ML20126F895

Initial Decision Authorizing Director of Ofc of Nuclear Reactor Regulation to Make Appropriate Findings in Accordance W/Nrc Regulation & to Issue Appropriate OL Amend Authorizing Requested Spent Fuel Storage Rack Replacement

ML20126F895
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/14/1980
From:	Little L, Remick F, Wolf J Atomic Safety and Licensing Board Panel
To:
Shared Package
ML20126F884	List: ML20126F882 ML20126F886 ML20126F890 ML20126F895
References
DD-81-02, DD-81-2, NUDOCS 8103200803
Download: ML20126F895 (102)

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ATTACHMENT B 4

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UNITED STATES OF AMERICA

.:n,ry NUCLEA.R REGULATORY COMMISSION ATO'CC SAFETY AND LICENSING BOAP3 John F. Wolf, Chair =an Dr. Linda W. Little Dr. Forrest J. Re=ick l

In the Matter of

)

Docket Nos. 50-295

)

50-304 COMMOE7ALI'd EDISON COMPANY

)

FOL Nos. DPR-39 & DPR-48 (Zion Station, Units 1 and 2) )

Proposed Amend =ent to

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Permit Storage Pool I

Modification INITIAL DECISION (February 14, 1950)

Ateearances Michael I. Miller, Esq., Philie Steetoe, Esc., and Alan P. Eielawski. Esc., Chicago, Ill., for the Co=enwealth Edison Cc=pany, Applicant Susan N. Seouler, Esc., and Anne K. Markey,_Esq,.

Assistant Attorneys General, Chicago, Ill., Intervenor Richard J. Goddard, Esq., and Steven C. Goldberg, Esq..

Washir.gten D. C., for the Nuclear Regulatory Co=issien Staff.

4 9

2 INITIAI. DECISION I.

PRILIMINARY STATEMINT 1.

The Cor=onwealth Edison Company (Applican:) has applied to the Nuclear Regula:ory Co:=ission for per=ission to ins:al; new storage racks in the spen fuel pool at the Zion, Illinois N: clear Generating Station.

The proposed new storage racks in the spent fuel pool would increase the pool's s:orage capacity from 865 to 2112 fuel asse=blies.

2.

C*n April 13, 1978, the Applicant for= ally requested the issuance of a license a=end ent. No: ice of the proposed a=end=en: was published in the Federal Register en July 18,.

1978, 43 Fed. Rec. 30935.

The State of Illinois (Intervenor) filed a ti=ely peti: ion for leave :o intervene in these pro-ceedings e.nd requested a public hearing on the application be 9

held.

3.

A Special ? rehearing Conference was held on Nove=ber 20 an? 21, 1978, at Waukegan, Illinois fo: the purposes of ruling on Intervenor's standing to intervene as a party in the proceedings and deter =ining whether certain of Inte:ven::'s contentiens =et the legal requirements of the Nuclear Regula-tory Co

'ssion's Rules of ?:actice.

Limited appearance state-cents were taken a: that time.

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. On January 19', 1979, the Board ad=1: ed the State of Illinois as an intervening party and ruled upon the ad-1/

=issibility of-certain of Intervenor's contentions.-

5.

Subsequently, Mbtions for 5"- ary Disposition were filed by Applicant and the Nuclear Regulatory Co==ission Staff (Staff).

Certain'of Intervener's con:entions were s"--$rily dis =issed on :he grounds tha: no genuine issues of 2/

=aterial fae: existed as to those conten: ions.-

6.

An evidentiary hearing was held in Zicn, Illinois fro: June 11 through June 15, 1979 and frc= June 20 through June 22, 1979, at which ti=e evidence was presen:ed by the parties wi:h respect :c the re=aining controver:ed conten: ions and Board questions.

During these hearings all-in:erestei w-

=e=bers of the public who wished to =ake li=ited appearance sta:e=ents were heard.

7.

Shortly af ter the sub=ission of Proposed Findings of Fact and Conclusions of Law by the par:Les, the Board was I

apprised by a Board Notifica:Lon entitled " Pipe Cracks in Stag-l nantBoEatedWaterSystemsa

?WRs" dated August 14, 1979, and IE Sulletin 79-17 tha: the use of type 304 stainless steel raised possible probless under the conditions found in the Zion spen: fuel pool.

This informa: ion caused the Board to i

reopen the record on its own.voli: ion :o receive evidence 1

1/.

Order Following ? rehearing Conference da:ed January 19, 1979.

2/

Order dated May 1, 1979; Order dated June 4, 1979.

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• 1 regarding the safety o'f the proposed fuel. storage. racks to be used in the Zion spen: fuel pool.

Affidavits by~ experts were

- J subritted by the parties.

That evidence was. considered in 3/

arriving at this Initial' Decision.~

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Board's Menorandt= and Order dated Ssprember 14, 1979..

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II.

FINDISGS OF FACT l

4 A.

Environ = ental I=ca e: Acoraisal 1.

Adecuacy Contention 2(a) states:

The S:a:e of Illinois contends that approval of the proposed license a:end:en: would be a =2j or action of the Co==ission significantly affecting the quality of the hu=an environ-cen in Illinois.

The National Environ = ental Felicy Act of 1969, as a= ended, requires the Co--fssion to sub=i: an enviren= ental i=cact sta:e=en: with respect to the proposed l'icense a=end=ent.

The 5:aff performed an environ = ental evaluation of the preposed =odification pursuan to the Na:Lonal Inviron-

. = ental'?olicy Act of 1969, 'as a= ended (NI?A).

The Environ =en:al.

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I= pac: Appraisal (ILA) was issued F. arch 29, 1979.~~

The EIA describes and evalua:es the Zion facility, 1:s need for increased spen: fuel storage capacity, environ =entali= pacts of the proposed

= edification, environ = ental i= pact of pos:ulated accidents, alter-na:ives for spent fuel storage, and cos:-benefit balance of the propcsed = edification as co= pared to al:erna:ives.

Under the headi=g, "3 asis and Conclusion for No Preparing an Environ = ental 5/

I=p ac: State =en:",'-

the IIA states:

k*e have reviewed this proposed facility modifica: ion relative to the require =ent set forth in 10 CFF. Par: 51 and the Cou=cil on Environ = ental Quali:v's Guidelines, 40 Cix 1500.6, and ~have applied, balanced, and weighed j_/

Staff Ev 13.

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6 the five factors specified by the Nuclear Regulatory Co==ission in 40 Fed. Rec. 42501.

'**e-have deter =ined that the proposi? license a=end=ent will not significantlyLaffect the quality of the hu=an environ =en and that there will be no significant environ = ental i= pact attributable to the proposed sc:icn other than that which has already been pre-dicted and des cribed in the Co==ission's Final Environ = ental Stata=ent for'the facili:y' dated.

Dece=ber 1972.

Therefore, the Co--'ssion (sic) has found that an Environ = ental Icpact S: ate =ent need not be prepared and that, pursuant to 10 CFR 51.5(c), the issuance of a negative declaration to this effect is appropriate.

The conclusions set forth in the EIA were supported by Staff's and Applicant's witnesses:

(1)

The preposed =odification will not require any addi-tional co==1 =ents of land, since-it will alter only' the spent fuel storage racks in,the existing spent.

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fuel pool.~

(2)

There vill be no significant change in plant water cons - 7:Lon or use as a result of the proposed modification.~~/

7 (3)

The potential offsite radiologietl environmental I

i= pact associated with expansien of the spent fuel S/

storage capacity will be environ =entally insignifican?~

either to the atmosphere ~~/

9 10 /

or to receiving waters.

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Id. at i 5.1; Tes timony of To= R. Tra== (Tra--) at p. 3 Iollowing Tr. 564.

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S aff Ex.13, s 5. 2 ; Tra== at pp. 4-5.

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Staff Ex. 13, i 5.3.1.

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f 5.3.2; Tr. 885,1060,1065.

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Staff Ex. 13, 5 5.3.4

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The additional solid radioactive waste resulting fro = the proposed =odification would result fro =

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increased loading on the pool purification syste=

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and frc= disposal of the presen: spent fuel pool L

racks.12/

The present filtration da-#neralization syste= is capable of handling the increased lead-11/

ing."~

The total a=ount of waste shipped fro = the i

plant will be increased by abou: 2 percen: (as 1

averaged over the lifeti=e of the plan s) and will have no significan: environ = ental i= pact.

(5)

The proposed =odification will not result in any significant increase in radiatien doses received in onsite occupa:icnal exposure;15I i: should add less than 1 percent to the total annual occupational 16/

1 radiation exposure burden at the facility.

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(6)

There 'will be no change in the che=ical or biocidal effluents fro: the plant as a result of the proposed

=odifica: ion.ll/

(7)

The proposed =odification will not result in any significant increase in the plant ther:21 discharge, 22/

Id., 5 5.3.3; Tr. 592, 776.

jjf Staff Ex. 13, 5 5.3.3; Tra== a

p. 5.

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Staff Ex. 13, 5 5.3.3.

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Staff Ex. 13, 5 5.3.5; Testi=ony of George J. 711=1 (plimi) at p. 5 following Tr. 677.

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Staff Ex. 13 5 5.3.5.

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Id., 5 5.3.B; Tr=-

at p. 6.

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8 since the increased thermal discharge would be less than 0.04 percent of the~ estimated total ther=al discharge to Lake F.ichigan.1.1./

(E)

No environ = ental i= pact on the co=:=mity. is expected to result fro: the fuel rack conversion itself or fro = subsequent operation of the pool

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with increased arounts of spent ' fuel.Lc.)

The Staff a=d Applicant testified in regard to Con-tention 2(a).

The Intervenor did not present any direct testimony regarding this contention.

2.

Procer Issuance Intervenor raised questions rela:ing to the ti=ing of

- 'the decision to' issue an IIA rather than an Environ = ental I= pact (EIS).2d S:atemen:

and to the si=ilari:7 of the EIA for Zion to those for c:her spent fuel pool codifications,,,2jsuch as Sale =.2;_/

Consequen:1, Intervenor questioned the adequacy, independence, 7

and site-specificity of the assess =ent of the environmental i= pacts i

of the proposed modification. 2$

The Board requested that the Staff substantiate tha: the EIA was performed after specific exa=ination cf plant design and in consideration of conditions unique to Zion Station, including its location and possible M

Staff Ex.13, 5 5.3. B ; Trm-at p. 4.

,19/

Staff Er.. 13, 55.3.9; Tra=n at p. 6.

,2_0/

Tr. 612-614.

,2.1/

Tr. 629-641.

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Public Se vice Co. of Ne Jersev, Docket No. 50-272.

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Tr. 623, 629.

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9 i= pact on the environ =en: and the hu=an health of the sur-24/

rounding area.-~

Staff's response was that the full range of potential site-specific environ = ental i= pacts for the construction and continued operation of Zion was considered in the Staff's Final Environ =en:al Stata=ent.(FIS), issued Dece=ber.1972, and that in the environ = ental review per:aining to the proposed =edifica: Con, the.S:aff evaluated whether the

=odification would result in potential for increasine i= pacts 25 previously evaluated in the TES.-~/

The Staff explained s'-#1arities in language of the EIA's for Zion and Sale = by noting tha: the Staff's witness was proj ect =anager responsible for both rarackings,_2_6/

and tha cievant portions of both docu-

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=en:s discuss generic issues applicable to all fuel-pool 27/

=odifica: ions regardless of location.--

The Board no:es that the ti=ing of the decision that an EIS was not necessary and the =arked si=ilarity of the EIA at hand to the EIA's for si=11ar. facilities raised serious doubts as to the credibility o.f the EIA for the Zion facility.

Resolution of these doubts required extensive questioning of the Sta#f witness by In:ervener and by the Soard.

24/

Tr. 576-577.

25/

Tr. 609-610.

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Tr. 611, 629-641.

27/

Tr. 637.

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However, based on examination of the IIA'itself in t

cenju= :ien vi:h evidence presented by Staff's and Applicant.'s l

vitnesses a: the evidentiary hearing, the Board finds that the proposed codification vill not significantly increase the environ: ental i= pact of the Zion facility.

Accordingly, the proposed action is not a major action of the Co=:ission sig-nificantly affecting the quality of the hu=ar, environment.

Tnus, no environ = ental i= pact statement is required, and the-IIA satisfies the requirenents set forth in 10 CTA 51.5 and

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3.

Nuclear Rerulatorv Co==issien's " Notice of Intent" s

Intervenor's Contention 2(b) states :

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Approval of the a=end=ent request would be contrary to the NRC policy position on spe fuel storage which prohibits non-emergency licensing of any existing storage facility i

prior to the adoption of an official icng

er= policy regarding the per=anen: storage of t

1 spent fuel.

See " Intent to Prepare Generic Environ = ental I= pact State =ent of Handling and Storage of Spent Light Wa:er Power Rese:or Fuel", 40 F. R. 42801, Septa =ber 16, 1975.

(1)

There is no e=ergency need to rerack as the existing storage pool contains = ore space than is necessary to accoc=odate full core discharge.

(2)

The existing pool is able to acco==odate nor=al refueling discharges until 1981; therefore, failure to gran: the applica: ion at this ti=e. poses no-threat.of.1==inent' shutdown of~:he-facility.

Contention 2(b) cites the Nuclear Regulatory Co=-

=ission's " Notice of Inten: to Prepare Generic Environ =en:al I= pact State =ent on Handling and Storage of Spen: Ligh: Water Power Reactor Fuel" (hereinafter " Notice of Intent").

At the ti=e of the evidentiary hearing, the generic environ = ental 28 /

i= pact state =en: (GIIS) had only been issued in draft for=.--

In its Notice of Intent, the Co==ission specifically noted tha: in the interi= period, i.e., prior to issuance of g

NUREG-0404, March 1978; The final generic environmental i=cac: sta:e=ent has now been issued.

NURIG-0575, " Final Generic I= pact State =ent on Handling and Storage of Spent Light Water Power Reactor Fuel", August 1979.

Even though the GEIS has been issued, the Board is proceeding on the basis tha:.Co==ission policy stated in.the Notice of Intent is1 applicable un:11 = edified by the Co==ission.

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12 the GEIS, a licensing' action intended to a=eliorate a possible shortage of spen: fuel storage capacity could proceed, provided it was acco=panied by an EIA (10 CTR i 51.5(c)) or IIS (10 CFF.

i 51.5(a)) tailored to the facts of the case.

In each such licensing action, it is inc=nbent on the Board to apply, weigh, and balance five fac: ors, i.e.: (1) the likelihood that each individual licensing action of this type vould have a utility that is independent of the utility of other licensing actions of this type; (2) the likelihood that taking any particular licensing action of this type during the :L=e fra=e under con-sideration vould not constitute a co= tit =ent of resources that would tend to significantly foreclose the alternatives avail-able with respect to any other individual licensing ac:icn of this type; (3) the likelihood tha any enviren=en:a1 i= pacts associa:ed with any individual licensing action of this type vould be such tha: they could adequately be addressed within the con: ext of the individual license applica:icn without over-looking any cu=ulative environ = ental i= pac:s; (4) the likelihood that any technical issues tha: =ay arise'in the course of a review of an individual license application can be resolved within that con cx:; and (5) the likelihood that deferral or severe restriction on licensing actions of this type would result in substantial har= to the public interest.

The EIA exa=ined each of the five factors.

With respect to the firs: factor, Staff, Applicant, and Intervenor

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b 13 agree tha: the propose'd licensing action has independent utili:y in that it will allow Zion 5:ation to continue operating beyond 1953, when lack of spent fuel rearage space would other-vise force the S:ation to shut down un:11 the precored federal 2W storage facility for spent. fuel is in-operation.-~

Upon cross-exanination, Staff's witness es:i=ated the availabili:7

. 30 /

of so=e type of federal s:orage facili:y by 1986,-

but noted that while the Ad=inistration has proposed legislation to autho-rice the governnen to contrac: for or to build such facilities, 31 /

such legislazion has no: yet been approved ~~

In fur:her supper: of the utility of the proposed action, the proposed

=odificatier. will provide the Applicant with flexibility,revenl if an offsite facility beco=es available in tha:

it.will -

allew acce==odation of a full core should~ it be desirable for

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operational reasons to offload,-~'/

32 and it will allow = ore efficien: scheduling of spent fuel ship =ents to the spent fuel repository, since afte:Lopening of the repository it will re-quire so=e ti=e for co=plete ::ansfer of spent fuel fro = the 37 various reactors in the country.-~

In regard to the second factor, the proposed action will no: constitute a significant co==1:=ent of =aterial resources 34 /

(such as steel, al" 'nc=, boren, and carbide).-~

I: vill no:

29/

S:aff Ix. 13, 5 8.4.1; Intervenor's ? oposed Findings i=

~~

regard :o Applican: Proposed Finding 38.

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':t. 690, 692.

_3_U. Tr. 693.

3jy Tr. 691.

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1L foreciese simila: lice ~nsing actions at other nuclear power plants, nor will it co--'t in any manner the h*EC to'again authorice additional expansion of storage capacity a: Zion in Ic92, at which ti=e the proposed storage racks will be full if no spent fuel is shipped offsite in the interic.~

Based en evidence fro = the Staff' /

SA which was no:

challenged by the Intervenor, there is no indication of any cu=ulative environ = ental impacts which have been overlooked in addressing the. potential environnen:a1 i= pac:s associated with this specific licensing action.

With regard totthe fourth factor,-the Staff witnesses indica:e tha; : hey 'have~ responded to all technical issues con -

, cerning health, safety, and the environ =en: which arose during thei: review of the proposed license ameniment, and that these is sues are addressed in the EIA and :he Safe:y Evaluation.- 7/

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The In:ervenor stated tha: the technical issues have not been f

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res 1ved and as exa:ples pointed to tne various technical con-ten:icns at issue in the hearing.

Further, the Board on its own =ction asked the parties to address certain technical issues which were not explicitly dealt vi h in the Staff's EIA and Safe:y Evalua: ion.

In addi: ion, the Board subsequently reopened the reecrd to receive evidence regarding the safety of the

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Staff Ex. lA and 15.

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proposed fuel storage racks to be used in the spent _ fuel pool.-~

The L3 card interprets the question raised by. the.

i fourth fac:or to be whether there are technical issues in this. individual-licensing proceeding 'which re=ain unresolved.

The Board finds that their are.no technical issues ~ which have

. arisen during the review of this license amend:en: applicatien which have nc been resolved within the centext of this proceeding.

In~ regard to the fifth factor, deferral or severe restriction of this licensing action would resul: inLsub-stantialRharm :o the public interes:.

Without such action, evidence indica:es that the Zion S:ation will lose full core discharge capabili:7 in 1931, followed by cer:ain shutdown in 1983.

Af ter 1951',' there: would bena possibility of_ shutdown a:T any :i=e due to lack of. space #n the. spen: fuel pool to accec=o-date offload of a full core.29/

Shu:down would har: the public interest in tha:-Applicant's ability to meet electrical energy needs could be adversely affected, or :he energy needs might have to be =et by plants which have greater' environ = ental i= pact 40/

or which are less economical to operate.

In regard to urgency to i=ple=ent the proposed =odi-fica:icn, Applican: testified that while there is no acergency need to install absorber racks at Zion by fall 1979 (the nez:

1 juy Board Memorandus and Order, Septe=ber 14, 1979.

juy Staff Ex. 23, i 2.0; Testimeny of Gary G. Zech (Zech) on Conten: ion 2(b) at p. 2. following Tr. 607.

,4y S:aff Ex.13, j 8.4.5; Zech at pp. 2-3; P1L=1 at p. 6.

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'Ly scheduled refueling outage),

rep?neenent of the spen:

fuel racks should' proceed as soon as possible to : 'nini::e occupational' exposure, since the less spent fuel in the pool at the ti=e of reracking, the less tice and labor will be required to effe:: the change.

However, any additional occupa-tienal exposure incurred by delaying reracking until'after

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fall 1c79 would still be well within limits se: forth in 10 CTF,Part 20.

The Board finds, accordingly, that while deferral of :he spen: fuel pool =odification vill not cause i

occupational exposure to exceed licits, it will be in the public interest to keep exposure to a =ini=un by reracking as 4

soon as feasible consistent with imple=entation of adequa:e quality assurance progra:s.and reracking procedures.

g P11:1 a: p. 6.

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Need for Centinued Doeration of Zion Station Contention 2(c) states :

Should it be necessary to shut dcwn the Zion facility, pendin nate..away fro = g the develo:=ent of an alter-reactor facility, the Ac has not shown that the ce== unity cur;cn:plican:

.y being served by Zion would be adversely affec:ed eco-no ically or by experiencing loss of electricity.

(1)

The Applicant has not explored' the possi-

'bility of =eeting curren: de=and by increased use of underutilized fossil-fuelad plants serving the Edison syste=.

(2)

The Applicant'has not considered curtailing the output frc= Zion in conjunction with a conservation progra= and coordinated rr.::e s: rue:vre which would reduce :he de=and for electricity in the area served by Zion.

T Applicant and Staff sub=1:ted :esti=en'y in-regard-rf I

43/

to Con:entien 2(c). 7 Shutdown = ofiZion. uni:s in the early 1980's could adversely affect Applicant's ability to =eet elec-4 trical energy needs and could force opera:icn of other plants

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which are less econe=ical :o operate, with resulting increased costs which would be borne by custe=ers.

Applican: esti=ated 44/

an average cost of $441,000-- per day with both Zion units out 45/

of operation ~~ or $178,000 per day with one unit out of i

6 43/

Tes:L=ony of Roland Kraa:z (Kraat:) following Tr. 815;

~~

Testi=eny of Argil L. Toalston (Toalston) following Tr. 845.

l av Expressed in constant 1978 dellars; does not assu=e any inflation rate or escala:Lon ra:e in replace =ent power costs.

Tr. 836-7.

4jy Kraatz'at p. 2.

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operatien.

S aff's witness estimated ~an average 'ost of I

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$240,000 per day with both units out of operation.~~ ' S:aff-also estica:ed replacement energy costs of $3.6 million per 1

.conth if Zion were operated at half load, a reasure assu=ed to redu:e genera:Len of spent fuel by a factor of two'end thus extend available s:orage capacity of the spe=t fuel pool to L S/

late 1956.~-

Differences in Staff's and Applicant's es:i=a:es 1

of costs were attributed to differences in assu=ptions related to two factors, i.e., source of replace ent power and capacity i

fac:cr-Staff assumed a =uch greater reliance.on cheaper 49/

high-sulfur coal burning units although Staff's witness ad-

~~

citted tha: use.of high-sulfur.ccal'=ight not be per:1:ted due 50' to environ =en:al censidera:icns.~~'

In regard :o capaci:y fa::or, Staff's esticate of 55 percent wa's based on nuclear pcwer plants in general, rather than on actual capacity fae: Ors (67 percen:) experienced at Zion Station in the past two years.

Because of the conserva:ive assu=ptiens used by the Staff, Staff's vitness noted that actual replacement costs would exceed 51/

his esticate.

~~

46/

A: the hearings Kraat: testified tha: :his cost would be I

~~

$262,000 per ccy (Tr. 832); however, by affidavi: dated July 9 1979, he stated that his testi=ony was in error and I

~

supplied the lower esti= ate given above.

B/

Toa15 cn at p. 2.

fjy Staff Ex. 15. 5 7.6; Tr. 843, 847-8.

l f__9/

Tr. 849, 871.

l j0y Tr. 864-B65.

jg/

Tr. 850.

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4 19 Applicant's calculatiens are based on co=parison of. cost of fuel used in generating electricity a: Zion S:ation with equivalent fuel-related costs for other nuclear, ccal, and oil-fired generating ' units (pri=arily wi:hin the Co--anwealth i

Edison Syste=) which would be required to replace Zion's 52/

output.

o Applicant also esti=ated that the' portion of Zion's l

cu put which would be replaced by oil-fired generating units v:uld require burning approxi=a:ely 850,000 gallons of oil per 53/

day (300 =1111on gallons per year).--

Applicant's witness further noted adverse effec:s on reliability. cf electric supply should the Zion uE.its becone.

, unavailable:in the early 1980's in that the esti=ated' peak load reserve levels during the period 1982 to 1985 would be, during

=es: years, subs:antially lower than the already sonewhat low reserve c lterion of 14 percent:

i 1982 2.3%

1983 10.1%

i 1984 17.1%

1985 12.1% Sy 55/

In regard to effect of energy conservation prac: ices on need for power, Applican: encourages energy conservation through cus:o=e:

f 5_2/

Kraatz, A :ach=ent A.

Sj/

Kraat:, p. 4: Z:. 815, 837.

jg/

T. 812; Kras :, Attach =ent B.

55/

Based on proj ec: ion of increased peak lead de=and at an annual race of 4-1/2 percen.

Tr. 820, 838.

i j

a

)

l 20 infor:ation programs and through ti=e-of-day rates for large industrial custorers, and an experi= ental tire-of-day ra:e us prograr.is underway for residential custoners'"-

Bowever, such teasures have only a s=all effec: on operation of the

.y Sta:Lon since it is operated in a baselcad canner. -

l On cross-exacination, Applicant's witness ad itted tha: Applicant has never sent out energy conservation infor:2-1 cm /

tion with cus:o=ers' electric bills, and he authenticated a cendensed s"- ary of Applicant's rates which indicates tha:

the rates charged to ec==ercial, industrial, governmental, and schcol custo:ers reflect a " declining block rate structure",

i.e., the greater the a cunt of electricity such custe=ers us e,

ed the icwer the ecs: per kilowa:: hour they pay.~~'

With regard

0 energy censervation, Staff witness :estified that, since a nuclear unit serves the base load rather than peak load portien of the load cycle, a reduction in energy de=and would nc:

affect demand upon a nuclear unit.

If censervation measures tend :c shif: the peak lead frc: 7.he peak to the base, the existing nuclear unit becc=es even =cre irpcrtant.

A: the sa=e ti=e, if base load is reduced, additienal energy generation will likewise be delayed er reduced so tha: the result is effec-tively the sa.ne.

.!g Kraat: at p. 4

.f.7/

Kraate at pp. 4 5.

jdV Tr. 822.

A c' Intervenor's Ex. 4; Tr. 826-29, B30-31.

_6_7 Tr. 862-63.

1 g.

4'

\\

21-The Board finds that the proposed acticn, in itself, 61/

will not significantly. affect the hu=an or othe.: environ =en:7#

I 62/

and therefore, no consideration of alterr,4:ives:is required.~~

However, were such consideration required, the Board finds the preponderance of the evidence to substantiate need for continued 5

operation of the' Zion Station unit a: least through the 1980's in view of.the uncertainty in constructica schedules for other 63 /

genera:ing units in the Co==onwealth Edisen Systa=.

-~

3 l

l l

l t

l l

l J5'd See Conclusions of Law,' infra, paragraph 62/

Portland General Ile::ric Co. (Troj an Nuclea Plant)'

l

' ~~

XEA3-531, 9 NRC 263 (1979).'"

JLy Kraa:: a: p. 3.

9

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.e.3 2.

Accidents i

1.

Drop of Heavy Obj ects.

Contention 2(f) sta:es :

There has been insufficien: develop =ent of credible accident scenarios, yer exa:ple:

(1) there is insufficient documenta:Lon to establish the ce: hods by which the /.ppli-vill positively preven: the covenen:

can of heavy cojects, such as shipping casks or e=pty fuel racks, over the poci during modification; thus, accidental droppings of such heavv obj ects, which could lead to unacce table damage to spent fuel or the pool $1ner and consequen: release cf radionuclides, has not been precluded.

(2) there is insufficient infor=ation regarding the methods by which accidental da: age to s:cred spent fuel asse:blies vill be pre-vented during the instal"a:Lon of the new poisoned spent fuel s:orage racks.

In order to preven: da= age to spent fuel asse=blies s:Ored in the poc1, procedures vill be utiliced such that neither the cid ra:ks being re=cved ner the new abscrber racks which are 6u being placed in the peci vill be carried over the spent fuel.~~

i The rack replace:en opera:Lons will be supervised by fuel har.dling fore =en, whc have a li=1:ed senier reactor opera-ter's license.11!

A least one of the fuel handling forenen i

will be present a: all times.

They vill direct the activities

,.- ~.-.

jj,'

Testi:eny of John 7. Leider, Jr. (Leider) at pp. 3-4 fol-loving Tr. 759; b'EC Staff Testi=cny on Con:ention 2(f)(2) at pp 1-2 fc11oung Tr.1960.

juy T:. 15ES, i++w e

r 23 of the fuel handlers, who will receive refresher training before each se=1-annual refueling outage".

In'addi:icn,' prior to the proposed rack replace =ent, they will review the proca-dures, the lif ting rig, and' the techniques to be used, and they will conduct a test lift using the =ain crane and the 66 lifting fra e attached to a new rack.~~

Assurance tha: racks.will no: be lifted over stored spent fuel during the proposed rack replacement _operatien will be provided during =uch of the rack movement by crane _ inter--

locks which preven: loads moving over the pool.

During those portions of the rack replacement which =us: involve move =ent L

over. :he pool with the interlocks bypassed, writ:en procedures

• will be in' effect. to prevent move =en:

of_

l

'the racks over the stored spen: fuel.

The interlock is bypassed through use of a key which is in the possession of the senior licensed fuel handling fore =an.

Ad=inis::ative controls will be required during portions of the rack replace =ent which involve move =ent of the racks over the pool because of the difficulty of devising =echanical interlocks to restrict crane move =ent when a nu=ber of directional coordinates are involved.

The ad=ints::a:ive cen rols on rack movement will be set forth in wri:>:en procedures and enforced by the crane operator, under the direct supervision of a licensed fuel handling fore =an.

The v:itten procedures fo: rack installation are being developed at 67 /

Zion 5:a: ion and have not yet been finalized.-~'

fy Leider at p. 3.

Jg/

T:. 1890-1891, 1896-1897, 1913.

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i 24 A spent fuel shipping cask will not be carried over the poc1 during the proposed rack replace =ent operatien.

Such casks will ne: be involved in the proposed modifica: ion.

Fur-ther :re, there are no casks in the plant, and there are no 68 /

m l

plans to bring casks into the plant.

By le er dated April 8,

1976 the Applicant made a co==i =ent to notify the NRC in advance should it tec0=e necessary to handle heavy loads in the vicinity of the spent fuel storage pool. 1/

6 In addition, the Staff intends :: issue a technical specification which will not allov the handling of any leads of greater weight than a single fuel asse:bly plus the spen: fuel handling tool over stored spen:

. fuel.

The. technical specification will not allow the cova=ent cf a shipping cask or an erpty fuel-rack over the c:ored spen:

fuel during :he proposed rack replace =ent.

This technical specification will be included in any licensing amend:en:

issued :: perni: the proposed rack replacement.

The consequences of hypothetical drop accidents related to the proposed rack replacement were considered.

These include the drop of a rack onto the poci floor, the drop of a fuel asse:bly l

en:o a s:crage rack during the transfer of the stored fuel from the old racks to the new racks, and the drop cf one fuel asse=bly being transferred onto another s:cred fuel asse:bly.

JL3' Leider at p. 2; Tr. 1903.

6C/

T;, 1930-1931, 70/

S:aff Ex. LA (SER), 5 2.3: Tr. 1963, 1965, 1971.

a J

25 The drop of a rack onto the pool floor will not result in =ajor da= age to the pool structure allowing gross 7./

2 leakage.1_

Although this drop accident was no: specifically analyzed, during the original plant design and safety review it was deter =ined that the drop of a =uch heavis: shipping cask into the poci vould not result in through-the-slab 7 2/ -

cracking and gross leakage.--

It is credible tha such a 73 /

drop'could tear the stai=less steel pool liner.--

Beneath the liner a network of channels is e= bedded in the surface of the concrete pool. structure which would collect the water draining through such a tear.

The wa:e: collected in this

=a=ner is piped through six 1-1/2" pipes through'the concrete valls of the pool':o'atcollection'cank'for': processing.as;

~

e liquid radwas:e and recycle 'in the plan:.. 'I: is anticipated

~

that pool water would not escape through the concrete structure of the pool to the outside environ =ent.

At the maximu= drainage rate through these pipes a =ini=u= of 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> would be available either to repair the liner or to add =akeup ve:er.

Te=porary 74/

i measures can be taken to reduce the leak rate.

Da= age to l

1 71/

Testimony of To= R. Tra== (Tra==) at pp. 9-10 following

~-

Tr. 564; Tr. 1920-1931; Testimony of Gary G. Zech (Zech) on Contention 2(f)(1) a: p. 2 following Tr. 1958.

21/

Tr. 1966-67.

11/

Tr. 1903, 1970.

74/

Tra-= at pp. 10-11; T. 1911-12.

1 l

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1 26 the liner which r.ight result frc= the drop cf a fuel cask would be within ' the. takeup capability of the various water sources that exis: at the plant and would envelope the da= age w'.ich tight resul; fro ='the drop of a rack. E/

The consequences of a drop of a single fuel assen.bly onto one of the new storage racks was analyzed. UI The assc=bly.

was hype:hesized to drop fre= a height of 24 inches, which.is the taxinut height at which such an asse bly can be transported

[

over stered fuel.1'7/' The criterien used was that no structural part cf the rack which is recuired to caintain E-effective less than 0.95 should be stressed beyond the elastic licit.

The par: ef the rack which could be dataged vill'notEcostain neutron absorber =aterial.

Therefore, no increase in'K-effective should occur as a result of this accident.El The defor:ation at the top ef the fuel rack resulting fron such an accident could te=rcrarily hinder the withdrawal of a fuel asse=bly s:cred in-1 the tube at the tinc.

However the tubes are cade of light cate-rial,which could be straightened so tha the asse=bly could be recoved.7C/

75/ Tr. 1980-1951; The sources of =akeup water at the Zion Station are discussed infra, in response to Soard Questien 4, pp. 84-86.

r 76/ Testi=ony of Cba.:1 Anwar Hossain (Hossain) folloding

~

Tr. 1700; Ae (Licensing Report), S S 3.4,

3. 5, an d 3. 4' p li c ant ' s Ex. 4

.4.

E/ Eossain, Attach =ent 3.

H/ Tr. 1713-1717.

79/ Tr. 1717-1715.

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4 The conseque~nces of a fuel assembly dropping directly.

on top of'ano:her' fuel assa=bly fro = a height of 2-1/2 feet were also analyzed.- No damage to any of the fuel rods in either 80/

asse=bly should occur as'a result of such a drop.--

During the review at the operating license stage, the design basis fuel handling accident considered was the. drop of a spent fuel asse=bly. onto the spent. fuel pool floor and the breaking of all the ' fuel rods in the assembly.

The analysis of the postula:ed acciden: is docu=ented in Section 14.2.1 of the Zion Final Safety Analysis Report (FSAR), where 'it is indi-cated that the plant's safety and clean-up systa=s are adequate t

o keep the consequences of this occurrence to within 10 CFR 81/

par: 100 lici:s.--

The additional handling required to shift stored fuel assemblies fro = the old racks to the new racks will 82/

increase the probability of a fuel asse=bly drop.--

The reracking will necessitate about 400 extra fuel = oves, which would add less than 1 percent to the total nu=ber of fuel moves anticipated during the plant's life:ime.

The consequences of l

a fuel asse=bly drep will not be increased by the proposed raracking.- /

83 Further, the consequences would be less than j[y Tr. 1964-1965, 1982-1983.

8 L/

Tra== at pp. 25-27; Hossain at p. 3; NRC Staff Testi=eny en Contention 2(f)(2) by John J. Zudans (Zudans) at p. 3 following Tr. 1960; SZR S 2.3.

j[y Tra== at p. 27; Zudans a: p. 3.

~

j[y Leider at p. 8; Tra== a: p. 27.

r 28 the consequences of dropping a fuel assembly freshly re=oved fro the rea :or during refueling, which was'the assu=ption used for the design basis fuel handling acciden: $$f There are four loads lighter than a fuel assembly vhich are handled over stored fuel..These are the spen: fuei J

handling tool, the burnable poison tool, the rod cluster con-trol changing fixture; and the thimble plug.

Although lighter than a single fuel-assembly, these four loads could develop Sreater kinetic energy because of greater potential drop heights.

Accordingly, the Staff intends to issue a technical specification change which will require that none of these loads be transported ~at'a heightegreater'than'2efeet"over the storage racksss/

t The Scard finds that the Applicant and the Staff have provided sufficient infor=ation vi h respe::'to the ce: hods, procedures, and technical specifications which will be utilined to prevent accidental da= age to s:cred spent fuel asse:blies or the spen fuel pool liner during the installation of new spent fuel storage racks.

Therefere, the 50ard finds that the risks associated with accidental damage to the stored spen: fuel or to the pool or its. liner during the proposed 1

codification are su:h tha: the modifications can be conducted without jeopardizing public health or safety.

l

- v Zudans'a:

3.

a e

t r,

JUV SER, i 2.3.

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29 2.

Pool Boiling.

Contention 2(g) states:

1 l

The Applicant's di teussion of spent fuel boiling is inadequate in that (1) there is no consideration given-to the possibility.

that the pool might boil, and (2) there is no discussion of possible damage to. fuel cladding or of'the consequent release of

. radionuclides under such. conditions; therefore, there is no assurance.that public health and safety will not be endangered.

In addition, the heat removal capacity of the spent fuel pool cooling system has not been shown to oe adequate to suppert the expanded pool capacity.

The Zion Station spent fuel pool cooling system has two cooling trains, each of which consists of a pucp, a heat exchanger, piping, and= associated'. valves and instrunentat!.cn.

The sped fuel pool cooling system is itself cooled by the Zion Station component cooling system, which includes five pu=ps, three heat exchangers and associated piping and valves.

The ec=ponent cooling system transfers the heat load fre= the spent fuel pool and other station heat sources (primarily the residual heat renoval systems, which cool the reactor cores after shutdown) to the service water systa=, which discharges 8y the heat into Lake Michigan.-~ The details of these cooling '

systa=s are set forth in Sections 9.3, 9.4, and 9.5 of the

/

87 FSAR and the accompanying FSAR charts.

l 31/

Tra=m at pp. 12-13.

17/ Applicant's Exs. 3 and 7.

.,..,m

~,,.

~-

l 1

1 i

i l

30 I

The Applicant analysed the spent fuel pool cooling sys:e= and concluded that either of the two spen: fuel poci cooling syste trains is sufficient by itself to prevent the SF?

vater fro: boiling, even with 2112 spent fuel assemblies e:cred in the poc1, wh:ch is the caxt== capacity covered by the applicatien. L/

E.

This conclusion is based on the=ohydraulic analyses it which a pre; :.e:ary co=puter code named PD01.ET was used to calculate bulk fuel pool water te=perature as a function of he:: input frc= spent fuel, heat reje :icn through the pool coeling syste=s, pool vater mass and ti=e.

This showed that fer the vorst case considered the maxi = te=pera:ure C^#

reached is 150' ?. J The v:rst case ass =ptions were that an entire cere of spen: fuel (193 asse=blies frc= one unit) is discharged ten days folleving the c =letion cf a normal ene-third core refueling discharge frc= the other unit.

This was assumed :c 1

91/

t o er at a time when only One heat exchanger was operating.-

In its Order dated May 1,1979, the Board inquired whether the fuel po:1 vill reach boiling te=perature under such circu= stances where the full core discharge f c= one Zion uni: felievs the' core refueling discharge frc= the other Zion unit by 10 days or less.

The Applicant's vi: cess tes:ified that considering an existing Zion technice.1 specification requiring that fuel transfers not 3'

Tra-at p. 12.

c9/

Trs

, A pendices 7 and G; Licensing ?,ep ::, 5 3.6.

r 9._3. ' Tra= at p.13, and Figure 3-22 of ' Appendix G.

9_1/

Trs-at p. 13.

e 31 begin unti1~100 hours following reactor shutdown, it is no likely that a full core discharge could-be acco=plished in less than 10 days: following co=pletion of a refueling discharge. -

However, the Applicant indicated that it would be willi =g to accept a. technical specification-restricting fuel move =en:s during core unloading through the i= position of a ten day 92/

=ini=u: ti=e for ce=pletion of full core-discharge.--

Both Staff and Applicant indicated that there is no safety reason wh'ch would ce=pel the Applicant to move fuel more quickly frc=

the reactor into the span: fuel pool.

However,'there =ay be an econo =ic penalty associated wi:h such a delay.- /,

93

+

A calculation of natural circulation flow' rates -

within the pool was perfor:ed alson o deter =ine.cher=al loads en the proposed absorber racks and the potential for localized boiling.

The =axi=u= increase in water ta=perature as a result of natural circulation flow up through a fuel asse=bly in a storage, tube was found to be 32.4' F.11/

These calculations e= ploy a proprietary code na:ed CIRCUS in which the peak power-spent fuel asse=bly is assu=ed to, be stored in the middle of

he pool in an east-west row of average power spent fuel asse=blies.

Water flow in this row of fuel asse=blies is assc=ed to follow a path fro the top of the pool, down the side of the pool (in the 9-inch gaps between the proposed new absorber racks 92/

Tra== at p. 19.

I cl/

Tra== at pp. 17-19; Tr. 1508-1510; Tr. 1674-1676.

gg/

License Report at p. 3-51; Tr. 1753-1754.

ears m.

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l and the east and wes: sides of the pool), through the 7-inch high flov area undernec:h the racks, through the 5-inch ho".e in the be::o of the fuel storage tubes, and up through the s:Ored spent fuel assenblies to the top cf the pool.

This

=odel gives an upper bound for increase in va:er te=perature within the s:crage tubes, because it ignores flow fro: the north and sou:h sides of the pool and flow between the racks.

Further, the rajor resistance to flow of cooling va c: occurs within the s:cred fuel asse:blies the selves.

For purposes of :he calcula:iens this resistance was taximized by assuring that the fuel asse:blies are stored with control rods present.

This is no: usually done at Zion excep in the case of a full'

/

=cre discharer..=-

The perfernance of the spen: fuel pool coeling syste:

is related te the c:her hea: leads which are transferred by the e penen: ecoling syste in tha: such performance is a fun::icn of the te=perature of the ::=ponent cooling syster l

vater.

Postulated plant upse: conditions such as a loss of cociant acciden: ("LOCA") could increase the te=peratures in the eo penen: coeling syste and therefore possibly cause a 9/

te=pertry reduction in spent fuel pool cooling.~~

Neither p00LET ner C:RCL*S is modeled to calculate the te=perature of the ec=ponen cooling syster during a LOCA.

Instead the Applican 95/

Licensing Report at p. 3-51; Tr. 1475, 1745-1750, 1754-1757, i<wc u. 4 1//*,

96/

Tra-- at p. 29; Tr. 1460-1461.

_ _ ~ -,

m

a 4

33

=ade allowance for such conditions in its calculations in its 97 /

choice of the ce=ponent cooling water ta=perature.--

The assu=ption was made that the te=perature of the component cooling. system water at the inlet to the spent fuel pool heat exchangers was 80' F.

On cross-exa=ination, Appli-cant's witness ad=itted that the. corresponding tamperature in the FSAR is 95* F.

The witness defended this choice by observing that the 95* F te=perature asse=ed in the FSAR is derived fro:

a water ta=perature in Lake Michigan of 80' F which is conserva-tively high.

The use of 80' F co=ponent cooling water assu=ed a lakewater te=perarure of 70' F.

The records of lakevater te=perature in the Zion-Final Environmental Statement, Appen-dix D, indicate that this lower te=perature is conservative.

. in that the =axi=== recorded average =enthly lakewater te=pera-ture at Waukegan is 63* F in August.

In contrast refuelings

'nor= ally take place in the spring and fall of the year when l

lakewater ta=peratures are less.

If a value of 90' F for the ce=ponent cooling water te=perature had been used 'the pool r

98/

te=peratures would have beer. about 15' F higher.--

Using its own analytical methods, che Staff performed calculations of spent fuel pool cooling capacity.

Their calcu-lations involved a hypothetical situation s1=ilar to the worst 11/

Tr. 1464, 1466.

11/

Tr. 1454-1455, 1459-1460, 1496-1500.

O

,_.-w n

i 34 case assured by the Applicant in which a full core with a full inventory of fission products is offloaded, filling the last of the 2112 spaces in the pool ten days af ter the thirtieth refuelir.g.

The carl =un possible heat load in the spent fual poc1 under such circu= stances is calculated to be 51 x 106 Etu/hr.

If one of the spen: fuel pool cooling trains is not operative, the outlet water te=perature vould rise to about 170' F.

Eased on :hese calculations the Staff concluded tha: the present cooling capacity for the Zion spent fuci pool is adequate for the proposed C.. /

.i m e. 4 2 4.m a o. s.on,~~

2 m

Intervener's testi=ony indicated that boiling could occur in the r. pen: fuel pool under two circu= stances.

The firs circu: stance vould be if there vera no cooling cf the water in the spent fuel p::1.

A :ording c the witness this could o::ur if the ceroonen co:lin.t s.yste= beca=e overloaded under rea::::

a :ident conditions.

The second way boiling could occur would be under hea: Icad conditions sitilar to those analyzed by the Applicant and the Staff, in which a full core discharge follows cc pletien of a nor:21 refueling discharge by ten days or less and oni.v ene spent fuel heat exchanger is operative.

In this

,cn case it was predicted localized boiling could take place. -

og/

NRC Staff Testi=ony on Contentien 2(g) by Richard M. Lobel, Ja:k N. Donohew and Edward Lant: (Lobel, Don:hev and Lant:)

a: pp. 7-9 following Tr. 1632.

120/

Dire:: Testimony of Marvin Resnikoff (Resnikoff) at pp.1, 4-10 following Tr. 1526.

i I

35 The acciden: conditiens referred to in Intervenor's testi=eny involved a scenario in which it'beco=es necessary to cool down both Zion reactors si=ultaneously using the residual l

heat.re= oval systa=.

Under such circu= stances, he calculated; that the total hea: load on the compenent cooling syste=,. :aking into account the =azi=u=.hea: lead produced by the spen fuel pool during the 33rd refueling discharge, would exceed the design hea: transfer capability of the co=ponen: cooling systa= heat exc' hangers given in the 75AR.10.'/ '

Hewever on cross-exa=ina: ion the wi': ness ad=1:ted that he had overesti=a:ed the total hea:

lead on the co=ponent cooling systa=.

Further, that in using the design heat transfer capability given in the 75AR he had

underesti=a

ed the. =axi=u= heat _re= oval capabili:7 of-the t-102/

ce=penen: cooling sys:e=, which could be =uch greater.

The -

witness could not hypothesize any circu=s:ances under which t

.the Applicant would not be able to =aintain cooling on one reactor unit thrnugh the stea= and power conversion syste=.

Therefore he indicated tha the heat lead f:c= a: lear: ene J

1,01/

Resnikoff at pp. 6-8.

102/

Tr. 1543-A4, 1546-47, 1575-76.

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3 c.

reactor unit would ne have to be put on the co=ponent cooling 1 ^. 3/ 10,' '

sys:e= under such circu= stances.

The witness also conceded

,ce/

m...

3..c 3 c 4 1.

.,_j 101/

The witness observed tha: this answer requires an ass==p-tion that given a design basis LOCA at one unit at Zion, personnel could operate the second unit.

The Board takes no: ice cf General Design Criteria nu=bers 5 and 19 cf 10 CTF. Part 50 Appendix A which state:

Criterio an d e c=c on e_n. _5,

-- S h a rin t. of structures, svste=s, nts.

Structures, syste:3, and ce=po-nents i=por: ant to safety shall not be shared a eng nuclear power units unless it can be shown tha such sharing vill not significan:17 i their ability te perfor: their safety fune: pair

Lons, including, in the avent of an acciden: in one unit, an orderly shutdevn and cocidown of the remaining

....z..,

C. <. e.<,

Co...o., _.--_.

.ow-_

n........

i shall be prev?ied frc= which a :icns can be taken te operate the nuclear p ver uni: safely under ner:21 conditions and to caintain it in a safe condition under accident cendi:1:ns, including icss-ef-coolant a :idents.

Adequate radiation prete::icn shall be provided to perni: a :ess and occu.sano.v of the centrol ro:: under c::ident con-ditions vi:hout personnel receiving radiatica l

exrostres ir excess of 5 re: whole body, er its ecuivalen: to any par: cf the body, f : the duration el the accident.

Eeuip=en: at appropriate locations outside the centrol ro = shall be rrovided (1) with a desitn s.s....s

..e

e. s..e. e a c :...,

c a p a..,1.4. -.;

.e s

.... -. n.

e.-f.

including necessary instru=entatica and controls

. o a :... a.r -. u.. e,.n.. z.

e z

n a su.e con... inn u.n..a.m, n

het shu:down, and (2) vi:h a po:en:ial capability f:r subsecuent cold shutdown of the reacter through the use of suitable procedures.

i I

I I

e f

j o

i

\\

37 that even if the co=ponent cooling systa= were subjected to the extre=e heat leads described in his testimony, this would

[

not cause a =e.lf=ction of the-coc:ponent cooling systa=.. He agreed that it would require = ore than a single failure to cause the co=ponent cooling systa= to cease to function.2.1I 1

Intervenor's witness esti=ated that the bulk'5??

water ce=perature would rise to 142.5* F in the event of a full-

' core discharge'following a nor=al refueling discharge by ten days with one heat exchanger operative.

However, he further postulated that the 5-inch hole at the bette= of a_ storage tube which nor= ally allows entrance cf cooling water, could beco=e blocked.

Under such circu= stances, he predicted that-.

localized boiling.could occur.ng/. 'On cross-exa=ination,.he-

.i explained that the hole at the botto= of a tube could become blocked if for example a shoe fell in the pool.

However, even if this occurred he indicated that the resulting localized i

boiling would not boil off enough water to expose the top of the stored fuel asse=blies.

He indicated-that he veuld not be concerned about damage to the particular fuel asse=bly fro:

I such localized boiling.92/

1 j

In its May 1, 1979 Order denying motions for su==ary disposition, the Board directed the parties to address whether ljy Tr. 1548-1549.

Q{/

Resnikoff at pp. 9-10; Tr.1550-1551 l

10]/

Tr. 1552-1554.

s

3e.

the Zion spen fuel pool cooling syste: and the co=ponent coeling syster mee: the single failure criterion as defined in 10 CTR Par: 50, Appendix A.

The conponent cooling syste=

the single failure criterien. g r does =ee However, the spent fuel pool cooling systen does not teet the criterior.

A single failure of the pipe which returns water to the pool fro: the spent fuel pool pooling syste: could resuit in a loss of spent 100/

fuel pool cooling ability.~-

The Staff testified that the single failure criterion is not applicable to the spent fuel 33u-/

pool cooling sys:er.~~

The Applicant indicated that the Zion spent fuel pool meets the applicable general design criterion in 10 CFR Par: 50 Appendix A, which does no: in:crp' orate the c' y' sintle failure criterion, i

L2p Tra== at p. 20, Tr. 1495-1495, 1510-1513, 1676, 1955-1955.

(c c' Tr. 1514, 1676.

Lig' Tr. 1654 3,3/

,w?c.iHas, i

rce s,. y s

112/

Aorlicant's vitness indicated that the applicable criterien

'is' General Design Cri:erion 61, "yuel Storage and Handling

~~

and Radioactivity Control", which states:

"The fuel storage and handling, radica::ive vaste, and other svste s which =ay contad: radioa :ivity shall be designe'd to assure adequate safe y under normal and pos ula:ed accident conditions.

These systems shall be designed (1) with a capability to perci: appropriate periodic insce:: ion and testing of cocpenents i=portant he safety, ('2) vi:h suitable shielding for radiation pro-tectien, (3) with appropriate contain=ent, confinement, and filtering systers, (4) vi:h a residual hea removal capabili v havif.g reliabili:y and testability that refle::s l

the icoorhance to safety of decay hea: and other residual heat r'e= oval, and (5) to preven: significant reduction in fuel storage coolant inven:ory under a; ident condi-tions."

Tr. 1495.

39 Nevertheless', a single failure of the inlet. pipe which returns water from'the spent: fuel pool' cooling syste=

113/-

to the pool'is a credible event.

There is testimony in the 1

record of the consequences of such an even:.

Once cooling capability is lost, the Applicant esti-

=ates that it would take'at least 8.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.to boil, asse-d ng the pocl were ini:ially at 150' F, which is in excess of the 114/

nor=al pool temperature.

The Staff's estimate is about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, starting fre= 125' F (11' F per hour).

Intervenor's

(

witness esti=ated 6.3 to 12.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> starting from 150' F, which 115/

is in the sa=e range as the Applicant's and Staff's estimate.

Applicant's witness-testified' that before-boilinge

-r would occur :the Applicant:would. have-sufficient ti=e * :osfix a -

4

~

4 broken cooling syste= or to ade takeup cooling water which would 11W 117/

drive down the ta=pera:ure of the spen: fuel pool.--

The Staff testified that there would be sufficient time before boiling co==enced to establish a flow of =akeup water to the 11W pool equal to the maxi =u= possible bo11off rate.

Intervenor's witness agreed that the question of boiling is negated if a continuing source of readily available =akeup water for the Zicn 11_3/

Tr. 1514, 1677.

11_lv Tra=m at pp. 20-21.

1 115/

Resnikoff at p. 2.

116/

Trar= a: pp. 21-23.

117/

The sonrees of =akeup water at Zion Station are described in more de:til in response to Board Question 4, pp. 84-86.

118/

Lobel, Donohaw and Lantz at pp. 8-9.

f

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., i.i.

m#_,

,w.

e.y.,,

-.,.,r,.

..,. - -.. ~,., -,,

,,,..,,.-,,>.y..,.,-.-m,-

,-m.

40 spen fuel pool is guaranteed.

he also agreed that the sources of makeup water a: Zion Station vould be adequate, but only if it would be possibic :o deliver the water to the pool under all ci: u= stances.

For this reason, he suggested that the makeup water systa=s be fully auto =ated so that human interventien is

,, ~

.?

u.necessary.

The pu= s and heat exchangers of the. spent-fuel poci j

coeling syste and the controls to the =akeup water supply are located in a roc: in the fuel building which has valls and ceiling'of concrete.

Such equipment cnd controis are accessible under anv circu= stances (even if one of the reactors should r

experience a 1.00A) through a railroad trackway entrance to the fuel building, and this could be done without going past the 527 s--

sc. en ruel o.c

,2.

In its May 1, 1979 Crder, the Board asked the parties to address, if boiling

occurs, the possible effect en the integrity of the claddin on fuel which has been s:Ored for a e

long period cf ti=e.

There currently is no basis to expe : that aged fuel vill be s eepardized b,v beiling conditions in the spen:

d e,/

fuel pe:1.

Further, leakage of radioactivity fro: a s:cred spen: fuel asse=bly during spent fuel pool boiling would not be i id Tr. 1556-60, 1570.

20' Tr. 1559-60, 1455-55, 1500-01, 1655-S9, 1859-63.

Q1/

Testinony of A. Burtron Johnson, Jr. (Johnson) at p. 10 following Tr. 1057.

e m-ww-m

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On U

41 r

significantly different fro ='that observed during tor =al. pool operation.'"/

19' Intervenor sub=1 :ed no testinecy dealing with the effect of boiling on stored spent fuel in conditions where 123/

the stored fuel is not exposed to the air.--

If boiling were to occur so=e non-volatile radioac-tivity nor= ally present in the pool water could be entrained i

in water droplets in the air above the pool.

These droplets would cendense ou: on surfaces in the fuel building or ven:1-

{

1ation ducts or be removed by the building filtration syste=.

3 After boiling ce==enced access to the pool area would have to be con: rolled to caintain exposures as low as reasonably achievable, but people could still an:er the pool area.23/

1 1

Conditions of high hu=idity caused by pool-boiling T

' ' c~

if continued for very long, could disable the prefilters and HIFA filters in the building filtration systa=.

However, boiling would no: need to be allowed to continue for such a length of time.

Further, the Applicant could replace the filters even during conditions of high radioactivity within the fuel (27 Lobel, Donohew and Lant: at pp. 4-7.

U f Tr. 1525.

j (19 Lobel, Donchew and Lantz a: p. 6; Tr. 1485-86, 1651-52.

F t

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e t

• v

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4.9 building.

Ac:crdingly, changes to the fuel building fil::a -

tion syster are not recuired to acccun: fer the possibility

. u..a.

n e p o o

-.i u... u c.z, _1,2_5, '

. s 3

Boiling in the spent fuel pool vould have a nes-i

, s. u.,. e e.e.ee..

c.n.s...

,,.,4

, 4..e..

....s..,.

. a.i..se...po,

.3

..r te perature to boiling end con:inued boiling for a period 1

of up to 5 to 7 days vould not affect the design behavior or

, e e. /.

structural integrity of the concrete in the spent fuel pool.--

Boiling shou'.d have no effect on the neutron absorb-l ing caterial (Boral) present in the proposed storage racks.

Boiling veuld tend to increase the concentration of beric acid in the pool va:er, since the va:c: vould beil-awaynbut u/

.k. e b -..# -

~ 5 e s e '...' 3. e. c. n. c e... a. '.-.. s

. a.. vo"....e.=....

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a.

a < > c o.. n. s. b e c,.. <..t. e.>

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l Intervener's vitness discussed an acciden; which tigh: fc11ov if the va:c in the spent fuel pool vere allowed to boil away, uncovering the s:Ored spent fuel asse:blies.

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.,=

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1_2_8/ Tr. 1324-27.

l 1

l r,v-a w, -

l 43 i

= According to his calculations, if no =4keup wa:er. were added, the tops of the spent fuel racks would be uncovered in a l

period of 2.9 to 5.9 days following initiation of boiling. The witness testified.that after being uncovered the spent fuel asse=blies veuld hea: up rapidly, and above 920' C-an exother=icl s

=etal-wa:er reaction would take place producing'large a=ounts 1

cf heat and hydrogen gas.

He indicated that the hydrogen libera:ed by this reaction could subsequently explode, which

=ight lead.co a =ajor release of radioactivity fro = the spent fuel building.

Because of the large inventory of radioactive i

=aterials in the spent fuel pool, he stated that such an acci-dent would be =uch = ore severs than a reactor =el:-down lle/

accident.

In support of his thesis that exposure to air of s:cred spent fuel could lead to a serious ac'cident, the i

witness cited a repor: by Sandia Laboratories,10/

1 a copy of

.which had been served on all parties by the Staff.

Neither the Applicant nor the Staff has perfor=ed calculations relating to the possible heat up of spent fue'l following exposure to air or the radiological consequences of such an event.

Both take the position that such a loss of wa:er accident at Zion Station is not credible.11/

1 i

The Board finds that the Intervenor has not presented a sufficiently probable sequence of events by which boiling in 123/

Resnikoff at pp. 2-4, 11-19.

^

112/

NUREG/CR-0649,. " Spent Tuel Hea:up Following Loss of. Water i

During Storage"r A. S. ~Benj a=in, Le al., March 1979.

t 111/

Tr. 1486-1487, 1654-1656'.

i

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,--,..-v

,e,--.mw 4

.-,,,-w--

,,.,,.-,m.

L t.

the spent fuel po:1 could lead :c a loss of vater acciden cf the kind described in the Sandia Repor: or in testinen of its vitness.

.v.v e.,

a c.,. > :. 3

, n. s v.: ~..s s c be e vc. g.o e a

n.._.

o.:.

s m.

hree to six days to add water te the poc1 to preven: this o. _-~. e.. e, a.. d. * ' e v.'..n e s s.~ ^,

a. d a. s.'.. a. s.., - '. '. a s e.' " k e "

k..e

.e.. a. : o a e a > e q.. c..,...eo

.k....s p..

ose-s.a..

..c.

v a 9.*.t n. n,,, 3..

y he has raised a question whether hunan intervention to add I

nG.eup water would be possible under all circu=s:ances, :he sc... ar e.. c c., a. >

y... e.v.. : : u. y,,

e 2 r.e.z,>

s.a,u....

co..

a>.<

.<~.

.c..

on this re crd, tha such inte vention would always be possible.

'"here is no reasonable basis for the witness's specula: ion k.. a s t. t...

a.A t.

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o,...

w.o... ; n a i..

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a n

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-3

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t..,n 4,e 1.*..*. /. s.t >

11

/

.. : ~. %. o... ~c a. 2.e.

1_3__2/~. ~. ' 5 A. '. '.'

133/

The Board takes notice of 10 CFR Part 50, ! 103, which states, in p ar t :

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the Co-' s si on... may,

(3)

Order the operation of any licensed facility.

(4) c >,. e,... ;. '..

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c r d e r t o r e c a p t ur e s p e c i al n,v,. a... o.. a

...v.uclear ca:erial or :o operate the facility.

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t 9

45 a

4 The Board, finds that the heat removal capacity of the Zion spent fuel' pool cooling systau and related cooling syste=s is adequate to support the _ expanded pool capacity.

The.

Board finds that the analysis of possible spent fuel pool water boiling is adequate.

The Board also finds that if boiling should occur in the' spent fuel pool, there should be no da= age.

to fuel cladding and no significant increase in the release of radionuclides.

The Board finds that there are sufficient sources of =akeup water and adequate access to such sources to ensure that the public health and safety is not endangerad' i

by boiling in the spent fuel pool.1.18 The' Board finds no basis in the record to require a technical specification which would restrict fuel movenent 'during core' unloading',by 4 posing.

a ten-day mininu= time on the co=pletion of full cote discharge.

134/ Although Contention 2(g) and Intervenor's testimony dealt only with loss or water. accidents in the spent fuel pool caused by boiling, such accidents could be hypothesized to occur through other neans.

Accordingly, the Board on its own =otion directed the.Appli' cant and the S:sff to s"--arize the design and/or engineered safegcards at the Zion spent fuel pool which decrease-the likelihood of severe pool drainage accidents.- The Board's findings with respect to these safeguards are found on page 86 below.

\\

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E.

Cerresic Contentiens 2(e)(3) and '(4) s:ste:

The atendmen reques and'su do not adequately discuss

ppor:ing documenta:ica-nitoring procedures.

In the light of the proposed codifica:icn and long te.-. s.,.43e c....,e,.

spe. e.,e,

. s..e n,e p..e n a..

i

..w should clarify the following:

(3)- Methods for detecting the less of neutren absorber caterial and/or swelling of stainless steel tubes in storage racks.

(4)

Details of a corrosion'tes:

regram to canitor perfor ance of n2:erials usek in the construe-tien of the racks.

C... e ~.. ~. '. o n * '..

s. c-. o.. -

The aram>~a--

eques: and supper:ing doeutentation have nc: analyzed the long ter (in:1ud ng storage C..

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. 3 -

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e<e.e.

n... c.. o s <..-.. e..pe. s e.:

c us

..g da.ss4m.n.a-2

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o alloys fcr the pool liners, pipes, s:crage racks r.nd-s:::a.re rack bases, such as the raivanic cerrosien berveen unanodized al"-fnur as is us,ed in. Brooks an,d

,e,.<..s S.....e

.a...,

a.:...

. e s.a esa s. eel po..

.i...

i

., i..- r..

...ag

...e..+...... o.

s... e s,.

t The Applicant has n:: discussed whether the proposed

difica:icn and icng ter storare =av cause the fo.' lowing effe::s en :he stored Euel:

accelerated corrosion, =iero-structural changes, alterations 'n

=echanical properties, stress enrres ton, cracking, 4... e... an.'. a.

a...> k A. s.c e.. a k s...s ~. i o n g.

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g a..g.a.:...:a._ u...ne z...c._t.,-

n g.S.cys.

-7 7.....

t Centention 2 (j ) s:a:es:

The amend-a-*

eques; and supp rting documentation do not give su#ficient data :: fully assess the durability and perferrance ci the 3cral-stainless steel tubes which for the spen fuel storage racks-(1) there 's 'nadequate analysis of the corrosion ra:e of the tubes.

e

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47 (2) there i's no' calculation ef the effect of water che=istry. on the Boral within the.

stainless s: eel.

(3) there is no mention of the possible swelling of Boral within the stainless steel tubes, a condition'which could. affect, among other things, removal of fuel asse=blies from the racks.

Centention 2(h) states :

The amendment requas: and supporting documentation do not consider possible degenera: ion of the Boral

?

density due either to generic defects or to mechanical failure which would di=inish the effectiveness of Boral as neutron absorber, thus leading to cri:icality in.the spen: fuel pool..

The proposed storage racks consist of a welded array of rectangular stainless steel tubes into which the span: fuel' asse=blies will'.be inserted.a Within:aach4 stainless steel tube are four neutron-absorbing.Boral sheets, one on each side.

On each side of each tube, near the top, is a 1/4-inch van: hole which penetrates the inside stainless steel wall and which will allow span: fuel pool water to enter the tube and come in contact with the Boral material.w /

Boral is a product manufactured i

by Brooks and Perkins, Inc. which consists of boron carbide (3 C) particles a= bedded in a =a:rix of ce==arcially pure (1100) 4 aluminum formed into a plate and clad with 1100 alu=inu= on both sides.LLv The materials exposed to water in the spent feel pool are stainless steel in.the pool liner, in the spent fuel asse=blies and in the storage racks; Zircaloy and Inconel in the

)

\\

ljj/

Applicant's Proprietary Ex. 6.

115/

Testimony of J. E. Draley (Draley) at p. 3 following Tr. 129,; Tr. 1261-1263.

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i i

L5 spent fuel asse:111es; and 3 oral in the storage racks.

Of t

these dissinilar materials, the stainless steel, Inconel, and

~irealoy have nearly identical electrolytic potential and therefore can be coupled without significant ele: roly:ic c galvanic'effe::s.

There is a major difference in ele::ric potential berveen aluminun and stainless steel and therefere galvanic c:rrosion vill occur berveen the aluninun cladding in the 3 oral and the stainless steel tubes which encapsule:e the 3eral.

However, the stainless steel pool liner will not be 13,/

affe::ed by interaction with the 3:ral.

There appears to be no basis to expe:: tha: the 30:a1 contained in the stainless steel tubes will contribute to degrada: ice of the fuel assenbly raterials'or the peel liner.

This is true whether or no: the racks are vented, because under the conditions and condu::ivities in the Zien sc.ent fuel t.ool, talvanic corrosien re,uires dire :

itt/

~~

Cnta:!.

So=e galvanic cerrosien berween the 3::a1 sheets and t

l the stainless steel tubes within which : hey are enclosed'will take place.

Because stainless steel is ele: troche =ically nere noble than the aluminun and Beral sheets, such galvani: corresten will not affe:: the s:ainless steel tubes, ner does 1: threaten 32c/

.w I

the structural integrit.y of :he racks.

Sene pittin of the s

I k

137/

li?.C Staff Tes timony on Contentions 2 (e) (3), 2(e)('), 2(h),

2 (i), 2(g), and 2(k) by Frank F.. A1:e c: and Edward Lant:

i l

(A1:eter and Lant:) a: pp. 3-9 following Tr. 1141.

1_3_6' Johnson at c..

6; Draley at.o.

9; Tr. 1099, 1115, 1129-30.

-. 5-7; Alcecar and Lant: at pp. 6-9 ; Johnson 1_39' Draley a: n at p. 6.

d

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s t

e 49 edges of the Boral. plate and perhaps the 1100 aluninum cladding which forms the outside layer of the Scral where the electrical-contact with the stainless steel tube is good emi be expected.

In neither of these two locations is the attack expected to be great enough to lead to serious loss of the neutron absorbing boron in the Boral or to cause corrosion product swelling of the Boral which would interfere with free move =ent of the spent fuel stored in the racks.

The reason for this is that the corrosien will be self-li=iting due to the fornation of an 140/

insulhting oxide fi1= over the growing pit.

During an in ca= era session, In:ervenor raised ques-tions about several proprietary reports ' describing > galvanic'

~ < ',

corrosion experi=ents conducted'by 3:coks'and Perkins; Inc;.

~

the manuf acturer of Boral, and by Battelle-Colu= bus Labora-tories for Brooks and Perkins.il/

l These reports were provided by the Applicant to Intervenor during discovery.

The Brooks and Perkins report contains a conclusion that maintaining a significant oxygen concentration in the water surrounding the l

3eral could lead to unacceptable corrosion behavior.

Pre su= ably on the basis of this research the Applicant changed its rack design so that the vent holes through the stainless steel tubes are located only at the top of the tubes, rather than at the top and the bottom.

This 11=its the access of fresh oxygen-bearing pool water to the inside of the tubes.

Applicant's 160/

Draley at pp. 5-6; Tr. 1142-1144.

1,31/

Intervener'.s In Camera Ixs. 1 and 2.

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l 1

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witness testified cha: he did not agree with :he Brooks and r

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te results that vould be unacceptable.

However, he had no obj ection to the clesing of the vents a: the botto: of d.e tubes.

• ..e Bar:elle-Celt:nbus reper: reflects experiments in which a high rate of galvanic attack cf 3eral in a'concen-

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t 51 Significant amounts of neutron-absorbing boren will i

not be los: fro = the Boral by corrosion.

This is because the boron carbide (3 C) particles are inert to the pool water 4

environ =ent and galvanic corrosion and remain embedded in any alu=inu= corrosion produce.

The amount of this corrosion product which flaker away will be.very s=all.%.U.

There has been no evidence of pool-stored commercial va.ter reactor fuel degradation to date from visual inspections,

tdiation =enitoring of sper.: fuel pools, and detailed exa=ina-tions of selected fuel rods.

Unfortunately, visual inspections and radiation monitoring detect only advanced stages of cladding degradation.

However;c'theore:icallassessments conducted by "an Applicant witnessrands by others have failed to identify's

' ?

mechanis= which is regarded as a substantial threat to fuel cladding integrity in pool storage.

The witness testified that there is sufficient basis at this time to proceed with icng term storage of spent fuel.

However, he noted that sur-veillance should continue to bc provided for the spent fuel over whatever time period the spent fuel will be stored.Lif Accelerated corrosion, micro-strue: ural changes, alterations in mechanical properties, stress corrosion cracking, 144' Draley at pp. 7-9; Almeter and Lantz at pp. 7-8;

~~

Tr. 1250-52, 1358.

145/

Johnson at p.10 and at pp.167 and 171 of Attachment 3; Tr. 1072-77, 1113-15, 1117.

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s Swelling of unvented storage ra k tubes, not involving

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swelling is belieced to have been caused by the accu =ulation cf entrapped gas be:veen the 3 oral and the stainless steel tube.

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type of swelling should be self-lititing, since enpansion of the I

blister should defor: the piece enough to allow release of hydro-I gen pressure.

So=e swelling of this type has occurred in tests 1.4 6./

Drale.v at pp. 2 3,10; Almeter cnd I. ant: at pp. 8 12.

P 1 _47/

Oraley at p. 13; Almeter and 1,s :: a t pp. 12-13.

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53 conducted by Exx' n Nuclear Company, but the Boral sa=ples used o

evere not of the, type of material used in the Zion racks.

The Exxon 'sa=ples differed in that they contained quantities of finer mesh boren carbide particles and areas of imperfect bond-ing within the Boral between the. aluminum cladding and the.

3 C/alu=inu= matrix.

4 This type of swelling should not occur in the Zion racks where there will be good quality control.16/

1 ThesecondtypeofBoralswellkngwhichmightoccur' would be related to local' corresion or pitting which might be induced by galvanic interaction between the alu=inu= in the 5

Boral and the stainless steel tubes where the two plates are pressed together.

The solid corrosion product has a greater-volume than that 'of"the metal, and' local swelling could resuit.:

Using the density of the prede=inant ale =ine= corrosion product, Bayerite, the corrosion product could occupy a volume some 3.2 times that of the alu=inu= from which it is formed.

Even if a Boral plate in a Zion storage tube corroded all the way through '(cladding and core material), the maximum swelling pro-duced by the corrosion product was calculated to be 0.234 luch, an'a=ount which would not interfere with the movement of fuel within storage tubes.ill l

Mechanical failure which might cause the Boral to i

fragment or break is not likely in view of the record of Boral i

products and in view of the record of the Boral cladding alloy, 13JV Draley at pp.11-12; Almeter and Lantz at p.13; Tri 1222-26.

143/

Draley at pp.12-13 ; Tr.1316-18.

l

i 54 1100 alu=inu=.

Fur:her, if mechanical defects should occur, the s:ainless steel tubing would keep?:he Scral largely ib._

positien.

In addition, the 3eral p14:es are ne: load-bearing _

^

t elements of the racks.

Only the mechanical strength of the stainless steel is relied on in the design of the racks, and 3

the streng:h of this caterial vi] t-ne: significantly deteriorate ever the life of the racks.

The only other effect which could i

possibly diminish 3:ral densi:y in the spent fuel pool is i

i radiati n.

havever, the lov levels of neu:ren #1ux in the pool vill have no significant effect on the Scral'in 40 years 150/

of full time use.~-

The surveillance program that the Applicant vill.use

o ensure that unexpe::ed da: age to the 3eral is ne: occurring

- vill utilize eighteen stall vented s:ainless s: eel coupens containing 3:ral spe:inens which vill be stered in the po:1.

c These coupens vill be recoved periodically, epened, and exa=ined i

for cerrosion damage.

In addition, evo full-size storage tubes vill _ be exposed in the pool near stored fuel so as to reproduce the radiation condition as well as exposure to the pool water.

These :ubes will be exa ined periodically for visual signs of swelling and will be opened and exa=ined for loss of boron if ex=-ination of the stall coupens indica:es a bcr:n-10 conten: in theenclosejBoralspecimenbelov0.02g=/c:2 1

150/

Al=e:er and Lant: at pp. 15-16; Drale.v at pp. 13-14 1

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55 t

This surveillance progra= should adequately. detect indications of corrosion damage involving possible loss of neutron absorber or swelling or.other da= age to the tubes in time to take necessary' re=edial action for the stortge tubes in the pool.

Corrosion reactions should.be sufficiently slow that any da= age that occurs will not endanger the safe and effective operation of the pool.LLI 1

On cross-exa=ination by Intervenor, Applicant's wi:-

ness testified that if the boron-10 content in the coupons fell below 0.02g=/c=2 and the full length. tube specimens also showed so=e da= age, it vould be possible, as a general mat'ter, to re=cve spen: fuel fro = the storage racks and inspect the tubes-in the racks.

There presently are no plans'to =enitor

- the generation of gas or corrosion products within the tubes being used to store fuel.

He testified that in view of the

' Applicant's proposed surveillance progra=, this is not necessary.

Similarly, there are no plans to measure the size of any corro-sion produe s that might flake off within the. tubes', or to monitor any accu =ulation of crud or corrosion products around the vent holes in the tubes.

The witness stated that because the density of the corrosion product is greater.than that of pool water, there is no force of which he is aware which would :mdce the:

rise to go to the' hole.11]I 1,51/

Draley at pp. 8-9 and at Attach =ent 5; Al=eter and Lantz at pp. 2-3.

152/

Draley a: pp. 1307-10; Tr. 1357-59.

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56 In respense to fur:her questioning by Interven :,

Applicant's witness'reaffir=ed tha: the s=all coupons and full length tubes used as sa=ples in the surveillance progra:

will sL=ulate the behavior of the tubes in the racks adequately to be safe in the iden:ification of any unexpe::ed swelling or proble= that occurs:.

Further, he testified that'1: is unneces-sary to condu:: c:re frequent exa=ination of these sa=ples than-the present plan calls for; however, the present' schedule could be ' changed if the Applicant elected to do so.

The Applicant has = ace a co==it=ent to institute the surveillance progra= at the ti=e it places the racks in the pool, although a delay of a few weeks w:uld:ne: be an undue. risk of any kind.ll/

I Intervener's wi: ness ques:ioned the Applicant's sur-veillance progra= because there are a s=all nu=ber of coupens to be used and because they =2y ne: be truly representative of the tubes ro be used in the storage racks, due to the difference in size.and because they =ay not necessarily be'=ounted in :he vorst-case environ =ent, however, the vi ness indicated that a:

the ti=e he prepared his wri::en testi=0ny that he was not aware of the fa:: tha: the Applicant's corrosien surveillance plan included the use of full leng:h fuel storage tubes.

The vitness stated that spe:ific a:ceptance criteria should be established in advance fer judging the results of any tests performed on ki_3/

Tr. 1312, 1320-22.

.#=

. +.

c-57 the sa=ples.

Nevertheless, he agreed that by. observing i

corrosion, the Applican would be a long way toward deter-mining whether or not the ultimate criterion, that is, the

' 154/

neutron absorbing capability of the 3eral, is being maintained!~

Subsequent to the completion of the' evidentiary hearing in this ma::er, the par:Les were served by the Staff with copies of a Board Notification -- Pipe Cracks in Stagnant 3erated Water Systa=s at PWRs.

The Board Notification was da ed August 14, 1979 and was signed by Darrell G. Eisenhu:,

Acting Director of the Division of Operating Reactors.

The Board Notification indicated that cracks have.

occurred in - safe:y related~ type 304 stainless : stael* pipin'g j ; ^

systa=s whic:.cror, ain stagnant borated water.

Affe~cted ~systa=s included the spent fuel pool cooling piping at another PWR.

The cracking is apparently due to stress corrosion cracking caused by residual velding stresses at he'at affected zones.

The Staff indicated that the cracking is not direc:1y related to and does not stem from spent fuel pool modifica: ions; substantial leaking fro: such cracked piping is not likely; 154 /

Tes:imony of Gregory C. Minor concerning Contentions 2(e),

2 (f), 2 (h), 2 (j ) and 4 (a) (Minor) at pp. 2-3 following Tr. 1405; Tr. 1417-28.

On voir dire exa=1 nation, Mr. Minor ad=i::ed that he is not an expert in the fields of corrosion or metallurgy.

Tr.-1378-79.

Accordingly,;

the Board approved a motion to strike those portions of the written testimony which purpor:ed to express an exper opinion on those subjects.

Tr. 1402-03.

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i SS necessary' repairs can be readily made; and the safety signifi-cance of cracks in icw pressure spent fuel cooling syste=s is nil.

However, following the evidentiary hearing, the record of this proceeding indicated that there is s:ainless steel in the spent fuel pool liner, the spent fuel asse=blies, the spent fuel pool cooling syste= and the proposed fuel' storage racks.

The stainless steel would be exposed to oxygen-sa:urated, borated water in the spent fuel pool,.if the proposed a=end:ent is issued.

Further, the evidentiary record indicated that the

=echanical strength of the type 304 stainless steel in the-pro-posed 'acks would be relied upon by the design of the racks, r

and :ha: s:agnan: water would exist within the vented tubes of the proposed fuel s:orage racks.

The record was not clear as.

to :he :ype of s:ainless steel in the liner, in the fuel asse:-

blies er in :he spent fuel pool cooling syste=.

Further, the record was not clear as to the extent to which the water in the pool would b' e stagnan:, or essentially stagnant,- nor to the extent that the water is oxygenated.

Therefore, the Board directed the par:Les to provide affidavits as to the extent to which type 304 stainless steel 1

will be present in the pool according to the proposed modifica-tionhian.

Further, in light of the new infor=ation contained n

in the'Eoard Notification, the affidavits were to address' wha:

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59 effects, if any, would occur to the type 304 stainless steel

~

as a result of being 4~ ersed in or in con:act with the water

'in the spent fuel storage pool.lidi

-l Following the granting of numerous motions for exten-siens of ti=e, the affidavits were submitted by late Dece=ber 1979.

In a conference call on January 3, 1980, confir=ed by written Order,2/

11 the Board indicated that there were two issues

.which the Board found were not addressed by all parties in their affidavits or, if addressed, were not done.so in adequate depth.

~

- The parties were given until January 24, 1980 to sub=i: addi-tional affidavits.

P The Board has considered the additional evidence pro -

. vided by all the parties.

Type 304 s:ainless steel does exis:

in the spent fuel pool as follows:

in the 3/16" pool liner; in the spent fuel pool cooling systa= piping, heat exchangers, F

^

pu=ps and valves; in the top and bottom nozzle asse= biles of the fuel asse=blies; in the rod control cluster asse=blies, burnable poison red asse=blies and the control rods; and in the present fuel storage racks.

Further, the proposed fuel storage racks would be =ade of welded type 304 stainless steel sheet, bar and pla:e.511 1

Stagnant water conditions can occur in the twe loops of the spen: fuel pool cooling system under conditions when a 111/

Me=orande= and order, Sep ta=ber 14, 1979.

1 113/

Me=crandum and Order, January 8,1980.

157/- Affidavi: of To= R. Tra== at pp. 1-2, Nove=ber 1979.

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Because there is no convective flow path within the spent fuel storage tube. walls, water inside the stainless steel-sheaths is expected to be stagnant.

Forced flow fre= the span fuel pool cooling syste= and convective flov frc: :he beat fro = the. spent fuel generally prevent the water in the spent fuel pool fro: beco:ing stagna=:.

However,-

there could be localized stagnant, or near stagnant, conditions 15c in crevices or in narrow spaces between adjoining fuel tubes 7 /

159 /

The spen: fuel pool does con:ain oxygenated and borated water 7-In:ergranular stress' corrosion cracking of stainless steel can occur if three conditions are present.

These include an aggressive enviren=ent (e_2., s tagnan:,1erygenated: borated...

s water syste=; pres ence of' con:a=inants'such ~ as ~ chloride' br" fluoride), a. condition of =etallurgical sensi:ication susceptible to stress corrosion cracking; and high residual or i=pesed i

s:resses.

All three conditions =ust be present before cracking

[

will occur.g '

t 113' Affidavit of Tc= R. Tra==, Nove=ber 1979 at pp. 3-5; Affidavit of To= R. Tra==, January 24, 1980 a: pp. 1-5; Affidavit of Roger Staehle, January -14, 1780 at of Rober:.Neil Anderson, Dece=ber 17, p. 1; Affidavi:

1979 at p. 2; Affidavi: of Rober: Anderson, January 23, 1980 at pp. 3-6; Affidavit of John R. Weeks, Dece=ber 7, 1979 at p. 2; Supple-l

= ental Affidavi: of Edward Lantz, January 15, 1980 a: pp. 1-3.

Lip' Affidavi: of Tra==, Nove=ber 1979 at p. 1; Affidavit of Tr a==, J anuary 24,1980 at p.1; Affidavit of Anderson, r

January 23,1980 at pp. 2-3; Supple = ental Affidavit of Weeks, January 10, 1980 at p. 2.

Lif - Affidavit of Staehle, Nove=ber 16, 1979 at pp. 3-4; Affidavit of Staehle, January 14, 1980 at p. 2.

1 l

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61 The evidence indicates tha an aggressive environ =en:

of stagnant, oxygenated, borated water may be.present within the.

vented stainless steel sheaths of the spent fuel storage tubes, -

and possibly at other loca'tions between tubes.

The Applicant i

=akes a co==1:=ent to monitor spent fuel pool water chemistry on a weekly basis for chloride and fluoride and indicates that chloride will be maintained below 1.0 pp and fluoride will'be

=aintained below 0.2. pp=.11J 1

Visual and liquid penetran: exa=inations were made on one of the existing fuel storage racks in use in the spent L

fuel pool for approxi=ately three years.

No cracking or:other

-162/

defects were observed.--

U1::asonic., dye-penetrant-and visual exa=inations were'perfor=ed on the spen:; fuel poolacooling systa=.

163 /

. No evidence of stress corrosion cracking was observed.-~ Ilec:ro-che=ical Potentiokine:ic Reac:ivation (I?R) tests. were perfor=ed on represen:a:ive. weld locations of the Zion fuel storage racks at the manufacturers plant.

These I?R tests for sensitization show that the values obtained for.co=ponents of the Zion fuel 164/

storage racks are well within the range for safe behavior.-~

t.

The carbon content of the type 304 stainless steel in the' Zion spen: fuel racks is below the local at which intergranular stress 1

161/

Licensee's Response-to Board's Memorandum and Order, Nove=ber 16, 1979 at p. 2.

162/

Affidavit of Thomas W. Lukens, October 17, 1979 at pp. 1-2.

1,6p Affidavi of Robert Shannon, November 6,.1979'at pp. 1-3.

164t. Affidavit of Willis Lloyd Clarke, Jr., November 2, 1979;

~~

Affidavit of S:aehle, Nove=ber 16,1979 at pp. B-9.

l

i 62 165/

stress in the proposed spent fuel racks.--

Therefore, the Board finds that intergranular stress corrosion cracking is not 166/

likely to occur in the proposed fuel storage racks.--

The Board questioned whether,the Applicant's co==it-to conduct a corrosion surveillance progra= should be men:

for=alized as a technical specification in view of the need to maintain the progra= over a long period of time.

The Staff testified that it has no plans to i= pose a technical specifi-cation en this subject, but that it will record the Applicant's co==i:=ent to follow this surveillance progra= in the cover letter which will acco=pany the issuance of any' license a=end-

=ent issued in this case.

Further, the NRC's Office of Inspec-tien and Enforce =ent does keep track of licensee co==1:=ents so 115/

The Board concentrated on the possible i= pact of in:er-granular stress corrosion cracking en the fuel storage racks, because of the possible effect~en =aintaining fuel suberiticality, if the racks were to fail.

Although s:ag-nant, oxygenated, berated water may occur in the spent i

fuel pool cooling syste= piping, the Board finds this not to 'be a =aj or proble=,

As indicated earlier in this deci-sion, the syste= is redundant, making repairs ?ossible withou: interrupting nor=al cooling.

No result in draining of the pool.

Further, pipe ireak can recen ultra-sonic, dye-penetrant and visual exa=inations of the i

syste: revealed no evidence of intergranular stress corrosion cracking.

166/

The Applicant com-' s itself to supple =enting its corro-sion rurveillance progra= by suspending ten specimens containing weld gec=e: ries and material si=1lar to those in the fuel racks.

The ten specimens are to be suspended adj a cen: to the proposed fuel racks and exa=ined visually and ultrasonically on a yearly basis.

Affidavit of Staehle, i

Nove.ber 16, 1979 at p. 12; Licensee's Response to Board's Mescrandu= and Order, November 16, 1979 at p. 2.

9

63 listed and can and does enforce them Tollowing careful' con-sideration of this issue, the Board finds that the corrosion J

surveillance'progra: need not be made the'subj ect of a. technical specifica:icn-or condi: ion of license.

The corrosien surveil-lance progra= is a prudent =eascre to e= ploy, bu: it has not been show= to have an 4-edia e bearing upon the public health and safety.

Support for this position is found in the decision 168/

in the Troj an case.--

In arriving at the instant decision..it is the Board's reco=mendation, however, that the Applicant should-not be relieved of this ce==1:=ent without careful review by

he Staff based on the facts a: that ti=e.

The Board finds that the corrosien surveillancem:

progra: co==itted to by the Applicant is.adequa:esto datace> -

s

he loss of neutron absorber =a:erial and/or swelling of the.

~

storage tubes.

1,67/

Tr. 1972-73, 1983-85.

168/

In the Matter of portland General Electric Cc=pany (Trojan Nuclear Plan:), ALA3-531, 9 NRC 263, at 271, 277-278 (1979).

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The' Board finds that the Applican: a.nd Staff have analyzed the long-tern electrolytic corrosion effects of, g

-using dissi=ilar alloys and that the anticipated effects.'are-no: expected to be significant.

The 3 card finds that the Applicant and Staff have analyzed the proposed codifications and leng-ter: storage effects on the stored fuel of accelerated corrosion, r.iero-structural changes, alterations in mechanical properties, stress corrosion and hydrogen absorption and precipitation by the irconiu= alloys.

Tur:her, the Board finds that based on these analyses the effects are not expected to.be significant. '

'The 3 card finds tha: the Applican: and Staff have adequa:ely analyzed the cerrosion rate of-:he fuel storage-

ubes, the effec: cf water chenistry on the Boral and the possible swelling of the s:ainless steel tubes.

The Board finds that adequate consideration has been given to the possible degeneration of the 3eral densi:y l

en the fuel storage tubes.

The Board finds tha: the corrosion surveillance prog a to which the Applican has cor=Ltted its elf,,

is adequate to detect significant loss or shifting in location l

of Boral.

Therefore, the Board finds that the risk of criti-cality in the spent' fuel pool from this effect is negligible.

S' I

l l.

I

4

)

65 F.

Qualiev Assurance Contention 2(k) states:

The amendment request and supporting documentation do not consider possible degeneration of the.3 oral density due either to generic. defects or to mechanical failure which would di=inish the effectiveness of Boral as neutron absorber, thus leading to cri:icality in the spent fuel pool.

Contention 2(1) states:

The Applicant has not described the procedures it intends to e= ploy to prevent the ins:allation and

~

use of da= aged and defective racks.

The quality assurance and quality control procedures of Co==enwealth Edison, Brooks and Perkins (fuel storage tube manufacturer) and Lackenby (fuel storage rack fabricator) were described.

These are designedwto prevent'the' ins:alla: ion ~ of '

racks with insufficien: Sc:al density or other defects into 16W the spen: fuel pool.--

The boron carbide and other materials used by 3:coks and Perkins to manufacture the Boral plates are certified by 177 the supplier to =aet applicable ASTM standards.

The certifica-tion docu=ents are traceable to specific lot nu=bers of the i

boren carbide and reviewed by Brooks and Perkins quality assur-ance personnel.

As an additional check, a sa=ple of each lo is sent to Isotopic Analysis, Inc..to verify the boron-10 conten:

If c/

Testi=eny of Walter J. Shevski (Shewski) at pp lowing T. 707 ; Leider at pp.10-12; NRC Sta-,.1-10 fol-Tes:1 mony on Contention 2(1) by Joel E. Kohler (Kohler) at pp.1-4 following Tr. 786; Almeter and Lantz at pp.13-15.

QQ' A=arican Society for Testing and Materials.

e r

66 of the boren carbide powder 'by =eans of isotopic analysis.

These steps are docu=ented by Brooks and Perkins, and reviewe'd by Nuclear Services Corporation (NSC).

Only upon a finding of adequate ec=pliance with these procedures will NSC authorize-use of the boren carbide. powder'for fabrica: ion.

The boron carbide is then used in the fabrication of Boral plates.

A-sa=ple is taken fro = each end of the Boral plates and 10 percen:

of these sa=ples are chetically analyzed for boron-10. loading 171 by Brooks and Perkins.~~/.

i The Boral sa=ple is dissolved, the boren carbide filtered out and then dried and weighed.

Because the isotopic content of the boren carbide is..known~through.previousi ic o t op i c'.-

analysis.cf each batch:of. boron carbide,'the boron-10-loading' I

l of the sa=ple can be calcula:ed by ceasuring the weight of the boron carbide which was separa:ed fro: the Boral plate.

The i

precision of he tes is 0 0003 gra:s per square'centine e: of 172/

boron-10.-~

Brocks and Perkins then forwards the test results to i

NSC for reviev, and upon a finding by NSC tha: these procedures

)

t have been adequa:ely co= plied with, the tubes are released to 173/

Leckenby fo: rack fabrication.--

121/

Shevski at pp. 5-7.

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Tr. 1040, 1940-41.

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123/

Shevski at pp. 6-8.

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The Applican't has retained NSC to perform inde-pendent inspections of Brooks and Perkins' fabrication of the fuel storage tubes.

NSC inspectors review Brooks and Perkins docu=entation on 'a rando= basis while on inspection visits.

However, all documentation is required to be sent to NSC headquarters for review 11.0 In addition to review by Brooks and Perkins and NSC quality assurance personnel, Co==onwealth Edison perfor=s independent reviews, inspections and audits of the tube =anu-facturing process to ensure that there is adequate density of boron-10 in the Boral plates.

As of the date of the hearings, there had been three audi:s of Brooks'and PerkinE conducted - -

by Co=ncewealth Edison quality ~ assurance personn. l.LIS' e

During the course of cross-exa:ination, Intervenor introduced two letters pertaining to ship =ents fro = Brooks and Perkins to Leckenby/of tubes which contained insufficient 176

~~

boron-10 content.

Applicant's witness confirmed that five l

nonconfor=ing tubes had in fact been shipped to Leckenby, and that the boron content of those tubes was 0.0189, 0.0189, 0.0186, 0.0196 and 0.0182 gm/c=2 The =ini=u= required boron-10 concen-2 tra:1on is specified as 0.0200 g=/cm.

This deficiency was not 1,74/ T:. 718-720.

123/

Tr. 720-723.

123/

In:ervenor's Exs. 2 and 3.

?

68 discovered in the April audit of Brooks and Perkins (the non-conforcing tubes had been shipped in March), but was discovered in the June audit by the Applicant.

None of the defective tubes had been used in the fabrication of the racks, and each tube had been tagged as defec:ive and isolated to insure it would not be used.U]l Intervenor pointed out during its cross-examination of Applicant's witness tha: the Applicant first ordered the Scral containing tubes for the new Zion racks in July 1978.

The original purchase order did no: specify that the - fabrica:Lon of the :ubes was " safety-rela:ed".. Therefore, the Brooks and Perkins quality assurance program was not required to confers'to' 10 CTR Pir: 50, Appendix 3.

The Applicant subsequently deter-~

• ined tha: this was incorrect judgment on its part and in c

Nove:ber 1975 required that the fabrica:icn of the tubes be l

safe:y-related.

Applicant has not required that the suppliers of the co=ponent parts of the tubes have quality assurance progra:s cob.for=ing to 10 CTR Par: 50, Appendix 3.

However, material supplied to Brooks and Perkins has to be certified to mee: ASTM requirements.

3 rooks and Perkins and NSC personnel review the docu=enta:ic: to verify that the materials meet the 17&'

ASTM requirements prior to their use.~~

1.l]/

Tr. 736, 740, 745-745, 755.

1,7y Shewski at pp. 5-6 ; Tr. 737-739.

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69 Prior to rel' easing the co=pleted racks for ' ship =ent to Zion Station, NSC is required to review and accept Leckenby's quality assurance inspection end review.

Upon receipt of the racks at Zion, the Applicant's on-site quality control and quality assurance personnel are required to perform a receipt inspection for ship =ent da= age and other possible defects.

yurther= ore, quality assurance personnel will be required to review the docu=antation to assure compliance of the materials 3

and fabrication require =ents.

Written procedures detailing these inspections were received in evidence as Applicant's Exhibit Nu=ber 1.E9/

As part:.of the-receipt inspection, a 'du-_y fuel-asse=bly built to exactly the sa=e di=ensions'and tolerance's as the fuel stored at Zion dill be lowered into and raised out of each tube in the absorber rack.

The Applicant will use a 20-pound drag criterion for determining the existence of a defect in the physical contours of any tube.

Past experience shows that the 20-pound drag is the friction force that the do y asse=bly will exhibit in being lifted and lowered into 18 7 a rack.~~

Under questioning by the Board, Applicant's witness indicated that the effective multiplication factor (K-effective) l 117 Shewsk1 at pp. 8-9; Tr.1939.

1 (17 Leider at pp. 11-12; Tr. 762.

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70 for the p:cposed fuel s:orage configura:Len vould not teet the Staff's criterion that it be less than 0.95 if one Boral pla:e out of six:een (every four tubes) were tissing, he indicated tha: this vould also be true if only one out of thirty-vo Boral plates were =issing.

The witness concluded that it is very i=pertant to know whether there are tissing Ecral pla:es in the racks before these racks are installed or ntilized.i'J l

After the racks are installed in the pool, but prier to placing spent fuel therein, neutron attenuatien tests vill be perfer=ed by National Nuclear Corporation to confir:

tha there is a Boral' plate in each of-the four valls of the

^'

individual tubes tested.* The':ests vill not be perfor=ed on every tube.

F.owever, these tes:s vill be statistically designed to prove vi:hin a 95 percent confidence level tha: the four pla:es are presen: in each tube.

The tes is capable of estab-lishing within 20 percent accuracy the boron-10 loading of each plate with 100 percent confidence.y On cross-ex=-'natien by Intervenor, Applicant's witness restified that even though the tests will be conducted while the tubes tre i--arsed in a beric acid aqueous solution, this will not cash any deficiency in the Boral.

This is because the test vill be calibra:ed to take in:o accoun: the boric acid concentra:ica Ib/

Tr. 1726-1741.

1

(*2/

Shevski at p. 9 Tr.1942-1947, 2010.

i

i 4

~

71 18 7 in.Se fuel pool wa:er.-~

In response to Board ques:ioning the Staff indicated that it will require a com-'t=ent on the part of the Applicant to ecnduct neutron attenuation tes:s which could assure with a 95 percent confidence level that the Boral plates are presen: such that a K-effective of. 0. 95. would not be exceeded. U/'

L In response to questiening by the Board, Applicant's wi: ness s:ated that in the unlikely event it is discovered tha: a 3eral pla:e is nissing in any tube, the Applicant's co--d :an: is to physically plug that tube to prevent the inadver:en: insertien of a fuel asse=bly therein.

Moreover, the Applicant will require tha:

100 percent of the re=aining/

155 rubes be exa=ined:by =eans of neutron-attenuati~cn tes:ing.-~

Throughout the receip:, inspection, installation of the racks and subsequen: neutron at:enuation tes:ing, the Staff vill condue: inspections and reviews to assure that only confor=ing acks are ins:alled in the pool.

The NRC Region III office of Inspection and Enforcement plans to u:ilize additional cons:=ue:Lon inspections during the p;cposed rack installation.

Further= ore, if it is deter =ined that the Applicant is i= prop-a:17 installing or handling the racks, stop-wczk orders will 189 be issued expedi:iously ~~

1.13/

Tr. 1944, 1950.

1,34/

Tr. 1984, 1987-1990, 1993-1996.

1/ T 1947-1948, 1950. 1,gg/ Tr. 798-799, 802-804. --.v-p ~ -.y,,..w-e

1 i 1 72 During the course of c ss-exanination of the Appli-cant's vi: ness on criticality, the Board inquired as te how .=uch beren in the 30:a1 could.be los: before K-effective would reach a level of 0.95. In response, the witness s:ated :ha: roughly 75 percen: cf the beren in each plate could be lost, vi:hout reaching 0.95. The witness explained that 0.95 is an arbitrary number specified by the liRC's Standard Keviev Plan to assure that a criticality event canno: take place. Any value of K-effe :ive less than 1.0 would ensure caintaining sub-criticality. Further, the calculations do no take credit for fuel burn-up, fission product poisoning, berated fuel p :1 va:er, or presence of any control rods. Eevever, they assume no plutoniun'-239 or 241 in the fuel.Q~l Of particular concern to the Board is assurance tha: the bcr:n-10 in the 30:a1 p'.ates vill be in place and renzin in place within the fuel s:crage tubes throughout the life cf the s:ation c: throughou: the use of the racks. The 3eard finds that the quali:7 assurance and quality cen:::1 procedures described by the Applicant and Staff vill ensure tha the 30:21 vill ini:Lally centain sufficien: beren-10, and tha: the tubes and racks vill be properly =anufae:ured and installed in the pool. , c 7/ Tr. 1726, 1730-1731. w .,m. a

u. g o 74 The Applican: has made a ce=ait=ent to conduct neu:ron at:enuation tests, to exa=ine 100 percent of the tubes if the neutron a:tenuation tests reveal one missing Boral plate and to physically plug any tube found which has less tha= the prescribed nr-ker of Boral plates, or to take whatever other re=edial ac: ion prescribed at that ti=e by the Staff. The 3 card finds that the in situ neu:ron attenuation test is a key aspect of the quality assurance progra= to verify that the tubes and racks as installed do indeed contain a sufficien: nc=ber of Boral plates tha: K-effective will not be greater than 0.95 when the fuel is in place in the tubes. The Board has already found that the corrosion sur-veillance progra= ce==i::ed to~ by the Applicant is ' sufficient ~ to de:ee: signific an: loss or shifting in ' location of the Boral. 0 6 0 9 6 isi ngiu 'sTs i ya

~. a, 75 G. Beard Ouestions i In the Orde: Following.Prehearing. Conference da:ed 19 January 1979, the Board propounded a set of six questions -[4(a). threugh 4'(f)) to each of the parties, with the request that eviden:iary showings on each of the ques: ions be =ade at the public hearing. t 1. Risk of Theft and Sabotage Board Ques:icn 4(a) s:ates : Will the proposed =odifications of the spent-fuel pool and/or the opera: ion of the Zion station with increased spen: fuel poo1~ storage-cap acity : (1) increase the potential risk of threats S:s:pecial nuclear =a:erial or to to s ion facilities? (2) increase the poten:ial risk cf theft c' special nuclear =a:erial fron the Statien? (3) increase :he po:ential risk of industrial sabotage to the Sta:icn er to the special nuclear material? i (4) decrease he level of physical protection of the facilities or special nuclear =a:erial at the S:ation? Soard Questic: 4(b) states : As a result of the p;cposed modification of the spen: fuel poci and the proposed operation of the Station with increased spen: fuel storage capacity, will it be necessary to modify the Physical Security Plan, Safeguards Contingen:y Plan c the I=ergency Plan for the Station? leg 1.13' The S:a:por: ion of Board Questica 4(b) pertaining to the 1on Energency Plan is discussed in the nen: section of this decision. 4 -.m .,..-_.m., _..m........._..,,m,,,,#..~,o.m.m.,--,..,-,,.--m.eme.-..~my,,,.e..m,-um,w,,,c, iw,,- #e,,,,--

( t 76 During the course of c Oss-exacination of Applicant's vih ess by In:ervenor, a questien arose cencerning the inter-pretatien of Questien 4(a)(3). The 3 card s:ated : hat 1: had =eant :he parties to address only the likeliheed or probability of industrial sabe: age. The 3 card explained tha: it had no: intended :e dire:: the par:Les : exp10:e the possible ecuse-

s. n. e.,r quences cf a successful ac: of sabe: age.-~

r 1 The Applicant's Security Plan and Safeguards Centin-gency Plan were des::1 bed in de: ail. 3ecause the Zion securi:y p cgra: is already designed to see: :he general perfer=ance require ents of 10 CTR $ 73.55, there would be no increased f risk =c special nuclear =a:erial-'o:~ to :he 5:a:i$nt as :airesul: of en-site c: stru::icn-'a :ivi:1es. Further::re, because :he same degree Of p ::ecti:n applies to the Zi:n spen: fuel peel regardless of the nu ber of spen: fuel asse:blies stored therein, there v:uld be ne in:: eased risk as a result of the cpera:icn cf 1."sq the Stati:n with increased spent fuel s::: age capaci:y.-- i The Cc--'ssica's regula:icns pertaining to securi:y do no: require tha: licensees design their securi:7 progra=s to preven: thef: ef spen: fuel. This is because the nature of spen: I n :/ Tr. 2023-2024 122/ Tes:i=eny cf Larry 3. 3ean (3ean) a: pp. 1-10 fellevin i Tr. 2019: !iRC 5:aff Tes:i=eny en 3 card Questions 4(a) gand 4(b) by Dean M. Kunihiro (Kunihire) at p. 1 folleving -n 4 v,, c. A. w 1 k -a, -,e, .,,-,m, -,,-e.,,.,, .r,c

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) 77 fuel makes it an una::: active target for theft. liowever, the features of the Station Securi:y Plan designed to prevent sabotage should be adequate to protect against the risk of 191/ theft. The modification and/or subsequent operation of Zion Station vill not increase the potential risk of industrial sabotage to the S:ation or special nuclear caterial. The level of risk which the Applicant cust protect against is defined in 10 CFR S 73.55(a), and this defined risk is not changed by the proposed =odification and/or subsequent operation. The risk defined in S 73.55(a) is no: dependent upon the nu=ber of stored 192/ fuel a s s e=blie s.- There vill be no decrease in the level of physical protection, because the security progra: is designed to handle construction activities such as the proposed =edifica:Lon, and ~ because rhe degree of physical pro:ee:Lon relating to the spen: fuel pool is independen: of the n"-ber of fuel asse=blies stored i therein. I: vill no: be necessary to modify the Security Plan er Safeguards Contingency Plan because of the proposed modifi-cation and/or subsequent operation. The proposed modification 1,91/ Bean at p.11; KuniM 2. IJJ2/ Bean at p. 11; Kunihiro at p. 2. l i ,.-y,- , _ ~.. ~.-~.

4 78 vill not per=it the Applican: to store =aterial differen fro: that presently stored in the pool and the level of security pro:ee:icn required is independen: of the quan:ity 19Y of 1::adiated fuel con:ained in the pool.-- 1 All co=pany e=ployees and centrac:crs are subj ect to physical searches prior to entering a pro:ec:ed area. Each individual en:ering a p ctec:ed area is screened by =eans of =etal and explosive de:ec:icn equipnen:. In addi:icn, the Applicant's ncn-site assigned enployees and contracters ' e=picyees are physically searched en a randen basis. Appli-19u can:'s regular S:a: ion e=ployees are net physically searched.-- The Board inquired as to whether the' Applicant or the Staff had considered special nuclear =aterial other :han span fuel (as intended by the Board) in preparing thei .wri::en testi=ony. The vi:nesses responded that they had to: previously censidered =a:erial o:her than spen: fuel, but tha: the cenclusions stated in their d tes:imeny were equally applicable to such =aterial. 1/ prepare 10 l l The Board finds, based on the evidence presented, that the p cposed =odification and subsequen: operation of 193/ 3ean at p.12; Kunihiro at pp. 2-3. 191/ Bean at p. 7; Tr. 2027-28. 1,i}/ T:. 2028-30, 2038-39. O

4 9 79 i Zion Station with increased spen: fuel storage capacity will not increase the potential rish of threats, theft, or industrial sabotage to special nuclear =aterial or to S:ation facilities. Further, the Board finds that there vill-not be a decrease in the level cf physical protection of the facilities or special nuclear caterial at the Station and that there is no reason to modify the Safeguard Con:ingency Plan or Security Plan for the Zion Station. These findings are based, in large measure, upon cur belief _that :he degree and type of physical protection afferded to the Sta: ion's pro:ected areas is independen: ef the Enoun: of spent fuel stored at the Station.

2. ~ Modifica:1:ns to the Enertenev Plan ~

A portion cf Bosrd Question 4(b) pertains to whether 1: vill be necessary :: =odify the E=ergency Plan, as a result cf the proposed = edification and the proposed operation of the Station with increased spent fuel storage capacity. A detailed explanation of the Applicant's Generating Station Energency Plan (GSEP) was provided which included a descriptien of the different energency response classifications, the corporate e=ergency response s: rue:ure and facilities, and a descrip: ion of the Applicant's training and practice drills. The proposed modification or subsequent operation of the Sta: ion .,,,7__ ~

80 ) will not require a change to the GSEP, since the GSEP is designed to, provide an appropriate response to a.continuu= of possible accidents and is not predicated upcn a particular t a=ount of nuclear fuel in use or in storage at the facility, 196/ or tied to specific accidents or equipment malfunctions. The.3oard finds that there is no need to change the Applicant's Energency Plan due to the proposed modification and.subsequen: operation of Zion Station with increased spent fuel storage capaci:y. 3. Changes in Accidenes Postulated in Previcus Licensine Reviews Board Questions 4(c), 4(d),. 4(a)L and '4'(f) state: (c) What postulated accidents,' which might affect the safety of plant operating personnel in the spen fuel storage building or which might result in the release of radiation or radioac-tive ma:erials from the s ent fuel storage building,werespecificalkyanalyzedinthe TSAR, SEE, ER and FIS utilized in the CP and OL licensing reviews of Zion Units 1 and 27 (d) Which, if any, of the postulated accidents in (c), above, will be increa magnitude or consequence (sed in probability, to personnel, to the general public or to the environ =ent) if the proposed spent fuel pool modifications are carried out? (e) What provisions have been made or procedures developed to protect the work =en and/or plant personnel from the consequences of such postu-lated accidents during the period when the t groposed spent fuel pool modifications are being perfor=ed? log / Testi=eny of Denton Louis Peoples (Peoples) at p?. 1-15 t following Tr. 2044; Su on Board Question 4(b)pplemental testimony of John R. Sears Emergency Planning (Sears) at p. 3 following Tr. 2053. u ..-..s.

i I 81 (f) k*hich, if any, of the postulated acciden:s in ( ), above, will be increased in probability, tagni:ude or eensequence (:o persennel, to the general public or to the environnent) as a resul: ef the co=ple:ien of the p cposed spent fuel poci codifications and the proposed sub-sequent usage of the increased spent fuel s:crage capacity. Nine postulated accidents were specifically analy:ed in the FSAA, SIR, ER and FIS utilized in the CP and OL licensing reviews of Zicn Sta:Len Units 1 and 2 which tight affe:: the safety of plan: operating persennel in the spent fuel s:crage building er which tigh: result in the release of radiation er radioactive raterials fron the spent fuel storage building. These are (1) the fuel handling acciden:; -(2) a::idents.re-sul:ing frc: ear:hquakes; (3) :Ornado related accidents; I (4) spen: fuel cask drop acciden:s; (5) spen: fuel pool cooling sys:e= calfun::ien: (6) =al# ---' ens in c her parts cf the i plan ; (7) loss Of AC power; (S) leakage of radica :ive fluids; 197/ and (:) dr:p cf a heavy obje : ento a fuel rack.-- The proposed =cdifica:Len will necessi: ate addi:Lenal fuel = ves. Therefere, the likelihood, and correspending risk of a fuel dr:p a::ident will increase slightly. However, the increcental risk vill be =ini=al since the nu=ber of fuel = eves necessary to a ::=plish the =odification will' add less than one percent to the :::a1 nu:ber of fuel c:ves which will be ic]/ Tr=- at pp. 25-31; NRO Staff Testimony in Response to l Board Questions 4(c), 4(d), and 4(f) by Jack Denchew and John J. Zudans (Donohew and Zudans) at p. 2 following 1o,c,7.

a 9 82 1 acco=plished during the Station's lifeti=e. The fuel'which will be =oved during the =odification will have decayed a: leas: one =enth prior to being moved, which.will decrease the i =agnitude er consequences of the postulated fuel handling acciden by a factor of ten co= pared to freshly discharged fuel because of significan: radioactive deca.y of the gaseous 198/ fission produe:s contained in the fuel.~~ The Staff has under way a generic review of load handling operations in the vicinity of spent fuel pools to de:er=ine the likelihood of a heavy load i= pac:ing fuel in the pool and, if necessary, :he radiological consequences of such an even:. Un:11 a review of the radiological censequences of a cask d:cp acciden is ec=ple:ed, a shipping cask will not.be loc / perni::ed nea: the pool.as There will be no significan: increased risk to per-sonnel, the general public or the environment fro = the re=aining acciden:s considered as a result of the modifica:Lon and/or opera: ion of the Zion Station with subsequent increased spent 200f fuel storage capaci:y.-- The Zion Station I=ergency Operation ?:ocedure Nunber 6 (IO?-6) outlines the actions required in the event 1_9_S] Tra== a: p. 27; Donohew and Zudans at p. 3. W Donohaw and Zudans at p. 7. R29/ Tra== a: pp. 2'5-33; Donohew and Zudans at pp. 2-9. o 4

4 1 l l 83 a fuel assenbly is da: aged or specific moniters indica:e high 1 I 1 201 radiation levels in the spen fuel pool area.~~/ l i The Board finds that E0?-6 actions would adequately i protect verk=en and/or plant personnel from the consequences of pos:ula:ed a:ciden:s dcring the period when the proposed spent fuel pool codifications are being performed. The Board finds tha: the risks associa:ed with a fuel handling acciden during the period of the proposed fuel pool codifications will be less than those considered a: the operating li:ense stage. The Applicant vill no: receive per-cission to utilize a shipping cask within the. vicinity of the fuel pool until such tine as the S:aff has co=pleted its spen: review and evaluz:Lon of the poten:ial radiological conse-quen:es of a shipping cask falling into the pool. Therefore. -:he proposed =odification does no al:e: the risk of a cask drop accident. The Board finds tha: there is no reasonable l basis for believing :ha: the risks of :he other postulated ) accidents identified in response to Que.:: ion 4(c) would be increased significantly as a result cf the modification and/e i subsequen: operation of Zion Station. 201/ Leider a: pp. 12-13 and Attach =ent A; NRC Staff Testi-cony on scard Question 4(e) by Joel E. Kohler (Kohler) a: pp. 1-2 following Tr. 2000. L l l e i e -,m m- --+r

5 .? t 84 4 Desien and/or Enrineered Safeguards to' Decrease [ Likelihood of Severe Pool Drainare Acciden ~ In addition to the questions posed by the Board following the Prehearing Conference, the Board posed five additional questions to the parties.during the evidentiary hearing ' following the li=ited appearance. statements --- a . Board Question 4(g) states: i The Applicant and Staff are asked to~ describe any design and/or engineered safety features incorporated in the Zion spent fuel' storage pool to decrease the. likelihood of a severe pool drainage accident. The spent fuel pool, including'the pool cooling-systa=,is designed as ac Seisnic: Class' I~ structure. The foundation of the pool is directly in the ground and is com-plately surrounded by earth. The pool is lined with 3/16ths-inch welded stainlessLsteel and is provided with leak channels a= bedded in the concrete to collect and carry off to the rad-waste system any water which should leak through the liner. Additionally, the bottom of the pool is reinforced in the shipping cask loading area to withstand a drop of a cask. Fuel casks are handled with a Seis=ic Class I designed. overhead crane which is interlocked to prevent the carrying of a cask over the fuel in storage in the pool. Fuel asse=blies are handled with a Seis=ic Class I designed bridge crane which I 1 222/ Tr. 574-577. J l

) 85 i i

avels above the pool.

The fuel pool building is also a Seis ic Class 1 design, to withstand tornado loadings and tornade driven =issiles. The valls of the spen: fuel pool are approxi=a:ely six fee: thick cenerete and the floor of the pool varies in thickness fro: three end one-half feet to nine feet. yur:her-cere, the base =2: for the pocl is about seven fee

hick.

The exterier of the cenere:e valls and flo:: is covered by a pro-te::ive va:erproof coating. The =assive failure of the spent 203/ fuel pool s::veture is not censidered to be a credible event. The ner:a1 supply of =akeup va:er for the spent fuel pool is fro: :he de:ineralized flushing va e: syste: which can add water at about 200 gallens per =inute. Also, water

uld be added dire::17 to the spen: fuel cooling syste loeps f:c: the refueling va:e: s:crage ta{.k through per=anently installed piping.

Appreximately 100 to 250 gallens per minute ceuld be supplied in this =anner. yurther, fire hoses which exis: in the spen: fuel pool area and the auxiliary building are connected :o ele::ric and diesel fire pu=ps in the Seis=ic Ca:egory 1 crib house struerure. This syste: could be used to supply at least 1,000 gallens per cinute to the pool. In 203/

. 1025-30, 1035-36, 1554-56, 1865.

e A

r 86 addition to these three sources of water which are per=anently i installed, heses could be hooked up to draw water from the.pri=ary water storage ta=k, the secondary water storage tank, and the service water supply systa=, of these the service water syste: is a Seis=le Category I source of wacer which has its ewn inde-204/ pendent pu=ps. The Board finds that there are adequate design and engineered safety features incorporated into the Zion Station spent fuel pool which would reduce the likelihood of a severe pool drainage accident. The Board finds that these fea:ures should preclude the possibility.of a severe drainage accident in the Zion 5:ation fuel pool. 5. Pool Liner Leak Board Question 4(h) states: The Applicant and Staff are asked to provide a history of the apparent leak in the liner of the spent fuel pool. Specifically., the following should be addressed: (1) Has the leak intensified with ti=e7 ) i (2) Wha: is bei g done with the water n leaking from the pool? (3) Are there any technical specifications which li=it the per=1tted leakage rate? l (4) Why has the leak not been repaired? 2E/ Tr. 10'32-35. e m6----%er,mm,-r-y ,-y,-mw-.-,-, n.m.w -w .-e w---.m..- ,-.-,,.,--.,n ,nvm ,-*,,-4.

b - i 1 87 (5) Eev vill.possible future. leaks be located and repaired if the p;cposed in:: ease in storage capacity is perritted? I When the Zien fuel poel was originally :ested, several-leaks in the vertical velds of the stainless steel liner were dise:vered which were subsequently repaired. The Applican: estab-lished a max 1=u= per=issible leakage rate of 50 gallons per' day Since the ec==ence:en: c' opera: ion cf Zion 5:a:icn in 1973, the a:oun: ef =ake up water put into the pool has been a' constan: 20 gallens-per day. This =ake up ra:e represen:s the a=cun: ef ? wa:e les: through evaporatien, water re :ved fro: the poc1 during changingu:f fil:er'and der'ineralizer: bed, .::ansfer of the bed f c: peel coeling to refueling wa:e: s::: age tank cleaning, ' as well as leakage through the liner. Most of the vate: less appears :: be th: ugh evap::ation. During the first week cf the hearings, a three day sa=pling test.vas condu::ed and it was deter ined tha: the va:e: collec:ed f:== the fue1 pool was so app cxina:ely a quar a day. The leakage goes through the leak-off lines inte the drain cellee icn tank and is handled as nor=al radwaste water. There are :: technical specifica: Lens which IL:1: the per:1::ed leakage ra:e f:c: the spent fuel poc17~ 205/ State of the ar: leakage detection devices can i loca:e a 0.005 gallen per =inu:e leak. Such a leak would result i 2 _05/ Tr. 5 88, 1921-22. 1926-29. 8 -me,. ..v.,_,.-,~g,,.- .,,,,.._.....wm...,,,.. ,..._.,.,.._..~..,--...__..,%,$ ~, s~~.

i r 88 k in an excess of seven gallons per day total leakage. 'There-fore, it is difficult to locate a leak such as the Zion fuel pool leak. There are.several =ethods by which possible future leaks could be located and repaired if the proposed increase in storage capacity is per=i:ted. First, the Applicant could atta=p: to eli=1: ate other possible leakage pathways. This would entail the checking of drains, puups, seals, valves, and heat exchangers. Secendly, is order to eli=inate leakage pa:hways fro = the top of the pool liner, the water 1svel of the pool could be decreased so=ewhat vi:hout endangering workers in the fuel poci area. If :he leak had still not been loca:ed, a diver could be s'ent in:o.:he'pcol to inspect ^the sea = velds in I the liner by means of a vacuu: box. This =igh: necessitate the shuffling of fuel and/or the re= oval of racks to permit suffi-cient clearance for inspection by the diver If reshuffling were not possible because of the a=ount of fuel stored in the pool, fuel could be te=porarily stored in shipping casks or in the contain=en: cavity. Once loca:ed, the liner could be velded as 1: was following the preoperational testing of the spent fuel 209 pool.-- The Board finds tha: the a=ount of water that is curren:17 leaking frc= the Zion spent fuel pool is negligible and does not represent a significant safety or environmental t Concern. 2,07

. 1923-25, 1928-29, 1993.

i l i

89 6. Co:cenent Coclins Syste: Leak Ecard Queitien 4(1) states : The Applicas: and Staff are asked to address the contention =ade during li=ited appearance stata=ents that the co=cenent cooling syste= has had a nu=ber of leaks which have not been repaired. The ce=penent coeling syste: consists of pu=ps, valves, piping and heat exchangers. By design, some of these co=ponents leak wa:er at a rate of abou: 0.2 gallens per minutes through seals in rotating ec=penents such as pu=ps and valves. Leakage is detected by level changes in the co=ponent cooling syste= surge tank'which is alar =ed in the control roo=. Early in 1978, Zion Station operating personnel noted tha: the leak rate had increased :o approxi=ately 0.4 gallens per cinute. The leak was traced to one of three heat exchangers in the ce=penen: cooling syste=.- Due to difficulties in procuring the gaske:r necessary,to reasse=ble this heat. exchanger, plant personnel did no: repair the leak during the spring 1979 refueling outage as originally planned. The Appli-cant noted that it planned to perfer= this maintenance operation during the fall 1979 outage. Water which leaks fr== the ec=penent cooling syste flows :o the service water systet. The co=ponent cooling syste= is moni:ored for radicactivity, and no radioactivity has -.s.,,,w n,--m a om-. - -,, - n, -,s,,,-,-n,~-m.,- ,,------m-,w.. ,+.-,wr -r-., ,- m., f,,,,,,, - ~r-~, n n-

4 s 90 t P been detected in that systa=, Even if the leakage rats were to increase, there would be no i=pairment in the ability of the 207 plant to centinue operation or to shut down.-~/ r On one occasion during the prior year or two, se=e boric acid had apparently leaked onto the component cooling systa= pu=ps from boric acid tanks located on the floor above. This did not affect the operability of the pu=ps and was subse- .208/ quently cleaned up and =aintained in a clean condition.-~ The Board finds that the ec=ponent cooling systa= leak does not represent a threat to the proper functioning of the syste=, and thus is not an unresolved safety question which mi;it affect the operation of the spent fuel pool cooling systa=.- 7. Increased-Fuel Burnue Tes ts 2 Board Question 4(j) states: The Applicant and Staff are asked to report on the increased fuel burnup tests from the' standpoint of the extent to which these ( subse"quent spent fuel assemblies have been considered in the various analyses perfor=ed as part of this proceeding. l On March 7, 1979, the Applicant was granted per-mission to subject four fuel assemblies to additional burnup in the Zion reactor. In studies which had been conducted with respect to fuel which had been exposed to a burcup of $8,000 2,07/ Tr. 1037-40. 208/ Tr. 805-09. 1 0 r ,, ~. .f,

b 91 megawa::-days per =e:ric to peak rod average burnups, no unusual or unexpected changes in the preperties of Zirealey had been observed. Therefore, the fuel in question a: Zion, which will be exposed to between 48,000 and 55,000 =egava::- days per =e: ic ten burnup (bundle average), should not behave differen:1y than the fuel which was the subject of the earlier 209/ s:udies in ter=s of the effects on the Zircaloy cladding.~~ Because of U-235 depletion, the decay heat associa:'ed with the high burnup fuel vill be approximately 9 percen:. lever for the firs: year cf storage than fuel subject to ner=al burnup. After about one year of storage the high burnup asse=blies will have a slightly higher decay hea: rate than nor=al burnup fuel stored for an equivalen: length of ti=e because of longer lived ise:cpes present. Howevat, on balance th'e decay heat from high burnur asse=blies vill be lower than tha: from n:r=al burnup fuel. Approximately 25 percen: =:re longer-lived iso:cpes can be expected in the high burnup fuel assemblies tha= in nor=al bprnup fuel. Eevever, the = ore volatile fission products l have shorter half-lives, in general. Therefore, the consequences cf a drop accident involving a higher burnup asse=bly would be lower for high burnup fuel because of lower power densities due to U-235 depletion. Therefore, the probabili:y of a 2.23/

. 1276-80, 1802-07.

s. 92 I radioactive release from leaking higher burnup assemblies l 21Q would be lower than for nor=al assemblies.-~ The Board finds that the increased fuel burnup tests being conducted at the Zion Station do not increase the hea lead on the spent fuel pool cooling system.and do not increase the risks of radioactive releases from leaking fuel or from a fuel assenbly drop accident in comparison to the conditions already considered as part of the amendment request. 8. Tuel Building'and Groundwater Monitorinz 1 i Contention 2(e) states: l The amendment request and supporting docu-mentation' do not adequately discuss. monitoring. procedures. In the light of'the pioposed' modification and long term storage of nuclearc a spent fuel'the~ Applicant should clarify the following [ inter alia]: (5) Procedures to monitor groundwater move-ment in the vicinity of the plant to detect leakage from-the spent fuel pool. l Although the parties sought to withdraw this conten-tion, the Board stated that it would like to hear evidence on this issue and directed the parties to consider this contention / as a Board question.2.11 Applicant's witness discussed ground-l water monitoring at the Zion Station 232/ 219/ Tr. 1789-91, 1795-99. 211/ Tr. 730. 212/ Tr. 1005-1027 4 f f si... ....,,.,...-.a...-.... 4

93 Applicant's' radiological =enitoring.progra= was pla=ned to serve two obj ectives : to deter =ine background concentrations of radioactive =aterials in the Zion environ =en prior to operational studies), plant startup (pre-and subse todeter=inetheradiologicalehuently fec p(operational studies). 7.12)viron=en:ts of lant operations on the e. Included in the i=1:ial monitoring progra= were several groundwater sa=ples and a sa=ple of lakevater off State Park 213 Lodge ~- / ~ Applicant's witness testified:: bat the'rcutine en-k viron= ental progrs= for =enitoring groundwater was condue:ed~ fron 1970-1977 and consisted of =enitoring three wells to the ' vest of the site, with quarterly grab ss=ples analyzed for 214 gross alpha and gross beta ac:ivity. / ~ further stated :ha:, at his suggestion,~~/pplicant's vitness A 215 Applicant "=ade a formal sub ittal to the NRC, requesting a change in the tech-nical specifications"'6 in par: "to do away with the well water 21 =enitori=g progra=. "- / The change also eli=inated the collec-217/ tion of lakevater fro the Lodge area -- Rationale for the 212/ Final Environ = ental S:ata=ent Related :o Operation of Zion Power Sta: ion, Units 1 and 2. Co==onwealth Edison Conpa=y, Docket Nos. 50-295, 50-304, Dece=ber 1972 (TES). 213/ Id., at V-33 and V-34; Final Safety Analysis Report T 2.8, Table 2.8.1. 2,1h/ Tr. 1008. ~ 2,15/ Tr. 100s. 2,16/ Tr. 1009. 217/ Tr. 1012. _. _. _.. _ _, _.,. ~ - -. - -.. _. _ - - _,. _.. - -, _,. _ _ _ _

n 94 change in technical specifications, which was 1=plemenced in ] Nove=ber 1977,was that "the only.vells that we had available to i .us were.on the west side of the plant-and groundwater in this area moves eastward" and "second, that there is no discharge to the groundwater from Zion Station or, really to my knowledge, from any other nuclear station.'g Not surprisingly, the "upgradient" samples that were taken between 1970-1977 failed U.9/ to show any' unusual level of radioactivity. Applicant's c witness ad=itted that this program would not be capable of detecting any leakage from the plant into the surrounding 220/ groundwater. The existing monitoring progra= for detecting release of liquid radioactive effluents into the environment consists of sa=pling at the Station" intake (2500cfeet;out into J the lake),,the Station. discharges -(700 feet-out from shore), and six public water intakes, the closest being about a =ile 221/ north of the plant. There are no groundwater monitoring ~- walls on the Zion Station site itself, either upgradient er 222 downgradient of the Station.~~/ 1pplicant's position is that the purpose of any groundwater monitoring would be to detect con'ta=ination of existing potable water supplies, rather than monitoring for possible contamination of groundwater fro: site 223/ activitie s.- 218/ Tr. 1009; Tr. 1011. 219/ Tr. 1010-1011. 220/ Tr. 1011. 2,21/ Tr. 1012. 222/ T. 1013. 223/ Tr. 1016; Tr. 1017. .,me ,---w c4~....,,-.,,.,--.....+,.remer .,ww,-r ,w.-w,,,'...,,.-,,.., we ,-4w,,w.,-.%.-,--.y,-., ,,.-,.m--e,e.w-.-.v-mwre-~ -e cs

a 95 h The Board finds that the issue of groundwater moni-i ) toring involves catters beyond the scope of this proceeding wh.ich is li=ited to matters related to potential-impac:'of increasing the storage capacity of the spent fuel pool. We are not authorized to examine ma:ters which were explored at the construction per=1t.or operating stages, nor those which-were resolved with subsequent amend =ents to the technical ,sp e cifications. However, the Board calls attention to certain' unusual features of the Zion Station. Zion Station is uniquely situated in that its 250-acre site is within the city li=its of the City of Zion, fronts on Lake Michigan, and is ~ adjacent to-a' '~ maj:: pa'rk, Illinois Beach State Park,- attracting ~over ~one ' cil ' lien visitors per year. y The residen:ial area of Zion is less than a =ile fro: the site. The residential center of 22V Zion is app cxi=ately 1.5 ciles fron the site. .The area is -~ l underlain by creviced dele =itic bedrock aquifers and water-1 I yielding glacial deposi:s which a e connected hydrologically; the geological structure is such.that prevailin roundwater flov should be eastward (toward Lake Michigan).-~ The shore-t line in the i=nediate vicinity features the only dunes in the state, "such a unique and special feature that the State of Illinois has set aside a 3-=ile tract of shoreline and adjacent territory as a state park."U21 224/ TES at II-10. i l 225/ FIS at 11-3. 2]j/ TIS a: II-5 and 11-8. 2,2]/ TES at,II-9. i

i r 96 The Board further calls attention to the fact that' the radiological =enitoring system has never included ground-water =enitoring in the 4-ediate vicinity of the site and at the present ti=e includes no groundwater monitoring at all. While the Board finds that the proposed modification will not in itself increase :he environ = ental i= pact of the Station, we find no basis for deternining whether the present STP or the 5:a: ion as a whole has had any effect on the grounduater in the vicinity. We further note that a current Regula:ory Guide points ou: :he i=por:ance of groundwater =enitoring in the 228/ 1 vicinity of spent fuel storage pools.-- I 223/ Regulatory Guide 3.44, " Standard For=a: and Content fo-the Safety Analysis Report to be Included in a License Application for the 5:orage of Spent Fuels in an Inde-pendent Spen: Fuel 5:orage Ins:allation (Water-Basin Type)", Dece=ber 1978, f 2.5. ~ l 1 v~$ --*--r w w -r-wq,y y m f a c +~ m-wa -E-- +- m1

= A i 97 III.., CONCLUSIONS OF LAW 1 l The Board has reviewed the evidence sub=itted by all parties in regard to Intervenor's contentions,-and in response to the Board's own questions. The Board has also considered the proposed findings of fact and conclusions of law sub=1 :ed by the. parties. Those proposed findi=gs of fact and conclusions of law not adopted herein by the Board are rej ected. The Board =akes the following conclusions of law: (1) The issuance of the license amend =ent . requested in this proceeding is not a major Co==1ssion action significantly affecting the quality of the hu=4n environment and therefore it does not require the prepara: ion of an environ = ental impact-stata=ent under the National Environ =en:al' Policy Act 'of-1969142 U.S.C. I 4321, et sec., and Par: 51 of'the Com-'ss' ion's regu-la:icns,70C7R Par: 51. - (2) The Co==ission's " Notice of Inten: to Prepare Generic Environ =en:al != pac: Statement on F.andling and S:orage of Spen: Ligh: Water Power Reactor Fuel", 40 Fed. Reg. 42501 (Septe=ber 16, 1975), does no: prohibit non-e=ergency licensing actions designed to a eliorate a possible shortage of spen: fuel storage capacity prior to ec=pletion of the Generic Environ = ental I= pac: State-ment. Per land General Electric Cor any (Trojan Nuclear Plant), ALAB-531, 9 NRC 263 (1979). The Board has applied

he five factors mentioned in the Com-d ssien's Notice of Inten: and concludes tha: they favor issuance of the requested license a=end=ent at this ti=e.

(3) The Board finds tha: the proposed action udll not significantly affect the hu=an environ =ent. I: therefore finds that it is not required by law to consider the alternatives of shutting down or curtailing the output of Zion Station. e 4 --,-.-----..-mi-------. .---m- ,,--e-sw,- w ,w w y-

o 98 4 (4) There is reasonable assurance tha: the activities authorized bv the reques:ed opera:ing license a=end=en:s can he conducted vi:hout endangering the health and safety of the public provided that the conditions set forth in the order, below, are incorpora:ed into the licenses. (5) The activities authorized by the requested operating license a=end=ents will be subj ect to co=pliance with the Co-ission's regulations. (6) The issuance of the requested operating License amend =ents will not be ini=icable to the r:o==en defense and security or to the health and safety of the public provided there is co=pliance vi:h the condi: ions se: forth in the order below. O e I O 9 4 9 4 .-e..-

i n 99 . IV. ORDER Wherefore, it is ORDERED, in accordance with the Atomic' Energy Act, as amended and the regulations of the Nuclear Regulatory Cc--'ssion, and based on the findings and conclusions ferth herein, that the Direc:or of Nuclear Reactor Regulation se: is autherized to make appropriate findings in accordance with the Co==ission's regulations and to issue the appropriate license amendment authorising the requested replacement of spent fuel s:crage racks at Zion Station. The aforementioned license a=en.d=ent shall contain the following conditiens; - (1) Tuel stored in the spent fuel pool shall. have a U-235 loading less than or equal to 40.6 gra=s per axial centi =eter. (2) No loads heavier than the weight of a single spen: fuel asser.bly plus the tool for moving tha: assenbl s:ored in the spen:y shall be carried over fuel fuel pool. The spent fuel handling tool, the burnable poison tool, the rod cluster centrol changing fixture and the thimble i plug shall not be carried at heights greater than two fee: over fusi s:cred in the spent fuel pool. The aforementioned license a=endement takes into considera:ics the following coc=it=ents by the Applicant: (1) No:ification of the NRC dn advance should it becone necessary to handle heavy if ads in the vicinity of the spent fuel storage pool.220 (2) A corrosion surveillance progra= for the racks to insure that any loss of neutron absorbe- ~ swelling of the s:oragh tubes is detected.13$aterial and/or / 227 Sutra, p. 24 230/ Sutra, p. 63

100 (3) In. situ neutron attenuation tests to' verify that tubes anc racks contain a sufficient-number of Boral plates such that K-effective will not be greater than 0.95 when the spent fuel is in place.211/ The Board finds that these ce=nitments by the Applicant add to the assurance of safe operation of the Spent Fuel Pool, and therefore they contribute to the Board's conclusien that the application to modify the Zion spent fuel pool' should be granted.. Accordingly, the Board finds as 1 a matter of law that the Applicant is bound by these com=itments and that failure to i=plement the: is subj ect to any appropriate sanctions found in the Co==ission's regulations. It is further ORDERID 'in.accordance with 10 CTR i $ 5 2. 760, 2. 762, 2. 7 64, 2. 785,.and 2. 786, that this' Initi-al Decision shall be effective i= mediately 2 / and shall constitute i t the final action of the Commission forty-five (45) days after the issuance thereof, subject to any review pursuant to the above-cited Rules of Practice. Exceptions to this Initial Decision may be filed within ten (10) days after service of this Initial Decision. A brief in support of the exceptions shall be filed within i 211/ Sutra, p. 74 232/ This proceeding is not covered bv the 'Co==ission's recent ~ -~ suspension of the i==ediate effectiveness rule '(10 CFR f 2. 764) for certain purposes. 44 Fed Reg 65049 (Novenber 9,1979). l.....

ATTACHMENT E UltlTED STATES OF AMERICA liUCLEAR REGULATORY COPaISSION OFFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR In the l'atter of ? Docket Nos. 50-295 50-304 CO:'M0!;UEALTH EDISON COMPANY [ (10CFR2.206) (Zicn Station, Units 1&2) 1 DIRECTOR'S DECISION UNDER 10 CFR 2.206 4 By letter dated April 27, 1979, Ms. Catherine Quigg, on behalf of Pollution and Environ.7. ental Problems, Inc. (PEM), transmitted a request pursuant to 10 CFR 2.206 for the preparation of an environmental impact statement on high burnup fuel at Zion Station, Units 1 and 2. This request was predicated on the fact that on March 7,1979, the Nuclear Regulatory Commission issued bendments Nos. 44 and 41, respectively, to Facility Operating License Nos. CPR-39 and CPR 48. The amendments revise Technical Specifications for Zion ~ 5tation, Units 1 and 2.M These amendments would allow the reins ~ertion of a._ 2 __. 1 maximum of foer fuel assemblies previously irradiated in Unit 1 for a maximum cf two additional fuel cycles (beyond the normal three fuel cycles) in Unit 2 to gain operating experience for an anticipated future extended burnup program. PEPI requested the preparation of an environmental impact statement to provide information which it thought the public needed because of the following factors associated with high burnup fuel: 1. greater fission gas releases from nuclear reactors; 2. increased fission gas releases from apent fuel pools due to increased corresion; 1/ A andments 44 and 41 are attached as Appendix A.

.2- ~ 3. previous government research, based on " low burnup fuel" is useless in predicting the behavior of "high burnup fuel", and 4. potential for greater radiological impact fri. reactor and spent fuel pool accidents. Consistent with the flational Environmental Policy Act of 1969 (Public Law 91-190, 83 Stat. 852) and the Commission's regulations (10 CFR Part 51), an environ-mental impact statement E was prepared at the operating license stage of Units 1 and 2. This statement addressed the range of environmental impacts associated with the operation of the Zion Station. However, an environmental impact statment is not required to be prepared for every license. amendment. In this case, the 5taff had prepared an environmental impact appraisal E and negative declaration #/ pursuant to 10 CFR Si.5 for the amendments, and had concluded that an EIS was not w'arranted because the action will not significantly affect the quality of the human environment. The negative declaration was published in the Federal Reoister on !! arch 19,.1979, (44 FR 16504). In the environmental impact appraisal, the Staff compared the fission gas re-lease from the extended burnup fuel assemblies in the Unit 2 core to the releases from the other fuel assemblies in the core. It was noted that operating Unit 2 y Final Environmental Statement Related to Ooeration of Zion Nuclear Power Station Units 1 and 2, December 1972. Environmental Imoact Acoraisal by the Office of Muclear Reactor Reculation 3f Succortino Amendment No. 44 to Facility Coerating License No. CPR-39 and Mencment No. 41 to Facility Goeratino License No. OPR-48 dated March 7, 1979. The Appraisal is attached as Appendix S. l 4/ Notice of Issuance of Amendments to Faci 11tv Coeratino Licenses and Mecative Declaration _ dated tiarch 7, 1979. The "otice is attached as ~~ Appendix C.

101 e thirty (30) days thereafter (forty (40) days in the case of the Staff). Wi:hin thirty (30) days of the filing and se:vice of the brief of the Appellan: [ forty (40) days in the case of the Staff), any other party may file a brief in support of, in opposition to, the exceptions. c: IT IS SO OFIEFID. TdZ ATOMIC SATE *"Y A'iD LICENSING 30A?3 Y C Linca W. Little, Me=er ~ yyl. Rem ct, hemcer Nw r s 'Jonn F. Wolf, Cnairnan j' i l 1 l t l Dated a Bethesda, Maryland, t

his 14:h day of February, 1980.

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