ML20199D127
| ML20199D127 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/15/1986 |
| From: | Ferguson R Sierra Club |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20199D096 | List: |
| References | |
| OLA, NUDOCS 8606190305 | |
| Download: ML20199D127 (19) | |
Text
_ _ _ .
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of: )
) Docket Nos. 50-275 and 50-323 PACIFIC GAS AND ELECTRIC COMPANY )
)
(Diablo Canyon Nuclear' Power )
Plant, Units 1 and 2) )
)
4 AFFIDAVIT OF DR. RICHARD B. FERGUSON DR. RICHARD B. FERGUSON, being duly sworn, deposes and"says as follows:
- 1. I am a professional physicist, Vice-Chairman and Conservation Chairman of the Sierra Club, Santa Lucia Chapter, i
and a Pacific Gas & Electric Company ratepayer. I received a Bachelor of Arts degree, cum laude, from Amherst College, Massachusetts in 1960 and a' Ph.D in physics from Washington l
University, St. Louis, Missouri in 1967. I taught on the physics I faculty of the University of California at Los Angeles from 1967 l
to 1970 and of California Polytechnic State University at San Luis Obispo from 1974 to 1984. I reside in San Luis Obispo County at Rocky Canyon Star Route, Creston, California 93432.
- 2. On behalf of the Sierra Club, on February 10, 1986, I requested a hearing and filed a petition for leave to intervene
- in the- NRC proceeding related to PG&E's request for a license l amendment to permit reracking of the spent fuel storage facili-l' l
ties for-the Diablo Canyon nuclear power plant. The Sierra Club 1
860619030S 860616 PDR ADOCK 05000275 G PDR
filed its petition because of our concerns about the environmen-4 tal and public health and safety. In particular, Section 132 of the Nuclear Waste Policy Act of 1982 requires that additional spent fuel storage at the site of a civilian nuclear power reactor be consistent with "the protection of the public health and safety, and the environment" and that the NRC is to act consistent with the " views of the population surrounding such reactor". No attempt had been made to ascertain the views of the population surrounding the reactor (including any of the more than one thousand members of the Santa Lucia Chapter of the Sierra Club, the majority of whom live within the nuclear evacuation zone surrounding Diablo Canyon). Moreover, the property and personal safety of ...a.tbers of the Club, as well as the environment of San Luis Obispo County, are seriously jeopar-dized by unsafe spent fuel storage facilities at Diablo Canyon and, in the Club's opinion, the proposed reracking would signifi-cantly reduce the margin of safety for the spent fuel storage system and pose a risk to the public health and safety and protection of the environment.
- 3. I have reviewed the materials which the NRC has made available to the public regarding the spent fuel reracking at Diablo Canyon as well as various other naterials concerning the power plant. In particular, I have reviewed PG&E's Reracking Report [1], the NRC staff's Safety Evaluation report [2], and the NRC's license amendment [3].
- 4. On May 30, 1986, the NRC amended (without any public ,
2
1 .
hearing) PG&E's operating licenses for Diablo Canyon to permit major modifications to the spent fuel storage facilities at the power plant.
- 5. The purpose of this affidavit is to address the potential' response of the reracked spent fuel facility at Diablo Canyon to seismic activity. In my analysis, I have not attempted to evaluate the NRC's assumptions regarding the likelihood or strength of an earthquake. I have accepted the NRC's assumptions regarding seismic accelerations. I have, however, examined the impact of such seismic motion on the proposed spent fuel storage system at Diablo. Canyon and the consequences for public health and safety and protection of the environment.
- 6. It is my understanding from the on-site NRC inspector that in response to the NRC license amendment, PG&E has already removed the original spent fuel storage racks at Diablo Canyon and will begin reracking this week. The reracking is expected to be completed by the end of August. It is my professional opinion I
that the spent fuel reracking should be halted immediately in order to protect public health and safety and the environment.
Failure to do so constitutes a real and present danger to the population and environment surrounding the power plant.
- 7. I base my conclusion upon factors unique to Diablo
- Canyon --
its known seismic hazards and the type of reracking PG&E proposes to undertake. These factors pose a significant threat to the public health and safety and protection of the environment near Diablo Canyon. As described below, the NRC has 3
failed to consider or to analyze adequately several significant aspects of the spent fuel- storage facility's response to an earthquake.
- 8. The integrity and safety of the spent fuel storage system during an earthquake is essential to the protection of public health and safety and to the environment. If the spent 1.
fuel racks were to become damaged, serious consequences could result. For instance, if the fuel rods were damaged, nuclear materials might escape and contaminate the spent fuel storage pool. Or, if the racks holding the spent fuel rods were damaged, the racks could compress, resulting in an unacceptably large production of neutrons by the spent fuel and in the fuel mass becoming " critical", i.e., being able to sustain a nuclear chain l
l reaction.[4]
- 9. As explained above, the major concern I have is with the integrity of the Diablo Canyon spent fuel storage system in the event of an earthquake if the system is modified in accor-l dance with the NRC's license amendment. It is undisputed that l
the Diablo Canyon site is located within three miles of a known active earthquake fault, the Hosgri fault, and that seismic activities pose a potential risk to the Diablo Canyon power plant. To my knowledge, no other nuclear installation in the world must withstand as large a seismic disturbance as the facility at Diablo Canyon.
- 10. Each of the two spent fuel pools at Diablo Canyon will contain sixteen of the new storage racks surrounded by water. [5]
4
4 The new spent fuel racks, unlike the original racks, are free-standing and unfastened to the floor and the walls of the pools.
[6] It is undisputed that during a moderately large earthquake, each rack is expected to slide in a random fashion on the floor of the pool. It is undisputed that.each of the racks is expected to experience potentially dangerous forces as a result of collisions resulting from seismically induced motions. [7] The possibility of damaging collisions results directly from the replacement of racks which are anchored with new racks which are not anchored.
- 11. PG&E's reracking will also increase the density of spent fuel in the pools significantly and will thereby increase the total spent fuel storage capacity. By increasing the density, PGGE will decrease the separation between neighboring fuel assemblies to a minimum, and in some places to less than 2 inches. [8] In doing this, PG&E has increased considerably the potential for serious consequences if collisions do occur. And, as explained in the preceding paragraph, increased collisions are likely with the reracking because the replacement racks will not i
be anchored, whereas the existing rack are anchored.
- 12. As explained in detail below, there are several types of risks from the spent fuel reracking which the NRC'has failed I
to examine adequately add which pose a significant threat to the l public health and safety and protection of the environment.
First, there is the potential for collision of the racks with the i walls of the storage pool. The NRC appears to have ignored this l
1 l
problem. Second, there is the potential for collision of one rack with another rack. The NRC has not assessed this impact properly. Third, there is the potential for multi-rack colli-sions - i.e., more than one rack colliding with the wall or with another rack. The NRC has ignored this potential. Fourth, the NRC has overemphasized the cushioning effect of water in colli-sions involving fuel racks. Fifth, one rack in particular (fuel rack "H") has a different configuration from the other racks.
Although collisions involving this rack could cause damage to the system more easily than from other racks, the NRC reports contain no reference to this special problem.
- 13. It is undisputed that the proposed fuel storage racks are expected to slide on the floor of the spent fuel pool during an earthquake similar to the Postulated Hosgri Earthquake
("PHE"). [7] During the PHE, the spent fuel pools (and indeed the entire power plant) are expected to undergo displacements of up to three feet in the north-south direction and eight feet in the east-west direction. (See Figures 1 and 2.) My analysis shows that the fuel racks, located inches from the walls of the pool, would collide with these walls as a result of seismic motion of the magnitude postulated to occur at Diablo Canyon.
- 14. From fundamental physical principles, it is possible to derive an expression relating the expected force exerted on the fuel racks as a result of a collision with the walls of the pool.
(See Appendix 1.) Using data supplied by PGGE, the magnitude of these forces can be predicted by means of this expression. My 6
calculations indicate that for racks weighing 200,000 pounds, the force on a rack could be as large as 1,000,000 (one million) pounds or greater when a rack collides uith a wall. PG&E states that the maximum allowable force on a rack is 175,000 pounds. [9]
The anticipated force is thus more than five times the maximum allowable and would be expected to cause serious damage to the rack.
- 15. During seismic activity, because the racks are not anchored, two or more racks could slide together as a unit.
Basic physical principles predict that the forces generated in a collision with two racks sliding would be twice as large as for single racks, three times for three racks,. etc.... The force on a rack colliding with a wall under these conditions could conceivably reach as high as two or three million pounds, more than ten times the maximum allowable.
- 16. Nowhere is the problem of rack-wall collisions discus-sed in the NRC's Reracking Report. The NRC's Safety Evaluation l Report mentions the possibility only in passing. [10] In neither i
report is any attempt made to estimate the force on a spent fuel rack resulting from such collisions. Nor does either report mention the possibility of racks sliding together. In my opinion, j the failure to analyze these factors is a fatal omission.
Contrary to the conclusions reached in these reports, the likelihood of collisions between sliding fuel racks and the walls of the spent fuel pools and the resulting damage to the racks represents a serious reduction in the margin of safety at Diablo 7
l l
Canyon. The resulting hazard to the public health and safety and to the environment is a problem unique to the proposed reracking at the Diablo Canyon nuclear power plant because of the lack of adequate anchors for spent fuel racks in an active seismic area.
- 17. It is undisputed that the sliding fuel racks will ,
coll.de with each other during the PHE. [7] The Reracking Report and the Safety Evaluation cite the results of a sophisticated
- computer model as evidence that forces generated by such rack-rack collisions would be less than the maximum allowable force.
[9] Regardless of the sophistication of the model, however, the I
results are only as reliable as the underlying assumptions. In my opinion, the assumptions used are unrealistic and the consequent i results misleading. The fallacies in the assumptions are described in paragraphs 18-20 below.
- 18. PG&E proposes that each of the two spent fuel pools at
[ Diablo Canyon contain sixteen of the new storage racks surround-ed by water. During a moderately large earthquake each rack is I
expected.to slide in a random fashion on the floor of the pool.
The resulting motion is quite complex and there is no known method for accurately predicting the motion of one rack; only approximate results can be obtained. Yet, the method used in the NRC reports to estimate the forces generated in rack-rack collisions ignores the motion of all but two racks. In my opinion, this assumption is unrealistic and leads to misleading results. The motions of surrounding racks could increase or decrease collision forces depending on their alignment at the
. .. ,. - g. n. ---_.--.--,-,--,w,.,,, ,-,~>,_..n ,.,.-,_-,,,,n.,-, ,
time of collision.
- 19. In addition, the NRC assumes a large cushioning effect for the water between racks. [11] The magnitude of the cushion-ing effect contained in the NRC's assumptions is unreasonably large. {As a result, the forces calculated are unrealistically small.}
- 20. I have made more realistic calculations which allow for potential movement of all surrounding racks and assume no cushioning effect of water. My calculations indicate forces as large as 600,000 pounds would be generated from rack-rack collisions. This is nearly four times the maximum allowable r
! value of 170,000 pounds. In my opinion, therefore, collisions between the racks would also result in serious damage to the i racks with consequent endangering of the public health and safety and protection of the environment.
- 21. The NRC reports also fail to recognize the hazardous configuration of one of the racks, rack "H". All racks are l
designed with a " girdle bar" or bumper around the top at the same elevation so that during collisions the bumpers will receive the upper impacts. Contact at the bottom of the racks during
- j. collisions is expected to be made between steel base plates.
However, because of certain limitations, one of the racks in each pool, rack "H", is constructed with legs shorter than those of l other racks. The height of the girdle bar has been adjusted so as to be the same as the others, but the base of rack "H" is lower than the bases of surrounding racks. [12] During a j 9 l
collision involving rack "H", the base of a neighboring rack would strike above the base of rack "H" in a region which is much more susceptible to damage than the base. Although collisions involving rack "H" are more likely to cause damage to the system 1
than collisions involving other racks, the NRC reports contain no I reference to this special problem. In my opinion, damage to rack "H" could occur during even moderate earthquakes and represents a serious hazard to the public health and safety.
CONCLUSION
- 22. The NRC's reports authorizing the spent fuel reracking at the Diablo Canyon nuclear power plant fail to examine ade-quately several risks' unique to Diablo Canyon with the result that the reracking, if undertaken, will pose a significant threat to the public health and safety and protection of the environ-ment. The location of the Hosgri fault three miles from~Diablo Canyon means that the spent fuel storage pool is in an active seismic zone. Although the original spent fuel storage racks were anchored by bolts to the bottom of the storage pools, the i
new ones are not; they are free-standing. This means that the racks will, as the NRC admits, slide around during earthquakes.
The reracking also means that the density of the racks will increase significantly and that the space between neighboring fuel assemblies will be reduced to a minimum. As a result, the potential for serious consequences if collisions do occur has increased substantially. As I have explained above, the NRC has ignored or inadequately examine the potential for collisions and 10
the resulting damage to the fuel assemblies and racks. The NRC has failed to assess realistically damage due to collisions of the racks with the walls of the spent fuel pools, of the racks with each other, of multi-rack collisions, and of the "H" racks, and has unrealistically assumed that water will sufficiently cushion the impacts of the racks in collisions. My calculations show that the reracking will reduce the margin of safety signifi-cantly and that there is no assurance that the new facility will adequately protect the public health and safety and the environ-ment.
Consequently, I conclude that the reracking at the Diablo Canyon nuclear power plant presents a significant safety hazard to the surrounding environment and population and poses a risk of irreversible contamination.
///
///
l ///
///
///
///
///
///
///
///
///
///
11 l
i
e
- Executed this 15th day of June, 1986, at San Francisco, California.
I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
LJ4[ y-DR. RICHARD B. FERGUSON State of California ss. 4 City and Co. of San Francisco On thi.s 16th day of June, 1986, before me, the under-signed Notary Public, personally appeared Dian M. Grueneich, personally known to me, who, being by me duly sworn deposes and says that she was present and saw Dr. Richard B. Ferguson, the same person described in and whose name is subscribed to the within and annexed instrument, execute the same.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
j = - - r %m _ _ _ _ _ _
erncx uu L l .n ! .. .
@',% s.,D~COSA!! 14. HUNT i
< r,c ' , ,..,...
- u. y . , ~,'..,
. iti. :,,S;
,.;y;),;'l, fj g h w v e ..,,
D'eborah M. Hunt
REFERENCES
- 1. Reracking of Spent Fuel Pools Diablo Canyon Units 1 and 2, Pacific Gas and Electric Company, San Francisco, California 94106, September 1985 (Reracking Report)
- 2. Safety Evaluation By the Office of Nuclear Reactor Regulation Relating to the Reracking of the Spent fuel Pools ar the Diablo Canyon Nuclear Power Plant, Units 1 and 2, U. S. Nuclear Regulatory Commission, May 30, 1986 (Safety Evaluation)
- 3. Environmental Assessment By the Office of Nuclear Reactor Regulation Relating to the Expansion of Spent Fuel Pools ..... Diablo Canyon Nuclear Power Plant Units 1 and 2....., U .* S. Nuclear Regulatory Commission, May 21, 1986
- 4. Reracking Report, Section 4
- 5. Reracking Report, pp. 2-4, 5
- 6. Reracking Report, pp. 6-1 ff
- 7. Reracking Report, pp. 6-9 ff
- 8. Reracking Report, p. 4-30
- 9. Reracking Report, p. 6-27 3
- 10. Safety Evaluation, p. 10 4
- 11. Reracking Report, p. 6-7
- 12. Reracking Report, p. 3-4 J
I gy -w-- gg s y. --,y , .-y ,7 -g---.y p., y -w-.w g.-iy , 9., , = - , e, ,-.%-.,-w ,..g. a+-,r. ev e *
. 4 APPENDIX A
, In order to compute the force on a spent fuel rack colliding with a wall I have used a one-dimensional model in which the rack is given mass M, the center of mass located at position X2. The rack is assumed to come into contact with a wall having position X1 and acceleration A toward the rack. Since the walls of the spent fuel pools at Diablo Canyon are embedded in bedrock, the wall in contact with the rack is assumed to be infinitely massive and A is taken to be constant during the (short) time of contact.
The elasticity of the rack and wall is lumped into a single ideal spring having spring constant k. The spring functions only under compression and represents a suitable combination of the "non-linear gap elements" used in the Reracking Report. [7]
The equation of motion for the rack is then (1) ( ; )C, ( )(g - I, - d ) s d where d is the equilibrium uncompressed length of the spring and 4 f is the instantaneous lateral force on the rack. With the substitution (la) X =. )(2 ' X: 'M and our condition that 5, = 4 we see that (lb) x=x-A x and equation (1) becomes (2) kgs M jd t M4 Changing variable again,
, (2a) y=X + (m/se.) A
. 4 we obtain (3) -
Y*
Solutions to equation (3) are well known, namely g = C s,, N t + y )
where C and q are constants to be determined from initial conditions and sc = . Recalling equation (2a) we have (4a) y= C sso ( w i +4)-d/W E (4b) S = w C co r (. w t + ( )
(4c) $=-W b ##'"("b+{
and we note that X = X1 - $2 is the relative velocity between the rack and the wall. Squaring and adding equations (4a) and (4b) we obtain (5) k)( + 4 [tM f (h/"} = C.
Assuming at t = 0 that X = 0 and k = V we solve for C; (6) (, = g, AA2 f/0 /
MA /A A' Recalling equations (1) and (1b), the instantaneous force on the rack is given by
[
- N Ng 2 N k k + A)
(7) f-MAtMAV/ 4-V^a*/4*'ein(wt4f) l From equation (7) the maximum lateral force on the rack is seen to be (8) $=MA(I e ) l + V* k/m n*') &2mA Thus according to equation (8) any rack colliding with an accelerating wall can be expected to experience a maximum force of at least 2MA.
. . e The interaction between the rack and the spent fuel pool is, of course, more complicated than a simple elastic collision. Some force is applied to the rack in the form of friction at the rack-f loor interf ace, for example. However, since the total time during which the collision occurs is short, little energy will be dissipated by these forces. Consequently, equation (8) remains a good approximation to the force on the rack during a collision. A similar argument can be given for internal damping effects in the rack. Interaction with the surrounding water is a complicated phenomenon which could increase or decrease the result of (8) depending. on the motions of the surrounding racks. We have ignored the effects of water interactions here, and the predictions of equation (8) should be regarded as estimates only.
Since a one-dimensional model has been used to derive equation (8), the results say nothing about how the force is applied to the rack. Some of the lateral force will be aplied to the " girdle bar" at the top, some at the base, and some will be applied as friction at the pedestal-floor interface. Depending on coefficients of friction, simultaneous vertical accelerations, etc., the frictional force could range perhaps from zero to the weight of the rack. The lateral force exerted on the sides of the rack would be decreased by a similar amount. Given the uncertainties associated with the estimates of the frictional force, it seems prudent to allow for the possibility that the entire lateral force of equation (8) may be applied to the sides of the spent fuel rack.
__ ___________ 9
l$ ^ ..
/G-
- FIGURE 2 fg NORTH-SOUTH DISPLACEMENT AS FUNCTION OF TIME POSTULATED HOSGRI EARTHQUAKE DIABLO CANYON, CALIFORNIA ,
/A~ Graphs drawn from values obtained by direct integration of data supplied g
/0 to Dr. Ferguson by PG&E June 8, 1986 i% :
i % V_ ,
!W 5 T b o ~
- 1p-4 s, 2 j
- L
! 2
,(1 -
Q
% .~
- V-[- - { i
! g l e _/, ,
- a
.i lI sLh - E-O
- O-lo
-i: <
-(2- ~
I ey l -// )
. s
-/6- -
i -17 5 /C /S 20 2.4 1
'T/or C (. 5 c c )
llll
.u a.
o
,,u a
e n
E M
I
. ,n T
d
. F e O i6 l8 N
O p9 d p1 . ,
I eu T ns ,
C i 8 N aa UE tte FK ban ,
A odu .
SUA J .,
AQI sf HneoE TTRu & -
NROl nG -
EAFaoP MEI vi ty ,
E L CIAmab ARcor rgn LG PS ,feo son IHOnnu D
ts A,
v wi g Dna TEArte 1STcdcF EA e r
\
y EWLosr. /
R Uthir U T T s pd D -
GSSAa ,y IAOI ryo FEPDGbt
.z e
- ~ ~ -
L o 0 - -
o o W 7 Y 9 g g l 0 ,
, = w tJ4,. u 1'"w w 0 ea4 M'D 2w -
tll Il l1ll ll 11L
y, tl y
~
.[o G toa.m,,
O
-1 PROOF OF SERVICE 9 g7%86> g i *=E,$du I, Deborah M. Hunt, declare that on Juna Ny[ kh867 J8 deposited copies of the attached Notice of Appearance',- rven W Application for A Stay, and Affidavit of Dr. Richard BN '
the United States mail with postage thereon fully pre and addressed to the following:
Dr. Jerry Harbour Mr. Leland M. Gustafson, Administrative Judge Federal Relations Manager Atomic Safety & Licensing Board Pacific Gas & Electric _Co.
U.S. Nuclear Regulatory Comm. 1726 "M" Street, NW, Suite 1100 Washington, D.C. 20555 Washington, D.C. 20036-4502 Glenn O. Bright Philip A. . Crane, Jr., Esq.
Administrative Judge Pacific Gas & Electric Co.
Atomic Safety & Licensing Board P.O. Box 7442 U.S. Buclear Regulatory Comm. San Francisco, CA 94120 Washington, D.C. 20555 Mr. Gordon A. Silver Henry J. McGurren, Esq. Ms. Sandra A. Silver Lawrence J. Chandler, Esq. 1760 Alisal Street Office of the Exec. Legal Dir. San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Comm.
Washington,- D.C. 20555 Ms. Laurie McDermott, Coordinator Atomic Safety & Licensing C.O.D.E.S.
Board Panel 731 Pacific Street, Suite 42.
U.S. Nuclear Regulatory Comm. San Luis Obispo, CA 93401 Washington, D.C. 20555 Mrs. Jacquelyn Wheeler B. Paul Cotter, Jr., Chairman 2455 Leona Street Administrative Judge San Luis Obispo, CA 93400 Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm. Dr. R.B. Ferguson Washington, D.C. 20555 Sierra Club / Santa Lucia Chapter Rocky Ce.nyon Star Route Atomic Safety & Licensing Creston, CA 93432 Appeal Panel U.S. Nuclear Regulatory Comm. Ms. Nancy Culver Washington, D.C. 20555 192 Luneta Street San Luis Obispo, CA 93401 Bruce Norton, Esq.
NORTON, BURKE, BERRY & FRENCH P.O. Box 10569 Phoenix, AZ 85064 s
I am, and was at the time of the service of the attached paper, over the age of 18 and not a party to the proceeding.
I dec)are under penalty of perjury that the foregoing is true and corract. 3 f i
/
, =
freborah M. Hbnt '
. - _ - _ - _ _ - _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ - __ _ - - - _ - - - _ - I