Experience, April 1978.

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6. Description and Safety Analysis, Attachment 1 to 11/18 letter, F. Librizzi (PSE&G) to G. Lear (NRG), pg. 24 .

e e Interrogatory 9. Please state what you believe to be adequate "qualification" of Boral material as it relates to Contention 6.

Response: Proof of Boral materials ability to with-stand the environment of a .dense spent fuel storage i;,.

pool for.the life of the reactor without degradation of its necessary qualities would constitute adequate qualification. Some techniques developed to comply with the aging requirements of Reg. Guide 1.89 ( 7 ) may also be useful here.

Interrogatory 10. a. Do you believe that protracted association of Boral material with the spent fuel will affect the properties of the Baral material for reactivity control and its integrity?

b. If the answer to (a) is yes, please state the reason for your assertion that the properties of Boral material will be affected.

Response: Present use of Baral has shown it is subject to problems of manufacturing defects and handling abuse.

If these or other factors (such as corrosion, water chemistry, long-term exposure to radiation, or aging)

7. Reg Guide 1.89, Qualification of Class IE Equipment for Nuclear Power Plants, November 1974.

prove to cause long-term deterioration or degradation .

of its characteristics, it could have a serious impact on the present storage schemes. Until this is proven to not be a problem, it should remain a concern of the NRC, . the Licensee, and the interve1tors. To* proceed with this licensing amendment without such proof is unwise.

Interrogatory 11. a. Do you believe that radiation will damage the Baral material so as to affect its prop-

• erties for reactivity control and integrity?

b. .If the answer to (a) is yes, please state the reason for your assertion that radiation will damage the Boral material.

c. Do you believe that corrosion will damage the Boral material so as to affect its properties for-reactivity control and integrity?

d. If the answer to (c) is yes, please state the reason for your assertion that corrosion will damage the Boral material.

e. If your answer to (a) and (c) is no, please identify the other means by which you assert the Baral material will be damaged so as to affect its properties for reactivity control and integrity~

f. If your answer to (a) or (c) is yes, are there any* other means by which you assert damage can be done to the Baral material so as to affect its properties for reacti-vity control and integrity?

e*

Response: The intervenor '.s *contention .deals with the inadequate consideration of qualification*and testing of the long-term (or continued) properties of Baral material in a densely packed spent fuel pool. The re~ponses to Interrogatories 7, 8, 9, and 10 have dealt with the basis for the contention. The answer to Interrogatory 11 is ooritained in the above responses.

The intervenors have not intended to detail methods of failure, but to show instead that there are insufficient data to .conclude that long~term characteristics of the Baral material are known for a spent fuel pool environ-ment. W~thout these data the safety analysis cannot claim that (over the life of the plant) the cells:

"provide sufficient neutron absorption with the boron carbide contained in the Baral sheet to allow spacing of spent fuel in a 10 3/8 inch by 10 3/8 inch array." (8)

IV. Coleman Contention 9 Interrogatory 12. Please define the phrase "inadequate consideration" as us.ed in Coleman Contention 9.

Response: In this situation, the term "inadequate consideration" means that only cursory or incomplete addres~ing of the option ~as presented in the available documents.

8. Description and Safety Analysis, Attachment 1 to 11/18 letter, F~ Librizzi (PSE&G) to G. Lear (NRC) pg. 5.

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e e Interrogatory 13. Utilizing the response in Inter-rogatory 12, state how the Licensee and Staff have given in-adequate consideration to the "no action" alternative for the Licensee's application.

Response: The Licensee's application and Safety Analysis do not address their proposed action if the NRC should rule unfavorably or delay the ruling* beyond the January, 1979 deadline, which the Licensee sets forth in the Safety Analysis. C9 )

The Analysis rules out transshipment as illogical, AFR's as unaccessable, and status quo as costing too much for replacement power after 1983~ These may accurately represent the facts as perceived by the Licensee, but they do not identify a viable*option which, realistically, must exist. For example, the Morris Operation has applied for an expansion to 1850 MTU but this is not mentioned as an alternative.

9. Description and Safety Analysis, Attachment 1 to.11/18

. lett~r, F. Librizzi (PSE&G) to G. Lear (NRC) pg. 5.

V. The above responses to the interrogatories represent the truthful answers to the best of my belief. Because the data supporting. the Licensee's application are incomplete, and the Final Generic EIS on Spent Fuel is not issued, it may be ne~essary to supplement these responses as additional information becomes available.

Respectfully submitted,

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GREGORYC. MINOR . .

8 /11 /78 DATE I . I e e RELATED CORRESPOl\"'DENCE

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NUCLEAR REGULATORY CCMMISSION Before the Atcmic Saf~ty and Licensing Board In the Matter of PUBLIC SERVICE ELECTRIC & Docket No. 272 GAS Ca1PANY Proposed Issuance of Arrendrnent.to Facility (Salem Nuclear Generating Operating License No. DPR-70.

Station, Unit No. 1)

CERTIFICATE OF SERVICE I hereby certify that copies of the attached "Intervenor's Responses to NRC Staff's Interrogatories" were served on the persons listed on the attached service list by United States mail (first class, postage prepaid) this 18th day of August, 1978.

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\Jtfl--:LcliL;t.~ f ,cf_f/-f c.-.,,

. SANDRA T. AYRES Assistant Deputy Public Advocate Dated: August 18, 1978 i*.

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I I SERVICE LIST I

Gary L. Milkollin, Esquire

• Barry Smith, Esquire Chall:nian, Atomic Safety and Office of the Executive Licensing Board Legal Director 1815 Jefferson Street U.S. Nuclear Regulatory Corrmission

.Madison, Wisconsin 53711 Washington, D.C. 20555 Mr. Glenn 0. Bright Mark L. First, Esquire

.r-Ernber, Atomic Safety and ceputy Attorney Gen=ral

• Licensing Board Panel cepartrrent of Law and U.S. Nuclear Regulatory Com'nission ,,,Public Safety Washington, D.C. 20555 36 W. State Street Trenton, New Jersey 08625 Dr. James C. Lanlb, III

t-Erober, Atomic Safety and Richard Fryling, Jr., Esquire Licensing Board Panel Assistant General Solicitor 313 Wcxx1haven Road

• Public Service Electric Chapel Hill, N.C. 27514 and Gas ComPanY 80 Park Place Newark, New Jersey 07101 Chai:rman, Atomic Safety and Licensing Api;::eal Board U.S. nuclear Regulatory Comnission Eleanor G. Coleman Washington, D.C. 20555 Alfred C. Coleman 35 "K" Drive Pennsville, New Jersey 08070 Chairman, Attrnic Safety and Licensing Board U.S. Nuclear Regulatory Corrmission Office of the Secretary Washington, D.C.. 20555 Cocketing and Service Section U.S. Nuclear Regulatory Cornnission Troy B. Conner, Jr. , Esquire . Washington, D.C. 20555 Suite 1050 17 Pennsylvania Ave., N.W.

Washington, D.C. 20006 William c. Horner, i::.squire 67 Market Street Salem, New Jersey 08079 Ruth Fisher

'Ihe Sun People - Alternate Energy Advocates South cennis, New Jersey 08245

• Advance copy mailed on or about August 11, 1978 *

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