ML20198N269

Declaration of DA Lochbaum,Nuclear Safety Engineer,Ucs Re Technical Issues & Safety Matters Involved in Approval of Yankee Np Station Ltp.* Declaration of DA Lochbaum Re Info Contained in CAN Contentions.With Certificate of Svc

ML20198N269
Person / Time
Site:	Yankee Rowe
Issue date:	12/15/1998
From:	Lochbaum D UNION OF CONCERNED SCIENTISTS
To:
Shared Package
ML20198N159	List: ML20198N153 ML20198N238 ML20198N269
References
98-736-01-LA, 98-736-1-LA, LA, NUDOCS 9901060070
Download: ML20198N269 (7)

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UNITED STATES OF ANIElllCA NUCLEAR llEGULATOltY COAlallSISON Before the ATONilC SAFETY AND 1.lCENSING llOARD in the matter of ) Docket No. 50-029-LA

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YANKEE ATO311C ELECTRIC COSIPANY ) ASLBP No. 98-736-01-LA ,

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.(Yankee Nuclear Power Station) ) December 15,1998  ;

DE.Cl. ARATION OF DAVID A. I OCIIBAUNI. NUCl. EAR SAFETY ENGINEER.

UNION OF CONCERNED SCIENTISTS. CONCERNING TECilNICAl, ISSUES AND SAFETY M ATTERS INVOI.VED IN Tile APPROVAL OF Tile YANKEE NUCl. EAR POWER STATION l.lCENSE TERMINATION Pl.AN l

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1. David A. Lochbaum, make the following declaration-

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1. My name is David A. Lochbaum. I reside in the state of Maryland.

2. I am employed by the Union of Concerned Scientists as their nuclear safety i 1

engineer. I have been so employed since October 1996. I have the following responsibilities: a) direct and coordinate UCS's nuclear safety program; b) monitor j developments in nuclear industry to assess and respond to impact; c) serve as technical authority and spokesperson on nuclear issues; and d) initiate legal action to correct safety problems.

3. -The Union of Concerned Scientists, with offices located at 1616 P Street NW Suite 310. Washington, DC 20036,is an independent nonprofit organization dedicated to advancing responsible public policies in areas where technology plays a critical role.

9901060070 990105 PDR ADOCK 05000029 .'~

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Declaration ofDavid A. Lochbaum, Nuclear Safety Engineer Page 2

-1. I h ve worked in the field of nuclear engineering since June 1979. I am a l graduate of the University of Tennessee with a bachelor of science in nuclear engineering.

5. After receiving my nuclear engineering degree, I went to work for the Georgia l

Power Company as a junior engineer at their Edwin 1. Hatch Nuclear Power Plant. I held various positions in the commercial nuclear power industry over the next 17 years prior 1

l tojoining UCS. This experience is detailed in the resume attached hereto as Exhibit A.

6. I am the author of Nuclear Waste Disposal Crisis (Pennwell Books, Tulsa, l l

January 1996) on the technical problems with spent fuel storage at reactor sites.

7. At the request of Citizens Awareness Network, Inc., I have examined the Yankee Nuclear Power Station License Termination Plan dated May 1997, and the revised pbm 1

dated December 1997. I have also reviewed the updated Final Safety Analysis Repon (FSAR) for the Yankee Naclear Power Station. I am familiar with these documents and have relied upon them in formulating the opinions contained in this declaration. I have also examined and am familiar with, for the purposes of preparing this declaration, the applicable federal regulations contained in Title 10 of the Code of Federal Regulations, Nuclear Regulatory Commission (NRC) Infom1ation Notice No. 97-51, " Problems Experienced With Loading And Unloading Spent Nuclear Fuel Storage And Transponation Casks," and NRC Bulletin No. 96-04, " Chemical, Galvanic, Or Other Reactions in Spent Fuel Storage And Transportation Casks." I have also relied upon these documents in formulating my opinions as expressed in this declaration.

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^ Declaration ofDavid A. Lochhaum NuclearSality IO gmeer Page 3

8. Hasing examined the relesant documents as mentioned. above, it is my professional opinion that the proposed dismantling removal of the spent fuel pool raises significant safety concerns for persons working at Yankee Nuclear Power Station and'or lising within close proximity to the facility. It is aiso my professional opinion that these significant safety concerns have not been adequately considered in the Yankee Nuclear Power Station License Termination Plan. These concerns are set forth below along with.

my recommendation that they form the subject matter ofissues to be considered by the Atomic Safety and Licensing Board in the above captioned proceeding.

9 It is my professional opinion that the following significant safety issues would be

's created by the dismantling / removal of the spent fuel pool for persons living in close proximity to the Yankee Nuclear Power Station and or persons working there:

(a) There is no repository available for spent fuel at this time. The federal site specified by the Nuclear Waste Act of 1982, as amended, was originally intended to be available by January 31,1998, but is many years behind schedule. The scheduled date for opening the repository is generally given as the year 2010 at the earliest. Based on the history of delays, it is reasonable to assume that the repository will not be available by the year 2010. Consequently, irradiated fuel assemblies remosed from the spent fuel pool at the .

Yankee Nuclear Power Station will probably be stored for at least a decade and for longer than a decade in all likelihood. -

(b) The Nuclear Regulatory Commission licenses dry cask storage systems for 20-year periods. Some of the licensed storage systems have already encountered problems such as the unanticipated collection and subsequent of hydrogen gas within a storage cask and

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Declaration ofDavid A. Lochbaum. Nuclear Safety Engineer Page4 a

weld problems which necessitate that the defective cask be unloaded. Thus, it appears very possible that irradiated fuel placed into dry cask storage systems at the Yankee Nuclear Power Station will remain stored there for longer than the original 20-year design and license lifetimes. Even if that were not the case, industry experience has revealed problems with NRC-licensed storage systems which, in at least one case, will

. require irradiated fuel to be unloaded.

(c ) Dismantling / removing the spent fuel pool at the Yankee Nuclear Power Station will eliminate the available contingency 'or coping with a dry cask storage system problem -

namely, returning the affected irradiated fuel to wet storage. The elimination of this option may result in increased radiation exposure risk to plant workers and/or the general public by delaying the ultimate resolution of the problem and/or by requiring a attemate i

resolution with greater probability of an accident (such as dry cask to dry cask transfer).

10. Because it is my professional opinion that the safety concems addressed in paragraph 9 would be created by dismantling / removal of the spent fuel pool at the Yankee Nuclear Power Station, I am also of the professional opinion, and do so state here, that the risk to persons working at the plant and/or living in c!ose proximity to the facility could be increased by the proposed dismantling / removal of the spent fuel pool at I the Yankee Nuclear Power Station, and the risks and potential are real, not highly speculative, and should be taken very seriously.

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Declaration ofDavid A. Lociabaum. Nuclear Safety Engineer Page 5 l

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'I declare under penalty of perjury that the foregoing is true and correct.

Executed December 15,1998

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David A. Loc %aum '

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DOCKETED UNITED STNfES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION I Before the ATOMIC SAFETY AND LICENSING BOARD- '99 JAN -5 P3 :51

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- Administrative Judges: OlF C 7 N Charles Bechhoefer, Chairmen RUl'.' 2 e iD Dr. Thomas S. Elleman ADJULO 1 e m FF i g~( / Thomast. Murphy ,

s in the Matter of fI ) Docket No.50-029 LA I

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YANKEE ATOMIC ELECTRIC COMPANY ) ASLBP No. 99-754-01-LA-R' i (Yankee Nuclear Power Station) ) i

) . I 1.icense Termination Plan ) Sers ed: January 5,1999 -  !

CERTIFICATl! OF SERVICl! FOR l CITIZENS AWARENESS NETWORK'S CONTENTIONS  ;

1, Deborah B. Katz., on behalf of Citi/ ens Awareness Network, Inc., certify under I 1

penalty of perjury that on January _,1999, copies of the enclosed papers were served on the

.6 parties below by mailing thim postage pre-paid U.S. Postal Service Express Mail (except I 1

Thomas S. Elleman who was'sersed First Class due to travel on anticipated date of delivery):

l Oriuinal and two copies to: One copy to:

Rulemakings and Adjudications StaiY Ollice of Commission Appellate Adjudication 1

- (Mail Stop 0-16-Cl) (Mail Stop 0-16-Cl)

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1 White Flint North I White Flint North 11555 Rockville Pike 11555 Rocksille Pike :

Rockville, MD 20852-2738 - Rockville, MD 20852-2738

Tel. 301-415-1675 Tel. 301-415-2184 One copy to:

Jonathan M. Block, Counsel for Thonuts G. Dignan, J r., Esq.

New England Coalition on Nuclear Pollution Ropes & Gray P.O. Box 566 One International Place

~ Putney, VT 05346-0566 Boston, MA 02110-2624 Tel. 802 387-2646 < Tel 617-951-7511 I'

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2 One copy each to- One copy to:

Atomic Safety and Licensing Board Thomas S. Elleman, Administrative Judge, Charles Bechhoefer, Chairman, ad Atomic Safety and Licensing Board

' Thomas Murphy, Administrative judge 704 Davidson Street (Mail Stop T-3 F23) Raleigh, NC 27609 U.S. Nuclear Regulatory Commission  ?.

2 White Flint North Diane Curran 11545 Rockville Pike llarmon, Curran, Spielberg & Eisenberg L Rockville, MD 20852-2738 - 1 2001 'S' Street, N.W., Suite 430 Tel. 301-415-7399 Washington, D.C. 20009 ,

t Tel. 202-328-6874 James L. Perkins, President .

Adam Laipson >

New England Coalition on Nuclear Pollution Franklin Regional Council of Governments .

o . P.O. Box 545 425 Main Street ,

Brattleboro , VT 05302 Greentield, MA 01301 l

j. Tel. 802-257-0336 Tel. 413-774-3167 )

!: )eborah B. Kat/.. Citizens Awarene Network '

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The followine persons were provided courtess connies of CAN's filinu:

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! David Rothstein L U.S. EPA Region i Suite i100-RCA l- 'l Congress Street Boston, MA 02114-2023 J Ted Bolen, Esq.

l Ensironmental Protection Disision OITice of the Attorney General 200 Portland Street l Boston, MA 02114 j.

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