ML18016A803

Comment on Cp&L Application Dtd 981223.Proposed Finding of No Significant Hazard Wrong & Must Be Rejected for Stated Reasons

ML18016A803
Person / Time
Site:	Harris
Issue date:	02/12/1999
From:	Warren J AFFILIATION NOT ASSIGNED
To:	NRC
References
FRN-64FR2237 64FR2237-00001, 64FR2237-1, NUDOCS 9902170248
Download: ML18016A803 (8)

Text

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ACCESSION NBR: 9902170248 DOC.DATE: 99/02/12 NOTARIZED: NO DOCKET ¹ FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH".NAME AUTHOR AFFILIATION WARREN,J. Affiliation Not Assigned RECIP.NAME RECIPIENT AFFILIATION NRC - No Detailed Affiliation Given

SUBJECT:

Comment on CPS L application dtd 981223. Proposed finding of no significant hazard is wrong & must be rejected for stated C reasons.,j A

DISTRIBUTION CODE. DS09D TITLE: SECY/DSB COPIES RECEIVED:LTR Dist: Public Comment on Proposed Q ENCL SIZE:

Rule {PR)-Misc Notice;.Reg G~

NOTES:Application for permit renewal filed. 05000400 E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL ILE CENT 1 1 NMSS/IMOB T8F5 1 1 0 C DR 15-B-18 1 1 RES DIR 1 1 RES/DRA/DEPY 1 1 RES/DST 1 1 EXTERNAL: NRC PDR 1 1 E

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Joint Comments of NC Waste Awareness & Reduction Nctisorh (N('ARN) and NC (:itizcns Research Group (NCCRG) l2 February 1999 Response to NRC proposed linding of "nv significant lurznrds" 64 FR 2237 at 223 tiff:,

I. I tow ciln sucll it fuiding be made in Itgh< of ihc fact that tlic cooling system for pools C and D which can bc filled with additioiviI highly radioactive waste under CP&L's proposal, cannot be N-stamped (ii<<m ii. col I 64 FR 223it)? Ilie Federal Register notice appc;us to give zero attaiysis of what a failure in this ay~rem couM do, but it appears tiiut CP& l. tuis already had a significant reduction in water level in its fuel pools at Harris, and this would in fact educe ihc niargin against boiling (and thc tiine to cxposc fuel) should it occur. cittier due iv ihe same cause as thc previous accident, or failure in the less-than-nuclear-quality (pci N stamp) cooling system.

2. A<<cvrding to CI'&t,'s presentation to ihe Orurige County (NC) Commission 2/9/99, CP&L hus yet to begin to design an actual cooling systeni fvr pools C and D. CP&L also has stated that thc existing I larris nuclear pLuit (Unit I) cooling water system lacks ihe capacity to cool pools C and D ifover I MBTU/hr oi'eat from spent fuel is in those pools. Giv<<n these facts, how can NRC certify as "no significant. hazard" a system wiu<<h de nvt exist, nnd has not oven begun to be designed?

3. Item iii, Column I of 64 FR 223tt. Identifie the usc of Hams Unit I coinponent cooling water (CCW)

I'or up iv 1.0 MBTU/hotirof heat load from additional radioactive spent fuel stored in pool C (or, D, according to the Federal Register notii~, id.) as an unrcvicwed safety question. Since this question is unrericwcd. how can it bc considered no signifiuuit hazard absent a review'/

4. Thc statenienLs about probability of an accident (item I of the 10 CFR 50.92 no significant Itazards considcrmon, col,2 64 FR 2238) arc plainly wrong. First, as pointed out by David Lochbaum in his I/2M~9 letter to the NRC Commissioners, lfyou kci Ti doing something with the same probability over and vver. whahcr it is moving spem fuel or playing Russian roulette, you clearly do inmcasc tiie probability of an accident (vr of shooting oneself, ln Russian roulette). 4715 additional fuel assemblics appear to be involved in CP&l.'s proposal, inaking thc cumulative number of assemblies involved more than double thenumber CP&L is now Jicensed iv store in it A and 8 waste fttel pools at Ihrris.

Second. ii'P&I.'s stateinenLs to thc Orange County (NC) Commissioners 2/9/99 are correct, most, or all of titese 4715 assembles may well be moved twice, CP&L declared that they would ship

. spent fuel that was at least 3 years ("old") after discharge from the reactor, and would only store spent nuclear fuel that was ai least 5 years old in pools C and 0 to reduce the he~ of cladding fires. This evidently means that ali fuel discharged from Harris ) itself will have to be moved once, to pool A, and perhaps again, to pool 8, spending at least 5 years before heing ntovei again, to pool C or D.

For spent fuel fiom CML's Robinson or Brunswick nuclear plants, ifit were shipped at "age" after discharge from those reactors, of 3 years but less than 5 years, the fbeI would bc unloaded in the cask loading/unloading pool at the north end of ihe Harris tuel building (near pools D and C) and then moved across those pools tv stvragc unt/I its -age" exceeded 5 years, and then moved back to pools C or D. Such acti vity implies possibly 9000 or morc fuel assembly movements. which could add nearly triple the number of fuel assembly movemcnts in thc stomgc building, That would mean nearly four times the potential for a fuel assembly drop, willithe aincndmcnt. A factor of nearly four increase in accident probability appears to be signi fi<<ani.

5. Thc proposed arialysis of a A>el assenibly drop appears io ignore the chance that the dropped assembly could daniagc or brcak loose the n<<uiron shielding beside another assembly, leading to accidental

- criticality or damage to morc than one fuel assembly. Thcsc appear to bc accidents beyond those mcndoncd as previously analyzed in the NRC's I/l3/99 Federal Rcgistcr notice; also the prolxtbility of such accidents is incrcascd by thc larger number of fuel assembly moves as noted above (item 4).

6. Thc rcquircment for at least 5 years after discharge for fuel io bc stored in pools C or D docs not appear to bc included in the Technical SpecNcations. Thus. the chance for a fitel cladding fire is increased (above pro, which ls the chance lf this amendment is denied), and a fuel cladding Qre does not appear to have been analyzed in the NRC's I/i3/99 Federal Register notice, 64 FR 2237. Unless such requirement, or whatever stricter and/or other rcquircincnts may be ilccessafy to avoid a cladding fire are included in thc Technical Specifications. they would not be enforceable.

7. I hc NRc's statement (64 FR 2239, col. 3, "Thermal-hydraulic and pool cooling") that "the pool temperature will not exceed 137 fdegrees f F, during the highest heat load conditions, appears io be wishful thinking absent a di>ign of, and an analysis of, thc additional cooling system capacity (CCW

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or other source) to cool pools C and 0 I'roin Hams I Wc bclicvc I tint, tu prevent a signilicant increase in the probability of an a<<cid nt froiu stored spent I'u<<l in pools C and/or D. a cooling and cleanup.

systcnt completely indcpcndciit ol'Harris Unit I, and <<omprising at least t>>o independent <<outing pathways. pumping systcnis. filtcrs and water supplies. nccds to bc in place. along with independent power supply (at least two dicscl gcn<<rators not associated with Harris I). to provide thc same level and cooling tliat would Iiave been there had Harris 2, with systems as described above, been of'rotection built. Otherwise. thc probability of an accident is in fact inure;Ised m two ways: By placing fuel cooling toads on Hams systems which they werc not designed for, and by increastng the prohtbilitv of an 1

accident involving Harris itself due to failures of tts component cooling and/or other systems due to 1

thc additional cooling demands and/or failures of thc cmtlng system for fuel pools C and or D. There appears to be zero indication that NRC staff has analyzed any of these contingencies, nor has COL provided in its application any rationales for switching f'rom cooling pools C and D independently of Harris 1 and its cooling, systems.

8. Both NRC and C pkL have evidently failed to analyze thc cladding Are causing potential of having spent fuel stored in a contiguration that so limits air cooling tltat, as described by Orange County's consultant Dr, Gordon Thompson, fires can bc caused when water is stilt covering the bottom of thc fuel assemblics, preventing convection cooling from the fuel building atmosphere, or greatly reducing it. This appears to be an accident yct to be analyzed. or anu! yzed properly (as Dr. Thompson stated 2/9/99 to the Orange County NC Commissioners) and the larger number of fuel assemblies allowed into pools C and D under COL's proposal would also increase thc conseqenccs of such an accident (more waste. morc fission products, more severe consequciuxs), In the absence of an cnforceabte license condition eliminating spent fuel that could overheat to such an event, this type of accident is possible in pools C and/or D.

9. increasing Ihc amount of spent fuel, full of highly dangerous 6ssion products and fissionable material, docs increase both thc probabily and the consequences of accidents. For example, the morc fuel stored, the greater thc risk that a dropped assembly will in fact strike stored fuel, und/or its supporting structure, and/or its neutron-absorbing shield {which COL relies on to prevent accidental criticality).

And thc more fuel present, the greater heat load that must bc dissipated to prevent overheating, and the greater atttount of fission products and toxic material (e.g. uranium) that could bc released in an accideilt.

10. Although CPbtL states Ihat it rejected horizontal silo storage, and by implication other dry cask technologies as well (Iheir words) (1 2/23/98 application at page 1 1-5 of Hottcc report HI-97 17GO),

because "fue1 with cladding defects p'tcakers"] cannot be placed in thc thorizontat] silo" (first reason staled), neither NRC nor CPS'ave stated or analyzed the impact of leaking fuel assemblies and/or fuel cladding defects on accident risks, accident probabilities, or demand on thc cleanup system for pools C and D, nor the design of any additional water or air cle'aning systems due to thc stomge of lhcir requested 4715 additional spent fuel assemblies to be stored in pools C and/or D. Such leaks and defects ion increase thc probability and severity of accidents, and the more fuel stonxl, the more fuel can bc contaminated by teaks or be involved in accidents.

For these seasons thc proposed finding of no significant hzcards is wrong and must be rejected.

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