ML19224C247
| ML19224C247 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 05/29/1979 |
| From: | Ketchen E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7907020008 | |
| Download: ML19224C247 (10) | |
Text
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F4 PUBLIC I'OCiniwT FN g
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fluCLEAR RECULATORY COl'. MISSION CN N b
-9 BEF09E THE ATOMIC QFFT_Y AND LI_CEJ SIjiG COARD gg 311973 > 1 S*
um a +t If Wi%.f In thc Matter of
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t fj DUKE POWER COMPANY Dccket Io. 70-2623
)
(Ac":ndment to !bterials License
)
SiiM-1173 for Ccont-e !!cclear Station
)
Spent Fuel Transportation and Storage )
at McGuire liuclear Station)
)
NRC STAFF RESPONSE Ill CPPOSITI0Ti TO " NATURAL RESOURCES CEFENSE COUMCIL fiOTION FOR SU M RY DISPOSITICN WITH RESPECT TO I;RDC CONTENTION 4" (I'ay 1,1979)
I.
Introduction flatural Resources Defense Council (NRDC) filed a motion for summary disposition with respect to fiRDC Contention No. 4 on May 2,1979.
IIRDC states, "that the basic thrust of our contention is that the proposed action does not assure that releases to workers Lill be kept as low as reascaably achievable,"
(Motion p.1), although the scope of the Contentien 4 as written would appear to be much broader. S Accordingly, our response is geared to the issue raised by NRDC in its summary disposition motion, i.e.,
that the Staff has not made every reasonable effort to maintain radiation exposures "as low as reasonably achievable" (ALARA).
/ Contention 4 states:
The proposed action increases the exposure to radiation of workers and the general public beyond what is ALARA.
a.
ALARA can be achieved by on-site expansion of spent fuel storage capacity at Ocence, including building another spent fuel pool.
b.
The residual health risks which remain even if the present IIRC regulations on exposures to workers are met are major costs of the proposed action 'ahich tip the balance against the proposed action.
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NRDC argue: that Duke Power Cor any's trensshirn. cat pronnsel does not neet ALARA when conpared with specific alternatives; namely, reracking the Oconee spent fuel pool with either stainless steel racks or neutron-absorhing racks (poison racks) or construction of a separate spent fuel pool at Oconee.
II.
Sta f f Position Duke Power Company's proposal ocets the ALARA requiruents of 10 C.F.R. 20.l(c).l/
The IN!C Staf f's motion for su.. nary disposition of May 11, 1979 demonstrates that the proposed transshipment is ALAPA and that there is no material issue of fact for hearing on the matters reised by NRDC Contention 4.
III.
P,o n ul a to r y Criteria The Nuclear Regulatory Commission requires reasonable efforts to maintain radiation exposures fron licensed activities as low as reasonably achievable, ALARA.
Thus,10 C.F.R. 20.l(c) provides.
In accordance with recomnandations of the Federal Radiation Council, approved by the President, persons engaged in activities under licenses issued by the Nuclear Regulatory Commission pur:.uant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974 should, in addition to complying with the requirenents set forth in this part, make every reasonable ef fort to maintain radiation exposures, and releases of radioactive materials in effluents to unrcstricted areas, as low as is reasonably achievable.
The term "as low as is reasonably achievabie" means as low as is reasonably achievable taking into dCCount the state of technology, and the economics of improvcments in relation to benefits to the public health and safety, and other sccietal and socioeconomic considerations, and in relation to the i.tilization of atomic energy in the public interest.
_1/ The Staff adopts "NRC Staff's Motion for Sunmary Disposition of NRDC Contentions I, 2, 3, 4, and 5," (May 11, 1979) pp.
1-6, 22-32.
As part of its response in oppositic.n to NRDC's sunmary disposition motion of May 2,1979 with respect to Contention 4.
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. IV.
Discussion A.
Under the ALARA concept, reasonable efforts are required to be nade to reduce radiation exposures that already meet regulatory requirements to even lower levels. The Couission's ALARA requirement pursuant to 10 C.F.R. 20.l(c) is subjective or largely judgmental and not quantifiable, horthern States Po.cer Comoany_ (Prairie Island '!uclear Cenerating Plant, Units 1 and 2);
Vermont Yankee fiuclear Power Cornoration (Vermont Yankee fluclear Station),
ALAB-455, 7 I;RC 41, 51-59 (1978).
In Prairie Island, 'he Appeal Board reversed the Licensing Coard's finding that an alternative meth]d of rack disposal was warranted wheie an estimated 19 nan-rems would be saved but at a cost of
$50,000 - 560,000.
It undertock to specify guidelines based on its interpretation of what 10 C.F.R. s20.l(c) requires in a case who e the issue was moot since the Applicant had already taken the action imposed on it by the Licensing Coard.
Signi ficantly, the Appeal Cocrd s ta ted, inter alia :
Thus, whether a particular method of rack disposal meets the ALARA test does not hinge entirely upon the existence or non-existence of some alternative, feasible method which would occasion a lesser amount of radiation exposure. Assuming that (as here) such an alternative does exist but would be more expensive to implement, it must also be determined, inter alia, whether the health and safety benefits which nignt be occasioned by the exposure reduction are sufficient to warrant the additional monetary expenditure.
Preiric Island, ALAB-455, p. 56.
Accord, Conrnn.vealth Edison Co. (Dresded/ Quad Cities Trarnshipx.ent), t.emorandua and Order, Slip Op., p. 6 (April 24,1979) (proposed action is not ALARA if there are reasonable alternatives that can be taken to reduce emissions even further [ radiation exposure].1/
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_1/ There are ordinarily no" emissions" in the form of liquids or gases from a fuel cask during transshipment, although there is a very low level of radiation emanating from the cask.
Alchough the Licensing Board used the term " emissions," radiation exposure during transshipment of spent nuclear fuel in spent fuel casks is not normally thought of in terms of " emissions."
4 Thus, there are two general criteria to be applied before an alternative to a proposed action could be said to be ALARA:
(1) the alternative must take into account ways to reduce raditticn dose; (2) Efforts to reduce radiation dose must be reasonable.
B.
The proposed action to cransship Oconee spent fuel to licGuire is ALARA since the alternatives proposed by I;RCC in this case either would not reduce dose or would be inordinately r:cre expensive in any event.
1 The Staff's affidavits / show that the proposed transshipment action and the reracking options are indistinguishable from a radiation dose standpoint.
flehemias Affidavit, p. 4.
Transshipment is estimated to require a one tine expousre of approximately 46 man-rems and 9.3 nan-rens per year from operation of the McGuire spent fuel pool.
flehemies Affidavit, Table.
Reracking with stainless steel racks at Oconee results in a one time exposure of 76 man-rems and 18.6 man-rems per year to operate the pool.
flehemias Affidavit, Table.
Similarly, reracking
~
1/ The affidavit of Dr. John V. tiehemias dated May 24, 1979 attached to this response is submitted in lieu of the "Af fidavit o# Dr. John V. fichemias,"
(flay 10, 1979).
Dr. ilehemias' affidavit inadvertently failed to account for the 30 man-rem occupational dose exposure for the proposed transshipment action.
In addition, as was pointed out by Dr. itchemias at page 2 of his affidavit of May 10, 1979, at that time additional information on radiation dose estimates for reracking was being requested from Applicant.
That add'tional ir. formation has been obtained from the Applicant as part of the Sta f f's review of the Duke Power Company Oconee reracking application.
The core recent information is reflected in Dr. flehemias' most recent affidavit of 'iay P4,1979-9,,
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with poison raci.s requires a one time dose of a ran-rens and 10.6 ran-re;r per year to operate the spent fuel pool.
The figures for a new pool at Oconee are 30 nan-rems per year for handling fuel and 9.3 man-rems per ycar for pool operation.
There is no can-rem dos e from construction of a neu separate spcnt fuel pool.
A new pool at another site results in 30 man-rens per year for handling fuel,15.6 nan-rems per year to drivers of the cask trucks, and 9.3 man-rems per year for pool operatior.
The above estinates show that the radiation doses projected from the thrce actions considered would be in the sa,re general dosc range over a period of years. Tnerefore, there would be no t; asis for concluding that any of the three is clearly to be preferred from the point of view of radiatic. dose nor that any significant dose saving would be expected to result from the selection of any one of the three.
flehemias Affidavit, p. 4; hehemias Affidavit, Table Signi ficantly, the health ef fects from radiation exposure fron either the propascd transshipment or alternatives are negligibly snall and, therefore, insignificant (Staff Ibtion for Sunary Disposition of Iby 11,19/9, pp. 29-32).
Ali. hough ALAP.A involves a different concept than that involved in !! EPA considerations, the analogue applies that where radiation dose from an action is at least as low as suggested alternatives, there is no obligation to consider possible alternatives which are, en the basis of dose levels and dose effects, indistinguishable and which would be more expensive.
Portland General Electric Company, et al. (Trojan f!uclear Plant), ALAB-531, Slip Op., pp. 3, 5.
(March 21, 1979).
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'? ) 9 The diff erences in costs for the several alternatives su7;usted by IMC co:= pared to the proposed transshipment action are significant, ho.;ever.
The transshipnent action is estimated to cost $2500 per fuel asscably.
Estinates of costs for reracking with stainless steel racks range from $5500 per assembly to $330J per asseably; for poison racks from $3650 per assembly to $6612 per a'serbly.
Spitalny cnd Glenn Affidavit,fiay 25,1979 - Table.
Estimates of costs for construction of an independent fuel storage facility (ISFSI) constructed and o?erated on site by Applicant range from S10,000 per assembly to $34,500 per astembly.
For an ISFSI constructed and operated offsite by others the esticates rance from $27,500 to $37,000 pe~ assembly.
Significantly, the estimates for construct on and operation of an 19FSI to the extent that an ISFSI was considered as an aliarnative to the proposed transshipment to not include any estimates of environa.ntal costs.
Spitalny and Glenn Affidavit flay 25, 1979 Table.
In summary, the radiation dose to workers projected to result from either transshipment to the iscGuire Station or reracking the present spent fuel pool Lould not be expected to result in significantly lower radiation dose from the selection of either one.
Staff's Summary Disposition liot. ion of flay 11, 1979, pp. 23-24. 110 wever, the costs of reracKing are significantly greater.
The option of constructing an additional spent fuel pool at Oconee would still require transfer of the fuel to and from shippir.; casks, transshipment of the fuel affected (although the shipments would be minimal) and an occupational dose from operation.
The net effect would be e very mino: reduction in overall radiation dose to workers.
The savings in exposure would not justify the wbstantial qf
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[OV additional expense with respect to the option of constructing an additional spent fuel pool at Oconee.
I'chemias Af fidavit, Table; Staff Sumary Disposition Motion of l'.ay 11, p. 24; Spitalny and Gleen Af fidavit Table.
C.
As we pointed out in our motion for summary disposition of May li,1979,
!?RDC does not have a material factual basis for its contention.
Staf f Motion of May ll,1979, pp. 25-29; 30-32.
We would further point out that Dr.
Cochran's affidavit of May 1,1979 attached to f;RDC's May 2,1979 mischaracter-izes the Staff's response to fiRDC discovery requests.
Examination of the Staff's discovery responses, includ!ng the Staff's responses of April 17-18, 1979 to NRDC's Request for Admissions, shcws that the complaint is about the Staff's failure to answer questions that were not asked.
Conclusion flRDC's motion for summary disposition should be denied as well as its request for an order to delay this proceeding until an ALARA analysis is complettd.
The Staff's motion for summary disposition of May 11, 1979 and attached affidavits, together with this response and attached affidavits to flRDC's motion for sLmmary disposition of May 2,1979 with respect to Contention 4, show that the proposed transshipment action meets the Commission's as low as reascnably achievable guidelines, 10 C.F.R. 220.l(c).
Moreover, the Sta ff's motion fcr sum."ry disposition demonstrates that there is no material issue of fact on the matters raised by Contention 4.
Accordingly, the Licensing i
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-8 Board should deny liRDC's motion for sure,ary disposition with respect to Contention 4 and grant the Staff's request that Contention 4 tn dismissed ty summary disposition pursuant to 10 C.F.R. s2.749 since there is no material issue of fact that warrants a hearing.
Respectfully submitted,
.CN
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' (IC, ice. /-)s'LM t'/%U Edwrrd G. Ketchen Counsel for I;RC Staff Dated at Bethesda, Maryland this 29th day of May, 1979 q-
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UtilTED STTTES OF ATERICA I'UCLEAR REGULATORY COlrilSSION DEFOP.E TFiE ATOMIC SAFETY f *;D LICENSitiG BOARD In the flatter of
)
)
DUKE POWER C0:1PldlY
)
Docket No. 70-2623
)
(Amendment to I'aterials License
)
SNil-1773 for Oconee fluclear Station
)
Spent Fual Transportation and Storage )
at ficGuire liuclear Station)
)
CERTIFICATE OF SERVICE I hereby certify th copies of "NRC STT.FF RESPONSE IN OPPOSITION TO ' NATURAL RESOURCES DEFENSE C JNCIL l'.0 TION FOR SlR"1ARY DISPOSITION WITH RESPECT TO NRDC CONTENTION :4 ' (May 1, 1979)", dated May 29, 1979, in the above-captioned proceeding, have been served ca the folleaina, by deposit in the Unitea States rail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Comission's internal mail system, this 29th day of May, 1979:
- Marshall E. Miller, Chairman Ms. Brenda Best Atomic Safety and '.icensing Beard Carolina Action U.S. fluclear Reguiatory Comission 1740 E. Independence Blvd.
Washington, D. C.
20555 Char otte, North Carolina 28205 Dr. Cafet H. Hano, Jr., Director Anthony Z. Roisman, Esq.
Sodega Marine Laboratory Natural Resources Defense Council University of California 91/ - 15th Street, N.W.
P.O. Box 247 Washington, D. C.
20555 Bodega Bay, California 94323 Shelley 31um, Esq.
- Dr. Erc.meth A. Luebke 418 Law Building Atomic Safety and Licensing Board 730 East Trade Street U.S. fluclear Regulatory Commission Charlotte, florth Carolina 20202 Washington, D. C. 20a55 J. Michael McGarry, III, Esq.
W. L. Porter, Esq.
Debevoise & Liberman Associate General Counsel 1200 Seventeenth Street, N.W.
Legal Department Washington, D. C.
20036 Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 kbb 2bs
.
- Atomic Safe ty and Licensing Appeal Board Mr. Gr:o t ~re / Owen Little U.S.
!uclear Regulatory Ce.: mission P. O. Oc3 2501 tlashington, D.C.
20555 Davidsor College Davidsot, fl. C.
28036
- Ato:nic Safety and Li.ensing Board Panel U.S. fluclea, Regulatt ry Cor:aission 1!ashington, D. C.
20555 Docketing and Service Section U.S. iluclear Regulatory Co:::aission Washington, D. C.
20555 fir. Jesse L. Riley, President Carolina Environmental Study Group 854 Henley Place Charlotte, itorth Carolina 28207 Richard P !!il son, Esq.
Assistant Attorney General State of South Carolina 2G00 Bull Street Columbia, South Carolina 29201
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Ed'aard G. Ketchen Counsel for URC Staff
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UNITED STATES OF AMERICA I
MAT 31 NUCLEAR REGULATORY COMMISSION Ek g
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BEFORE THE ATOMIC SAFETY AND l.ICENSIt!G BOARD In the Matter of
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DUKE POWER COMPAt'Y
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(Amendment to Materials
)
Docket No. 70-2623 License SNM-1173 for Oconee
)
Nuclear Station Spent Fuel
)
Transportation and Storage
)
at McGuire Nuclear Station)
)
AFFIDAVIT OF DR. JOHN V. NtHEMIAS I, Dr. John V. Nehemias, being duly sworn, do depose and state:
1.
I am a Senior Health Physicist in tr
' vision of Site Safety and Environmental Analysis, U.S. Nuci Regul6 tory Commission (NRC).
2.
I have prepared a statement of professional qualifications which is attached to this affidavit.
3.
This affidavit addresses in part, Natural Resources Defence Council Contention 4(a).
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Contention 4(a):
ALARA can be achieved by on-site expansion of spent fuel pesi storage capacity at r ee, including build' 3 another spent fuel pool.
This contention addresses the fact that the proposed transshipment of Oconee spent nuclear fuel to McGuire Nuclear Station for storage will involve some radiation exposure to the public and to workers involved in the transshipmer,t.
Intervenor's point is that these radiation exposures could be entirely eliminated by simply expanding the spent fuel storaage capacity at Oconee, either by re-racking the present spent fuel pool to permit storage of a larger number of fuel elements, or by building another spent fuel pool at Oconee.
We understand that re-racking the present spent fuel pool at Oconee would provide only enough additional fuel storage capacity to accommodate about two years' supply of spent fuel. At or before that time, additional spent fuel storane capacity would be required, either by building another spent fuel pool at' Oconee, or by trans-shipping the spent fuel, utilizing available space at McGuire.
(a) Re-racking the present Oconee spent fuel pool Two prior fuel pool modificaticos have occurred involving underwater use of divers.
Total occupational radiation exposures were 18 man-rems at GINNA and less than 3 man-rems at Zion.
266 286
=
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Duke Power has estimated, we believe conservatively, that occupational doses during modification of the spent fuel
' pool at Oconee would be 76 man-rems.
Based on experience with similar modifications at other plants, we would expect that actual doses may be somewhat lower.
In addition, subsequeat operation of the pool would involve about 18.6 man-rems per year. Estimated doses would be about the same for re-racking the Oconee pool with poison racks.
The Applicant has taken appi apriate actions to assure that occupational radiation posures will be as low as is reasonably achievable, including:
. using the spent fuel pool cooling system filters and demineralizers to clean up pool water at their available capacity;
. transferring identified leaking spent fuel assemblies to the Unit 3 spent fuel pool;
. removing extraneous tools, components, and testing equip-ment from the pool or providing shielding;
. vacuuming the pool floor and other underwater surfaces likely to be contaminated with radioactive materials before work begins; o <>
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. using low exposure areas for waiting and travel paths to t he, extent feasible.
The Staff concludes that occupational radiation exposures resulting from the proposed spent fuel pool re-racking at Oconee will be ALARA.
(b) Transshipment of Oconee spent fuel to McGuire The radiation doses to public resulting from the transship-ment to McGuire are estimated in the Environmental Impac!
Appraisal to be 0.1 man-rem. This relatively minor portion of the total dose could be eliminated by construction of a new spent fuel pool at Oconee.
The principal radiation dose resulting from this trans-shipment, however, would be delivered to workers. Duke Power has estimated t'
' drivers would receive about 16.6 man-rems during 300 shipments. Occupational doses resulting from activities related to transfer of the spent fuel into a shipping cask, movement of the cask from the spent fuel pool to the new location, and transfer from the shipping cask to the new storage facility are estimated to be about 30 man-rems. Except for possible differences in the distances to be shipped, estimated doses would be about the 266 280
4 same for shipment to other undetermined sites.
In addition,
, subsequent. operation of the pool would involve about 9.3 man-rems per year.
The applicant has taken appropriate actions to assure that occupational radiation exposures will be as low as is reasonably achievable, including:
. retention at Oconee of any fuel element known to be leaking:
. storage of fuel for a minimum of 270 days at Oconee prior to shipment;
. routine treatment of pool water at Oconee by operation of fuel pool purification equipment, to reduce concentrations of radioactive materials in the water being transshipped.
The Staff concludes that occupational radiation exposures resulting from the proposed transshipment of Oconee spent fuel to McGuire will be ALARA.
(c) Construction of a new spent fuel pool at Oconee The actual activities involved in construction of a new spent fuel pool at Oconee would not involve any radiation exposure to the public, or to the personnel involved.
However, when the new spent fuel pool has been constrected, as in the case of transshipment to McGuire, f uel transfer 266 289
. L would stili be required. The spent fuel would have to be transferred, one fuel assembly at a time, from the existing spent fuel pool into a shipping cask, moved in the cask from the spent fuel pool to the new location, and transferred from the shipping cask to the new storage facility. These activities will involve radiation exposures to the personnel taking part in the transfers.
Duke Power has estimated the doses resulting from these activities to be about 30 man-rems per year.
In addition, subsequent operation of the pool would involve about 9.3 man-rems per year.
T'he total man-rem doses projected to result from the three actions being considered would be in the same general dose range over a period of years. Therefore, because of the inexact nature of the estimating process, there would be no basis for concluding that any of the three is clearly to be preferred from the point of view of radiation risk, nor that any significant dose saving would be expected to result from the selection of any one of the three.
See attached table.
We conclude that the exposures likely to result from the transshipment of Oconee spent fuel to McGuire or from re-racking the pool at Oconee, as described by the applicant, would be ALARA.
Each aspect of the proposed actions have been considered from the point of view of Ieeping radiation exposures ALARA, eliminating unnecessary exposures, and taking all reasonable precautions to reduce exposures. Simil a rly,
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9 if the applicant proposes in the future to construct a new spent fuel storage facility at Oconee, we will review any such application with regard to ALARA considerations.
While the NRC has not issued specific guidance related to ALARA considerations involved with fuel storage or transfer, we have issued Regulatory Guides 8.8, "Infonnation Relevant to Ensuring That Occu-pational Radiation Exposures at Nuclear Power Stations Will Be As Low As is Reasonably Achievable," and 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably
- c. ' -.
Achievable." These guides spell out our' ALARA philosophy and describe the ALARA approach to reduction of exposures.
These considerations have been applied in our rev:ew of the applicant's proposals ragarding spent fuel transfer and storage at Oconee and McGuire.
I hereby certify that the above statements are true and correct to the best of my knowledge and belief.
3 C. _
n V. Nehemias Subscribed and sworn to before me this) 9 day of May, 1979.
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,C Notary Public My commission expires b.. (
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266 29;
Projected Doses Based on Duke Power Estimates (per 300 fuel assemblies)
Alternative One-Time Doses Doses Per Year Thereafter Transshipment 30 man-rems (handling fuel) 9.3 man-rems /yr to McGuire 15.6 man-runs (driving)
(operating pool) 45.6 r
re-racking 76 man-rems (pool work) 18.6 man-rems /yr Oconee pool (operating pool)
C< '.
re-recking 76 man-rems (pool work) 18.6 man-rems /yr Oconta pool (operating pool)
(with poison racks)**
new pool at 30 man-rems (handling fuel) 9.3 man-rems /yr Oconec (operating pool) new poos at 30 man-rems (handling fuel) 9.3 man-rems /yr any other site 15.6 man-rems (drivers)*
(operating pool) 45.6 would depend upon distance to be travelled.
. ** would involve extensive time delays.
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UNITED STATES OF AMERICA fiUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
DUKE POWER COMPANY
)
Docket No. 70-2623
)
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(Amendment to Materials License
)
g SNM-1773 for Oconee Nuclear Station
)
Spent Fuel Transportation and Storage
)
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O3 316"N at McGuire Nuclear Station
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A AFFIDAVIT OF BRETT S. SPITALNY AND R. DANIEL GLENN t
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Our names are Bret Spitalny and R. Daniel Glenn. We have preparci statements of professional qua'.ifications which have been submitted previousif in the above-referenced docket.
E.
We have prepared the attached Table 1 from information available in the above referenced jocket.
We hereby certify that the above statements are true and correct to the best of my knowledge and belief.
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' ~ Brett T. Spitalny L
R. Daniel Glenn Subscribed and sworpday of /1f4/,1979.
to before me this,76[
Notary Public
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(/J My Commission expires:
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COMPARISON OF ALTERNATIVES Exposure (Man-rem)(9)
Cost Alternative _1 Per Assy Total Per Assy Total Transshipment (300 Assys)
Handling 0.l(b) 30 Applicant Drivers (2)
.052 15.6 PuH ic
.0003
.1 45.7 2461 738,000 Handling 0.24 72 Staff (a)
Drivers (2)~
.0003 y
.1 2500 750,000
.053 16 Public 88.1 Alternative 2 Rerack (high density stainless steel-750-336=414 additional spaces)
Handling
.18 76 Applicant Drivers (c)
Public (c) 76 8300 2,490,000 Staff Handling
.05 20(d)
Jrivers (c)
Public (c) 5500 1,650,000 20 Alternative 3(*
Rerack [ Poison Racks - (1239-336 =
953 additional spaces)]
assuming no prior rerack Handling (racks)
.08 76 4000 3,812,000 Applicant (trans)
.1 24.8 640(h) 610.000 Drivers (trans)
.052 12.9 fublic (trans)
.0003
.07 lT3 T 4640
~ GUF Handling (racks)
.02 20(d) 3000 2,859,000 Staff (trans)
.24 59.5 650 620,000 Dris rs (trans)
.053 13.1 Public (trans)
.0003
.07 SP.7 3 tabu 3,479,000 9-539 8
additional spaces] assuming prior reracking with stain-
,[ g, h q r. -.(; / 't less steel racks Handling (poison racks) 08 76 4000 3,812,000 Applicant (stainless steel racks) 08 76 2612 2,490,000 Drivers (c)
Public (c) 1T2~-
EST2-6,302,000 -
5taff Handling (poison racks) 02 20(d) 3000 2,859,000 (stainless steel racks) 92 20(d) 1730 1,650,000 Drivers (t)
Public (c) 40 4730 4,509,000
COMPARISON OF ALTER!!ATIVES' Exposure (Man-rem)(9)
Cost Per Assy Total Per Assy Total Alternative S Independent spent fuel storage installation - onsite (1500 assemblies)
Handling 0.1 30(I)
Applicant Drivers negligible Public 0
,y __
30 34,500 51,750,000
.L4 72 Handling Staff Drivers negligible 0
Public 72 25,000 37,500,000 Alernative6 Inde; endent spent fuel storage ins tallation - offsi+e (1500 assemblies)
Ha ndling 0.1 30ff) 34,500 51,750,000 Applicant Drivers
.052 15.6 2,461 733,000 Public
.0003
.1 45.7 35,961 52,458,000 Handling 0.24 72.0 25,000 37,500,000 Staff Drivers
.053 16.0 2,500 750,000 Public
.0003
.1 88 '
-27,500 38,250,000 (a) Staff estimates are based on comparable experience and do not necassarily reflect conditions within the Duke system.
(b) Applicant's original estimate of 0.4 man-rem / shipment was lowered bare? un averages of 2 years o' Nel handling experience.
(c) Driver and public estimates are not provided for trie disposition of the racks.
T (d) Staf f estimate 40 - 50 man-rem for Duke Power r ? racking.
(e) Transshipment is required to accommodate workint space (248 assemblies).
(f) For com;.arison purposes, doses are for the movement of 300 assemblies.
(g) Radiation dose as a result of pool operation has not been included.
(h) Costs for transshipment are averaged cver total additional spaces gained.
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NEC PURIC DOCUMENT R0W UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
DUKE POWER COMPANY
)
Docket No. 70-2623 (Amendment to Materials License
)
g SNM-1773 -for Oconee Nuclear Station
)
Spent Fuel Transportation and Storage
)
cgy22 9
at McGuire Nuclear Station
)
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AFFIDAVIT OF BRETT S. SPITALNY ff AND R. DANIEL GLENN t
1.
Our names are Brett S. Spitalny and R. Daniel Glenn. We nave prepared statements of professional qualifications whict. have been submitted previously' in the above-referenced docket.
2.
We have prepared the attached Table 1 from information available in the above-referenced docket.
We hereby certify that the above statements are true and correct to
~
the best of my knowledge and belief.
%dtt S SpW I
e Brett'3. Spitalny
_d R. Daniel Glenn Subscribed and sworpday of to t
before me this46 T
/ f Af
,1979.
A.,
" ' Notary Public My Commission expires; f /dd, 2[3[j 2,, b
t' t
I CC"P ARISCN OF ALTEP" ATIVES l
Exoosure (fdan-rem) (9)
Cost t
J Alternative 1 Per Assy Total Per Assy Total 1
f Iransshi; - t (300 Assys) 0.l(b) 30
'maling l
Applicant Drivers (2)
.C52 15.6 Public
.0003
.1 l
45.7 2361 733,000 Handling 0.24 72 Staff (a)
Crivers (2)-
.0003
.1 2500 750,000
.053 16 Public
~
83.1 Alternative 2 Rerack (high density stainless steel-750-336=414 additicnal spaces)
Pandling
.18 76 Applicant Drivers (c)
Public (c) 76 8300 2,490, COL Staff Pandlir;
.C5 20(d)
Crivers (c)
Public (c) 20 5500 1,550,000 Alternative 3(*}
Rerack [ Poison Rscks - (1239-336 =
953 additicnal spaces)]
assuming no price rerack Handling (racks)
.C8 76 4000 3,812,000 Applicant (trans) 1 24.8 640(h) 610.000 Drivers (trans)
.052 12.9 Public (trans)
.0003
.07
~
113 3 4540 4,422,CC0 Pandling (racks)
.02 20(d) 3000 2,859,000 Staff (trans)
.24 59.5 650 620,C00 Drivers (trans)
.C53 13.1 Public (trans)
_CCO3
.07 92.7 2 00 3,479,000 a a Alta-ativ b hh
'" f I
j'(Lg i b{g h
7.,j j y g4 p
y
- erack [Niscn racks d;..,
g 5: Qk NN t f. p (1239 - 750 = 539 h
h
,g i
add ti nal scac2s] assuning
- rier reracking with stain-less steel racks Handling
(;;oiscn racks)
.C3 76 4000 3,812,000 y
4:ali: ant
' stainless steel racks)
C3 76 2512 2,DO,000 Crivers (c)
(c)
Public 132 co d e,302,.00 Sta'f Paneling 20(d) 3000 2,E59,000 (coisen racks) 02 (stainless steel 20(d) 1730 1,550,0C0 racks)
-02 Crivers (c)
Public (c) 40
,47,30 q
,-),5C3.w00
,) D D l' N '
t L
4 1
d v
CCMPARISON OF JLTER.*:ATIVES i
Exposure (!'an-rem)(9)
Cost Per Assy Total Per Assy Total Alternative $
Indenendent spent fuel storage installation - onsite (1500 assemblies)
Handling
- 0. l_
30(I)
Applicant Drivers negligible Public 0
30 34,500 51,7 50,ff.00 Handling
.24 72 Staff Drivers negligible Public 0
72 25,000 37,500,0C0 Alternati.e_6, Independent spent fuel storage installatien - offsite (1500 assem.blies)
Handling 0.1 30ff) 34,500 51,750,000 Applicant Crivers
.052 15'6 2,461 733,000 Public
.0003
.1 45.7 36,961 52,488,000 Handling 0.24 72.0 25,000 37,500,000 Staff Crivers
.053 16.0 2,500 750,000 Public
.0003
.1 88 1 27,500 38,250,000 (a) Staff estimates are based on comparable experience and do not necessarily reflect conditions within the Cike system.
(b) A;plicant's original astimate of 0.4 man-rem / shipment was lowered based on averages of 2 years of fuel handling experience.
(c) Oriver and ;ublic estimates are not provided for the disposition of the racks.
1 (d) Staff estimate 40 - 50 man-ren fcr Duke Pcwer rerack.ng.
(e) Transshf ement is r?quir9d ta acccmedate werking space (243 asseclies).
(f) For cmpariscn pur;cses, doses are for the mcvement of 300 assemblies.
(g) Radiation dose as a result of pcol operatial has not been included.
I I
(hi uJsts for transshipment 3re tveraged cver total additicnal spaces gained.
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J O w,a u d L au G Uu~c,e J N i
266 298
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