ML19029A874
| ML19029A874 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/11/1979 |
| From: | Onsdorff K State of NJ, Dept of the Public Advocate |
| To: | Kornblith L, John Lamb, Milhollin G Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML19029A874 (13) | |
Text
DEPARTMENT OF THE PUBLIC ADVOCATE DIVISION OF PUBLIC INTEREST ADVOCACY P.O.BOX141 I
STANLEY C. VAN NESS PUBLIC ADVOCATE TR*NTO N. N*W """¥Tr~r-rr April 11, 1979 Gary L. Milhollin, Esquire Chairman, Atomic Safety and Licensing Board Mr. Lester Kornblith, Jr.
Member, Atomic Safety and Licensing Board Panel CARLS. BISGAIER DIRECTOR TEL. 609-292-1693 1815 Jefferson Street Madison, Wisconsin 53711 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. James C. Lamb, III Member, Atomic Safety and Licensing Board Panel 313 Woodhaven Road Chapel, Hill, N.C. 27514 Gentlemen:
In accordance with the prov1s1ons of the perhearing order in this proceeding, intervenors, Mr. & Mrs. Alfred Coleman, hereby submit their proposed direct testimony to be elicited from Robert M. Crockett, Vice President for Fuel Supply, Public Service Electric and Gas Company.
Mr. Crockett was designated by intervenors as their witness at the March 15, 1979 prehearing conference held in this matter, at which time counsel for licensee raised no objection thereto.
Accordingly, it is our understanding that Mr. Crockett will be available to give his testimony without further compulsive process being issued by this Board.
Of course, if Mr. Crockett has some unavoidable conflict, intervenors would be amenable to Public Service producing another company official who is fully familiar with the authorship and content of Mr. Crockett's January 19, 1978 letter and the attachments thereto.
The last sentence of this missive identifies Mr. Louis A. Sonz, Nuclear Fuel Engineer, as an appropriate P.S.E.&G. Co. official to.provide such further information pertaining to the UtilitY 1s current nuclear fuel plans.
- Thus, it would appear that this person would be an appropriate witness for the intervenors in place of Mr. Crockett if licensee believes that such substitution is warranted.
Gary L. Milhollin, Esq.
Dr. James C. Lamb Mr. Lester Kornblith April 11, 1979 A company witness will be offered, then, to introduce and elaborate on the full contents of the Crockett letter of January 19, 1978 addressed to U. S. Department of Energy, Eric S. Beckjord, Acting Director, Division of Nuclear Fuel Power Developrrient.
In addition, intervenors may introduce al1 relevant P.S.E.&G. Co. documents pertaining to the operations of Salem One which have been filed with the NucJear Regulatory Commission and placed in the Public Document Room. *It is expected that these public records can be stipulated to by the parties.
In particular,.documents presently being reviewed for submission on the intervenors direct case include Licensee Events Reports as summarized in its Reportable Occurrence Reports, August 1976 through March 1979, detailing problems with the boron concentration of the primary reactor cooling water.
Any additional documents which are sub-sequently selected as relevant will likewise be identified prior to the hearing in this matter.
In response to the prehearing order directive relating to order of proof, intervenors have no objection to the suggested procedure offered by licensee, with the exception of the proposed use of witness panels.
Any proced1Jre which allows* several persons to act in concert to present testimony substantially undermines the very purpose for oral presentation of evidence.
Collaboration by sworn witnesses is the antithesis of individual responsibility for the truthfulness of affirmations given under oath. While this obj~ction is made without any implication of potential for in~entional untruthfulness by any witness proposed for these hearings, the reliance upon group consultations contains an inherent risk for group responses for which no one person accepts personal responsibility. Unless a o.,rerridiny benefit c1n be shmm for this procedure. it should be avoided to prevent these inherent risks associated therewith.
In a similar vein, intervenors hereby join in the objection of Lower Alloways Creek to the prehearing order's directive relating to the submission of proposed cross-examination.
This stifling requirement can only thwart the attainment of spontaneity of the responses elicited in the live testimony to be proffered on May 2 through May 4, 1979. Since this procedure.is not mandated by any identified rule or regulation governing hearings before the NRC, a strong showing of benefits to be derived therefrom should be made to justify its use. Without suggesting that such a showing would override the due process rights of intervenors to conduct their cross-examination without limitation as may be imposed by the bounds of their pre-filed outline, it is respectfully submitted that no reasons whatever for this novel procedure has been offered to justify this onerous mandate.
J
Gary L. Milhollin, Esq.
Dr. James C. Lamb Mr. Lester Kornblith April 11, 1979 Thus, unless the Board orders otherwise with the right of immediate appeal, intervenors shall deem their filing of an outline of cross-examination to be without prejudice to pursue additional cross-examination not covered by the outline, to the extent that same is germane, not repetitious and reason-able in light of the testimony presented during these hearings.
KAO: id cc:
Service List Respectfully submitt~d, STANLEY C. VAN NESS PUBLIC ADVOCATE BY: i/eilh 0 O~I KEITH A. ONSDORFF
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Assistant Deputy Public Av ~~§Y'
Robert M. Crockett
~.,;e.-.a*~-. r'. J 07101 201/430-6826 Vic.~~_.-=;.*::-=--::
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January 19, 1978 U.S. Department of Energy Eric S. Beckjord, Acting Director Division of Nuclear Power Development Mail Stop F-305 Washington, D.C.
20545
Dear Mr. Beckjord:
PSE&~ received the the ~equest of Mr. George W. Cunningham relative to the interest of domestic utilities in transferring spent nuclear fuel to the Federal Government.
Although PSE&G would prefer to have reprocessing and recycling of nuclear fuel for both economic reasons and conservation 6£ natural resources, we recognize that this is not possible at present.
Therefore we commend and support the D.O.E. proposed spent fuel policy which would have the Government accept spent fuel and store it in a retrievable repository for an indeterminable:ti~e.
A fee table for rlisposal charges would provide an excellent basis for calculatins n~clear fuel burnup costs and we look forward to the fee detersination, discussion, and availability.
We must emphasize that ~uch fee should reflect only the cost of services perfc~~ed, anc th2~efore, as we have stated at the D.O.E. briefing in October, 1977, there should be separate fees for situations usin9 interihl as well as geological storage, and situat~ons using geolo;ical storase alone.
The five year pre-disposal storage time is considerably longer than what appears to be necessary and it is our concern that design of the storage facilities based on this factor would require unnecessary penalties.
We advocate a repository capable of receiving spent fuel having considerably shorter cooling history than the proposed five years.
Detailed responses to the questionnaire are attached.
~hese ~resenfi
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the:--curr_entiPS_E&G:;;D:-uc],,_e_"_q_cfti.eL,:p-lans{a_ri.c1,~*F._~corr.m~n~ati~msj=l:elat:i\\1~-,.__::_:~
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.o::spent~£u6-:t-~~----==rcr--further information is required, please direct._ ~-~, __ ::. :.=::.:"_
your inquiries to Mr. Louis A. Sonz, Nuclear Fuel Enginee~, telephone number 201-430-6813.
Very truly yours, Attachments
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PSE&G RESPONSES TO DECEMBER, 1977 LETTER OF TEE DEPARTl1ENT OF ENERGY CONCERNING SPENT NUCLEAR FUEL DISPOSAL
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Question 1.
The information related to spent fuel assemblies discharged by calendar year is contained in Table 1.
These estimates are based on current fuel designs and operating schedules which are subject to change.
Question 2.
Table 2 provides a cumula.tive total. of spent fuel cooled at least five years.
This is based on the Table 1 information.
Question 3.
Table 3 contains the estimate of transfer of spent fuel to the Government based on a minimum of five years on site storage.
However, PSE&G would prefer to ship spent fuel with a minimum of one year on site storage, commencing when the retrievable geologic repository is available.
The transfers to the Government would be the result of an economic evaluation once the circumstances and fees are determined.
Based on the proposed costs for interim and geological storage facilities there is an incentive for a utility to wait for the geological repository to be in service if there is no need for interim water basin storage off the reactor site.
When such direct disposal is available, the~e are advantages to the utility in shipping the spent fuel directly to the geological repository providing reprocessing is not available.
Af*ipresenb-,..--th~Hop~Creek,.,,r.eacto:r:s...do--no-b-hav~suf£icient:.:.spen"t..!
fuel~pool~:~_apas:t:Yz.~()_Y.,;1:fiye"!-years..of storage,* therefore-five yeaJ 4
cooling on* site is _not_ possibI_e*:--,; ~-*--.-*
Limitations of on site spent fuel storage would have the PSE&G reactors reach saturation of the associated spent fuel £acility, assuming full core dump capacity, as follows:
Reactor Salem 1 Salem 2 Hope Creek 1 Hope Creek -2 ~:
....... - _. **-*** * '*Atlantic-:?1-:-
Spent Pool Capacity Adequate thru 1993 thru 1994 thru 1988 thru 1989 Pc3.St.,l.99Q: *_.* - ---'~----*
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PSE&G Responses to Dec~er, 1977 Letter of the Department of Energy Concerning Spent Nuclear Fuel Disposal Question 4.
It is not clear to PSE&G what the rationale is for five year cooling fuel criteria.
If the design basis for the repository or interim storage pool is based on five year cooled fuel it may force utilities to expand their on site pool capacity
- 2.
or require interim storage which otherwise may not be necessitated.
The five year cooling period seems to be excessively long.
PSE&G urges that the D.0.E. investigate further the spent fuel specification requirements with the thought of reducing this period.
PSE&G certainly would prefer to see it reduced.
Advance notice for transfer of spent fuel is understandable for planning purposes.
It must be recognized that there is the lik~lihoodl of emergency situations such as leaking fuel or some other difficulty~
which will necessitate shorter notice and earlier transfer.
Question 5.
PSE&G comments on the acceptance guidelines and criteria provided for consideration are as follows:
a)
Reprocessing is preferred to disposal.
If reprocessing is not irw.~inent, it is very desirable to.have a retrievable repository available operated by the United States Department of Energy.
b)
Government maintenance of spent nuclear fuel off the reactor site should be on a voluntary basis for domestic utilities and sho~ld be 2vailable as soon as possible.
PSE&G supports the D.O.E. efforts to have a geological repository available in 1985.
c)
Advance notice to transfer spent fuel is und2rstandable.
Five years notice must have a degree of flexibility, or in other words, a limited 2~ount of schedule mismatch penalties associated with the contract because of the inherent inability to predict future fuel designs, isotopic burnup, fuel leakers, etc.
The length of the contractual advance period acceptable would be a function of the terms and conditions of the contract.
d)
Cooling of five years appears to be excessive and PSE&G would prefer to have a more reasonable period on the order of one year, or less, as the minimum.
The spent fuel facility design should be based on fuel cooled much less than five years.
e)
A published fee structure which is properly determined and justifiable before state utility cowmissions is desirable.
f)
The fee must represent the services utilized and if interim storage and transportation to the geologic repository are not required in a situation, there should be a fee for the geologic disposal separate than that for all services.
e PSE&G Responses to Dece~ber, 1977 LPtter of the Deoartment of Energy C;~cerni~g Spent.Nuclear Fuel Disposal
.e g)
It is assumed that the fee in dollars per total mass of heavy metal would be calculated based on the accountability record at time of transfer of material to the facility.
Billing would occur when spent fuel is transferred at the repository.
- 3.
h)
A table of fees and charges for spent fuel disposal should
- be published for a period of five to ten years in advance of transfer.
i)
The Government repository should be able to accept all rail and truck casks which are licensed.
j)
The Government repository should be able to accept channeled and unchanneled fuel, and also fuel with burnable poison rods inserted in the assemblies.
Question 6.
As mentioned previously, the form of fee should reflect the services needed and if separate fees for interim off site storage and geological repository storage are determinable 1 they should be published and applied.
Any fee for disposal of spent nuclear fuel should be determined to recover only those ixpenses associated with disposal and the ability to retrieve the fuel if reprocessing is possible in the future.
As stated previously, PSE&G would like to analyze the determination of the fee structure and be given an opportunity to comment.
QuestioD 7.
Acditional comments are:
a)
Title should change when fuel is accepted for disposal.
There should be no liability exposure to the utility after delivery
-to the Government, unless the fuel is returned to the utility for reprocessing.
b)
Governmental support of the disposal fee should be available to hearings in which the utilities must provide information.
c)
The treatment of inherent values in spent nuclear fuel is of interest and it should be a right of the utility to recover its spent fuel with an equitable adjustment of the disposal fee if such recovery is available. in. the future.
1/19/78
Calendar Year 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 19 8 ~- --- -
TABLE l ESTIMATE OF SPENT FUEL DISCHARGES -
PSE&G Reactor Salem 1 Salem 1 Salem 2 Salem 1 Salem 2 Salem 1 Salem 2 Salem 1 Salem 2 Sale::; l Salem 2 Saler:, l Salem 2 Sales 1 Salem 2 Hope Creek 1 Salem 1 Salem 2 Hope Creek 1
__ Salem 1-Salem 2 Hope Creek 1 Hope Creek 2 Fuel Type PWR PWR PKR PWR
- PWR Pio;R PWR PWR PWR PWR PWR PWR PWR BWR PWR PWR BWR PWR PWR BWR BWR No. of Assemblies Discharged 64 64 64 128 64 64 128 64 64 128 64 64 128 64 64 128 64 64 128 64 64 240 368 64 64 196 324 64
" 64 176 240 544 Heavy Metal of Spent Fuel MT-HM 29 28 29 57 28 29 57 28 28 56 28 28 56 28 28 56 28 28 56 28 28 43 99 28 28 35 91
- 28
- ~-
- :-~-:.:.~-:._:.-- ~-- -*2 8 31 43 130
e Estisate of S?ent Fuel Discharges -
PSE&G Calenda*r Year 1989 1990 L.?>,.S:jas 1/19/78 Reactor Salem 1 Salem 2 Hope Creek Hope Creek Salem 1 Salem 2 Atlantic 1 Hope Creek Hope Creek No.* of Fuel Assemblies Type Discharged PWR 28 PWR 28 1
BWR 164 2
BWR 180 2
BWR 176 546
- 2.
Heavy Metal of
. Spernt Fuel MT-HM 28 28 29 35 120 28 28 29 32 31 148
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Calendar Year 1979 1979-1983 1984 1985 1986
- 1987 1988 1989 1990 LAS:jas 1/19/78 TABLE 2 ESTIMATED CUMULATIVE TOTAL OF SPENT FUEL COOLED AT LEAST FIVE YEARS -
PSE&G No. of Assemblies Heavy Metal of Fuel Cooled at Least Spent Fuel Cooled Reactor Type Five Years at Least Five Years First Discharge -
Salem 1 MT-HH Cooled less than five years Salem 1 PWR 64 29 Salem 1 PWR 128 57 Salem 2 PWR 64 29 192
---s6 Salem 1 PWR 192 85 Salem 2 Ph'R 128 58 320 143 Salem 1 PWR 256 113 Salem 2 PWR 192 86 448 199
- Salem,
PWR 320 141 Saler.. 2 P~.;R 256 114 576 255 Saler;; l PWR 384 169 Salen 2 P\\*iR 32*0 142 704 311 Salem,
PWR 448 197 Saler'.': 2 PWR 384 170 832 367
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Calendar Year 1984 1985 1986 1987 1988 1989 1990 LAS:jas 1/17/78 TABLE 3 ESTI?*Li'.l..TED TR~~SFER OF SPENT FUEL DISCHARGES --' PSE&G
~
BASED ON FIVE YEAR ON SITE RETENTION.
No. of Heavy Metal of Fuel Assemblies Spent Fuel Reactor Type To Be Shipped To Be Shipped Salem 1 PWR 64 29 Salem 1 PWR 64 28 Salem 2 PWR 64 29 128.
---s7 Salem 1 PWR 64 28 Salem 2 PWR 64 29 128
---s7 Salem 1 PWR 64 28 Saler.; 2 PWR 64 28 128 56 Salem 1 PWR 64 28 Saleili 2 PWR 64 28 128 56 Salem 1 PWR 64 28 Salem 2 PWR 64 28 128 56 Salem 1 PWR 64 28 Sal err. 2 PWR 64 28 128 56
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IN THE MATTER OF PUBLIC SERVICE ELECTRIC AND GAS COMPANY (SALEM NUCLEAR GENERATING STATION, UNIT NO. 1)
DOCKET NO. 50-272 CERTIFICATION OF SERVICE I hereby certify that copy :of Intervenors, Col emans,., Direct Testimony and objections to the Format of Hearing Procedures as Outlined in the Prehearing Order and April 2, 1979 Proposal of Licensee in the above-captioned proceeding has been served on the following by deposit in the United States mail, first class, this llth day of April, 1979.
G2ry L. Milhollin, Esquire
- Chai:::n2~, !1.to;:iic: Safety au.d Licecsi-;ig Bo.?.."t"J 1815 Jefferson Street N3dison, Ri~consin 53711 Mr. Lester Komblith, Jr.
Member, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 1\\'ashington, DC 20555 D.:-. J.:!c-::s C. L28b, III
~~=b~r. ~~02ic Safety 2n~
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- U.S. ~!uclc.::ir Regulatory Cc~.:-:?::i..s"sion l!.:!shin;ton,, D.C. 20555 Troy B. Conn~~> Jr.> Esq_
Suite 1050 17.:}7 Pennsylv~r:.ia Ave.> U.:"Ll
\\-:ashi:uiton> D.C.
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E~rry S~ith, Esq.
OE f "!.ce of the-E:;:(ecutiv~ Legal DirectoL" li.. S_
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Co~~:i.ssion t-::~~:1t.;::;,:~ton, D.C-2C55S Jw.c D. }~c:Artor:. Esc;.
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D2puty Attorn~y G~n2ral Dcp~~t~e~t of 1~~ ~n~
Public Sz.:fety 36 ~est Stac2 ~treet Trer?.to~>
Xe~..; Jersey*
03625 Richar<l Fryling, J~-, Esq_
Assist~~t G2~2r~l Solicito~
Public Se=vice Electric and*
Gas Cospany 80 P2rk Pl2ce Ne:J2r~~, ~~et-T JersE:y 07101 Elearto~ G. Coleaan Alfretl c_ Cole~2n 35 11K" Drive Peansville> Ket.; Jersey 08070 Office of th2 s~crctary Do~kcti~~ and Service Section U.S.* i':uclea-r-Regulatory Co:nission W2sning::on> D-C.
20555 C~rl V~lor~, Esq_
535 'Iilton ~-*=>.:!<l
~:o.:-thficld, Ke:-: Jersey 08225 Dale B~iden~2ugh G::egor~,r }Ii110!.""*
!-L H. }L Tee hnic2l AssociL!t:es 366 California Avenue> Su2te 6 Palo Alto, Califoxnia 95306 Janice E. ?.!oore Counsel £or l\\'RC Sta££ US ;:.;_1clear Regual tory Comm.
~ff1~c of the F~ecutive Leaal Dir.
l\\aslungton, DC 20555 0
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