ML19224D227
| ML19224D227 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 05/31/1979 |
| From: | Roisman A National Resources Defense Council |
| To: | |
| Shared Package | |
| ML19224D217 | List: |
| References | |
| NUDOCS 7907110134 | |
| Download: ML19224D227 (56) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of
)
)
DUKE POWER COMPANY
)Dkt. No. 70-2623
)
(Amendment to Operating License SNM-1773 )
for Oconee Spent Fuel Transportation and )
Storage at McGuire Nuclear Station)
)
NATURAL RESCURCES DEFENSE COUNCIL MOTION PURSUANT TO 10 CFR S 2.720 (h)
The attached discovery request is addressed to specific Staff evidence the answers to which can only come from the Staff.
Therefore we request that the Staff be required to answer the discovery request.
Respectfully submitted,
/??AfI - l C.~~ %
O i
Z. fRoisman Anthony / esources Defense Council Natural R 917 15th Street, N.N.
Washington, D.C.
20005 (202)737-5000 Dated:
May 31, 1979 n'
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5) 7907110[ W C
's UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of
)
}
DUKE POWER COMPANY
)Dkt. No. 70-2623
)
(Amendment to Operating License SNM-1773
)
for Oconee Spent Fuel Transportation and
)
Storage at McGuire Nuclear Station)
)
CERTIFICATE OF SERVICE I hereby certify that copies of NRDC DISCOVERY REQUEST TO THE REGULATORY STAFF, MOTION PURSUANT TO 10 CFR S 2. 72 0 (h),
and attached copies of Staff AFFIDAVITS were mailed today, May 31, 1979, postage prepaid, first class mail, to the persons on the attached service list.
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4 Anthony Z.
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Marshall E.
Millar, Chairman Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Cadet H.
- Hand, Jr.,
Director Bodega Marine Laboratory Post Office Box 247 Bodega Bay, California 94923 Dr. Emmeth A.
Luebke Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 James Michael McGarry, III, Esq.
Joseph B.
- Knotts, Jr.,
Esq.
Debevoise & Liberman 1200 17th Street, N.W, Washington, D.C.
20036 Richard K.
Hoefling, Esq.
Office of Executive Legal Director U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 rg
'h Secretary of the Commission CD U.S. Nuclear Regulatory Commission Washington, D.C.
20555 e '
q Attention:
Docketing and Service Section g
o Donald R.
Belk Safe Energy Alliance 4937 Lebanon Drive Charlotte, N.C.
28210 Richard P. Wilson Assistant Attorney General 2600 Bull Street Brenda Best Columbia, South Carolina 29201 Carolina Action 305 East Chapel Hill Street Shelley Blum, Esq.
Durham, North Carolina 27702 418 Law Building 730 East Trade Street Chuck Gaddy Charlotte, North Carolina 28202 NC PIRG Davidson Collece Jesse L.
Riley Davidson, North Carolina 23036 Carolina Environmental Study Grou; 854 Henley Place William Larry Porter C"h a ' o "" ~ e :
N*C*
- 8207 7
Associate General Counsel Duke Power Company 422 S.
Church Street Charlotte, N.C.
28242
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION SEFORE THE ATCHIC SAFETY AND LICENSING SCARD In the Matter of
)
}
DUKE POWER COMPANY (Amendment to "aterials License
)
SNM-1773 for Oconee Nuclear Station
)
Spent Fuel Transportation and Storage at "cGuire Nuclear Station Affidavit of Brett S. Spitalny and Jahr P. Roberts i,
Our names are Brett S. Spitalny and John P. Roberts. We have prepared statements of professicnal qualifications which are attached to this affidavit.
2.
This affidavit addresses Natural Resources Cefense Ccuncil (NRDC)
Contentien 1 which reads as follows:
1.
The proposed action is a step in the prcoosed arcgram to handle the shortage of spent fuel storage space by shicping and storing scent fuel away frcm the reactcr where it was generated.
The croposed action has no independent value in solving the scent fuel storage prcblem and is innerently premised on the near-term construction of an interim away frcn-re:ctor storage facility.
The proposed action, if taken, will bias the
- inal cecisicn on whether to approve the program by foreclosing at-reactors cations at both Occree and McGuire.
The orcoosed ac-ico is therefore inconsistent witn the conditions I and 2 laid dcwn by the NRC in prcmul-gating the criteria for acproval of interim spent fuel s:Orage.
(a0 Fec. ?eg. a2301).
Thus, the proposed action cannot be acted ucen until ccnoletion of impac: statements on the crocosee pecgran r.cw being cceducted by DCE (Storage of U.S. Spent ?ower Reactor Fuel (CCE/EIS-0015-0)
August 1973, and Sue?lement, Cecember 1978; Storage of Foreign Spent Power Peactor Fuel (00E/EIS-C040-D) December 1978; Preliminary Estinates of the Charge for Spent ;uel Storage and Disposai Services (COE/ET-0055) July 1975; Charge for Spent Fuel Storage (COE/EIS-CCal-D) December 1973; and NRC (Craft Generic Envir:nmental Imcact Statement on Handling and Storage of Spent Lignt Water Power Reactcr Fuel (NUREG-CaCa)).
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W In addretsing this centention, cur response does nct include consideration of the pi posed program (identified as a 00E initiative)
Cited in the contention, or any national policy which may or may not be develooeJ by the Federal Government.
Our response rather follows the deci:icn of the Ccr. mission that licensing actions such as the pecposed be. considered on a case by case basis on their individual merits.
[ Spent Fuel Storage, Intent to Prepare Statement sn Handling and Storage of Spent Light Water Pcwer Reacter Fuel, (40 Fed. Reg. 42501, Septer.t:er 16, 1975) (Ccmmission Statement)] We adcot as part of the basis for our affidavit the analysis contained in the Fnvironmental Imcact Acpraisal (EIA) (December 1973).
Proccading on this basis we examined whether the action considered has independent utility pursuant to Factor 1 of the Cocaission Statement.
The Cc r.ission's state. ment of Factor 1 is.
"It is likely tnat each individual licensing action of this ty::e would nave a utility tnat is independent of the utility of other licensing actions of this type.'
Of the three reactors at the Ccenee ':uclear Station, Units 1 and 2 are presently going to an 13 month fuel cycle, ahile Unit 3 will remain on an annual cycle.
Units 1 and 2 will be discnar ing fuel assemblies at the rate of 72 every 18 months; and Unit 3 at the rate of 55 assemblies every 12 months.
The amcunt of space presently remaining in the reactor basins at Cconee aill crovide storage for 209 assemblies.
Post irradiation examination (PIE) e;ui; cent and piping is installed in the Ocoree 1 and 2 basin Q',??
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. occucying the equivalent of 51 assemblies of this available space.
Therefore, after the Oconee 3 discharge in May 1979, the facility will operate with 158 readily available spaces. A full core lead at each of the Oconee Units is equal to 177 assemblies.
If for scme reason, conditions dictated an unplanned core off-load, the " PIE" equipment could be remcVed to accommcdate the discharge.
This cotion, however, will be eliminated at the time of the next scheduled discharge in November, 1979.
At the conclusion of that refueling, only lal locations will exist, including those presently allocated for the " PIE" ecuipment.
The transfer of 300 assemblies as proposed in this licensing action would alleviate the immediate shortfall of storage capacity at
{hisactionrecuiresnootheractiononthepartof-heapplicant Cconee.
either price to cr subsecuent to transfer of the Cconee spent fuel to s Orage at McGuire to ensure its utility,. nce do other licensing acclications need to ce made to ensure such utility.
This 3cticn would arovice 2-1/3 years of continued operation of the plants, and subsecuent continued electrical acwer generaticn.
Thus, this action, stand alcne, has an indecendent utility regardless of any other actions of this tyce that the acplicant may or may not pursue to provide additi:nal future alleviation of stcrace capacity shortf all.
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This contention continues to suggest that this action is inconsistent with the Cc nission's second factor.
That fact:r reads:
~,3 0 85) 33i
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-4 "It is not likely that the taking of any particular licensing action of this type during the time frame under consideration would constitute a ccr.mitment of resources that would tend to significantly foreclose the alternativ:2 available with respect to any other individual licensing action of this type."
With respect to the proposed licensing action, we have considered ccmmitment of both material and nornaterial rescurces, and cur analysis is based on the fact that imoacts frca the orcoosed action are negligibly small, and, therefore insianifican_t (.EIA, p. 59).
The material resources considered are those to be utilized to ship Oconee spent fuel to McGuire.
The nonmaterial resources are primarily the labor and talent needed to accccolish the pecposed action and the available stcrage caoacity which exists in the McGuire Unit I basin.
$ince the spent fuel storage cacacity of the Duke system provides for sufficient total capacity to the mid-1990's, there does not accear a Octential for impact cn the capacity to provide for
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s to ra ge o f cluj m eren _luel frba t h a_ckicn.
Additicnally, a suitacle
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scent fuel cask is available to tne applicant.
Hence, these resources were considered to be ncnmaterial in nature.
The cnly censumable material resource would be that of the diesel fuel used during the 340 mile round trip for each spent fuel assemoly.
Use of the amount af diesel fuel is really incensequential when considering the proposed action or any other action to alleviate the spent fuel storage problem.
The proposed action in simple terms is movement of spent fuel ar.c storage in available scace.
Thus, it dces not involve ccrmitment of rescurces such as men and materials, and use of space and envircrmental resources (air, g
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. aquatic, and terrestrial resources); expensive equipment modifications; or construction and operation of fixed based facilities as do other suggested options. Thus, the proposed action is unique in the physical sense in that it would ccmmit lit 'ie, if any, material resources to a commitment that cannot be revtrsed.
The Oconee spent fuel can always jle moved it a later time frc the available McGuire scace if such a Aecision recuires it.__
Accordingly, based on cur consideration of these factors, the proposed transshipment action does not ccnstitute a commitment of resources that would tend to significantly foreclose other actions to ameliorate Duke pcwer Ocmcany's spent fuel storage space shortage at the Oconee facility.
The staff has concluded in the Evironmental Impact Appraissl that this action has no significant 'mpact on the quality of the human environment.
In conclusion, the implementation of this action does not foreclose the applicant frca installing additicnal storage cacacity at Oconee, wnich on February 2,1979, Duke acclied for, nor dces this action fereclose Duke fren other alternative actions involvinc transfer of either the spent 'uel involved in this action or other Oconee spent nr1' f11 OJ
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. fuel to additional storage capacity as it may beccme available at Cconee or elsewhere.
Consequently, we conclude that this action is in accordance wit? the Comission's second factor Although this contertion raises questions concerning only factc s 1 and 2 of the Comissica's notice (40 FR 22301), the Commission requires the staff to consider all five factors in examining license actions of this type.
The Staf#'s Envirornental Impact Acpraisal (EIA) addresses all of the five facters.
The Staff has applied, balanced, and weighed all of these factors (EIA pp 61-6J) and has determined that the arcpcsed license amencment will not significan:ly affect the quality of the % man environment and : hat tnere will be no significant environmental incact attri'utable to the prcoosed action.
c As a result of this consideration of the five fact:rs and this determination, the Staff has concluded tha: this is an appropriate action and shculd be allcwed to precead.
I here:y certify that the above sta:e.ents are true and correct to the best of my '<nowledge and belief
?M S. S d;f<~A,.
Srett S. SpitaSny W
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3 Subscribed and see m to before me this // 7"# day of May, 1979
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m UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION cr
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s In the Matter c'
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i DUKE POWER COMPANY f
(knenement to Materials License
)
SNM-1773 for Oconee Nuclear Station
)
Spent Fuel Transoortation and Storage
)
at McGuire Nuclear Station)
)
Affidavit of Brett S. Spitainy I, Brett S. Spitainy, being duly sworn to depose and state:
1.
I am the Proj ect Manager for the McGuire/Cconee spent fuel transpcrtation and storage proposal, Office of Nuclear Material Safety and Safeguards.
2.
! have precared a statement of professional cualifications wnich is attached to this affidavit.
3.
This afficavi: acdresses.*atural Rescurces Defense Council (NROC)
Centention 2 which reads as follows:
The prcocsed action is a major federal action significantly af fecting :he cuality of tne human ervironment and cannot be actec ucon uncil precaration of a final environmental imcact statement.
The contention suggests that the staf shculd have prepared an Envircr.Tental Impact Statement in lieu of an Environmental Impact p craisai p
(EIA).
The natural Resources Defense Council (1RCC) bases for this state-Ten; is that tha proccsed action is a major feceral action significantly affecting the quality of the human environment.
The centention does nct
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4
- suggest, however, tnose areas of concern in wnich the EIA fails short of its intent, f.e., of evaluating the proposed action to allow a determina-t.~on to be made with respect to significant impacts, if any, of the propored action.
Resolutien of NRDC contention 2, therefore, is necessarily decendent directly on the resolution of NROC contentions 3, 4, 5 and 5. (See NRCC response of April 15, 1979, P. 14, to apclicant's interrogatory No. 51 of March 23,1979. ) My affidavit and the affidavits of R. Daniel Glenn, Dr. M. Parsont, Dr. J Nehemias and T. Jerrell Carter as well as the Envircnmental :.cact Appraisal (EIA) (Cecemcer,1973) show that (1) the environmental impacts are negligibly small, anc, therefore insignificant, and (2)
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'ra nc nea#orrad alter-atives to the acclicant's recuest to chip Cconee scent fuel to McGuire for storage if alternatives to the precosed action are evaluated.
I adcat the material set forth in the EIA pertinent to the NROC contentions 3, 4, 5 and $* as part of my testimcny and affidavit in this case.
Alt,hcugh Duke Fewer Ccmcany has applied for an amendment t0 modji ~/
j the Oconee scent ~
uel cacacity by rerackinc, ccification of thq_gxisting Ocenee spent fue! pccis to provide additional storage cacacity is less preferred on an econcgic basis..icdification of the Oconee pool is rcughly ccccaracle to the recuest to transship Ccenee fuel to McGuire
" The moticn for smeary dis;csition is not being scught with rescect to contention 5.
Curther exolanation will ce supplied at the acconing hearing, reaffirming the staff's conclusion in the EIA that relatec impacts are not significant.
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< iE th respect to ncrmal radiation exposure, although neither activity has other thLn a negligibly small environmental inpact including the impacts of radiation dose.
Transshipment and s crage of Oconee fuel at.v Guire c
has negligible or no measureable environmental imoacts, and certainly no significant envirarmentil impacts.
As the NRC Proje:: Manager of this licensing action, I have directed and tat en part in the oreparation of the Envirornental Impact Appraisal (EIA) in support of the staff's negative declaration (43 FR 51057).
The staff's EIA has considered all fac'.s that are material to this issue anc concludes tr.ere are no s_ignificant moacj_s from the pr:cosed action.
I have prepared testimony with respect to NRCC Contention 3, alter".a-ives and CESG Contention 1, alternatives.
My affidavits, thcse of other sta#f affiants which I have exami.iedT ani the E:A clearly demon-strate that the Dr:cosed acticn will result in negligibly small and, trerefore, insignificant impacts with rescect to air, acuatic, and terrestrial environs.
Impacts fecm cc upational exposur? and the dose to the gener21 public are negligibly small and tnerefcre, insignifican:
The a f fi d av i t s o f "e s s rs. Hodge, Gl enn a r.d La k e :cnfi rm tha t t he burd e n o f r a_d i.a._;_i o_n_
dose as a result of routine and ncn-routine c; era:1cns (CESG anc CA Contentien 2) are also negligioly small, and, therefore, insignificart.
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_4-In addition, the Natural Rescur:es Defense Council (j ROC) in its re:ponse to discovery requests of the staff and of the applicant, has failed to point cut substantively where the Environmental Impact Appraisal (EIA) is in error, or if those impacts noted in the EIA are other : nan negligibly small, and, therefore, insignificant.
Based on my analysis, which has considered the EIA and the evidence offered in evaluation of the factrs described in NRDC Conter.;';ns 3, 1, 5 and 6, I have determined with respect to NROC Contention 2 that the environ-men:al impacts from the proposed action will be insignificant and, therefore, constitutes an insignificant effect en the quality of the human environment.
I herecy certify that the abose s:atements are true and accurate to the ces; of my belief.
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r Bret: S. Soitalny Subscribed and swcrn to before,e this //-d day of "ay, 1979 a
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-s UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION BEFORE THE ATOMIC SAFET7 AND LICEN3ING SOARD In the Matter of
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)
DUKE POWER COMPANY
)
)
Docket No. 70-2523 (Amendment to 'Mterials License
)
SNM-1773 for Cconee Nuclear Station
)
Spen Fuel Trans:crtation and Storage
)
at McGuire Nuclear Station)
)
AFFICA'/IT OF SRETT 5. SP!TALNY AND R. DANIEL GLENN This affidavit addresses Natural Resources Cefense Council (NR:C)
Contention 3c and 3d whicn read as folicws:
NRDC 3.
Tha folicwing alternatives 0 the procosed action have not been acecuately considered:
c.
There are no technological or ecencmic disadvantaces to expanding scen: fuel pcol capacity at Oconee if it is assumed that all Cconee s;en: fuel will be stored there until it is shipped to a legally a roved permanent stcrace facility for nuclear wastes.
This cotion will reduce the risks of routine, accicental and intentional (sacc: age) releases of radicactivity during transportation.
d.
Apolicant has not fully utilized all of the potential it has to compact scent fuel in existing pools at Oconee and has not provided adecuate justification for ne assertion that s:crace expansion at Cconee Unit 1 and 2 is not viable.
The centention suggests that the storage of spent fuel at the Oconee site shculd be retained at that site until such time that it may be shi; ped to a " legally accrcved permanent storage facility O
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for nuclear wastes." The Natural Resources Defense Council (NROC) has defined the solution to the spent fuel storage problem as; having storage space sufficient to receive all spent fuel to be generated by the reactor (in this case Oconee) between now and when the spent fuel can be disposed of in a permanent repository."
NRCC Continued -
"The earliest date for such a rect;4 tory is, in our judgement, not until the mid to late 1990's."
(See NRDC response to staff's interrogatory 13-3 dated April 11,1973.)
For the purpose of this contention, the staff has assumed that a legally accroved cermanent storage facility for nucle t e was}_es will not be available until 1995.
The contencion has clearly drawn a connection between the interim stcrage of spent fuel, and its final disposition.
The Commission, on tne other hand, in its statement of July 5,1977 (22 FR 34391 }-in-resconse to a Natural Resources Cefense Council (NRCC) petition for rule making stated:
There is, ne believe, a clear distinction between permanent disposal of wastes and their interim storage.
The Commission must be assured that wastes generated by licensed pcwer reactors can be safely handled and stored as they are generated."
Consideration of MRCC's preposal te enable the Oconee facility to store spent fuel until 1995 would require specific events to take place.
NRCC has procosed that Duke modify tne Oconee spent fuel pcols with neutron absorbing Taterials to allow for the hign density ccmpaction of eD
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. spent fuel assemblies (poison racks). (See NRDC April 11, 1979 response to staff's interrogatory No. 3-E dated March 23,1979) This action would provide ample time to construct an additional pool or Independent Spent Fuel Storage Installation (ISFSI) on the Oconee site.
To provide the applicant with ample time to rerack, NRCC has proposed imposing a license condition on the applicant.
This condition would require Oconee to use a portion or all of their full core reserve (FCR) which is presently being maintained at the facility by Duke Power Ccmpany as a management operating perogative. The Commission does not require utilities to maintain an FCR, although the NRC staff favors this practice (see the related affidavit of T. Jerrell Carter, and discussion below),
The plan presented by NRCC is viable.
Additionally, it is indeed technologically ar.c} _econcaically feasible.
Looking at the options suggested by NRDC a little closer, hcwever, reveals a few details which shcuid not be overicoked.
There are prosently six vendors Of neutron absorbing (?oison) racks with a rarmal lead time ranging from eign to twelve acnths (fro.7 the t[me of contractual agreement is made). I,hecostoftheseracksalsovary although experience has indicated that they average frcm 520C0 to $3000
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per assembly (1972 dolly:s). ILnese costs do not reflect the costs necessary
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for mcoifications to the cooling system which would also Oe required.
This cost is in addition to the cost which has already been expended by
9 Duke for the acquisition of high density stainless steel racks.
These stainless steel racks contracted through Combustion Engineering have already been designed, analyzed and are presently being delivered +c the Occne d tL_
Assumino, that Duke cursues_ the accuisition of poison racks, the poison racks would not be received at the Oconee site in time to rEtw for installation prior to loss of Oconee's full core reserve. (Sem @plicant response dated March 27, 1979 to NRDC interrogatory 10, dated Man s 8,1979. )
_In addition, with the cools full or nearly full, fuel would ha'oe 03 be shioped offsite to cravide enouch room for workers to install :heser racks.
Aside from the oroblem of ample working space, the procosed zsa of the FCR warrants careful consideration.
The staff's ceneral policy ;nsition with respect to the maintenance of a full core reserve is addressad in the affidavit of T. Jerrell Carter, Jr. (NRCC Contention 5).
The asscciaced costs of the loss of an FCR should additionally be addressed.
The extended shutdcwn of a reactor as a result of the need to unload a core, in terms of lost electrical cutput is extremely costly.
Egperience has shcws. tha* :F,uttinq dCwa_3 olant for even one day is less desirable than cursuing other alternatives.
This presu poses that (1) another alterna-tive exists, and (2) the envircnmental impacts are not significant and do no'. ;ose any uncue risk to the health and safety of the public. (See E'A Table 10-1, P. 58 and T. Jerrell Carter affidavit.)
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5-Actual costs incurred resulting from shutdown have been recently extimated by the applicant to range from $165,000 to $250,000 per day for one Oconee unit.
(See apolicant's response dated March 27, 1979 to NRDC interrogatory No. 11, dated March 8, 1979.
Experience has shown that this estirate is on the low end of the scale which ranges upward to aforoximately $500,000 per day.
Apolicants, as stated in the Commission's Standard Review Plan (NUREG 75/0871 are to provide their design basis for the capacity of their spent fuel pools prior to the construction of their facilities.
As discussed in the staff's testimony for NRCC Contention 5, (T. Jerrell Carter affidavit), the standard design ohi'osophy nas been to design a cool capable of holding the amount of fuel ecuivalent to the numcer of spent fuel assemblies unloaded from the core, during the re'ueling cycle, plus the fuel contained in a full core load, (e.g.,1-1/3 core for a single unit plant and 1-2/3 core for a dual unit facility).
The Oconee station consists of 3 reactors.
Two reactors share one pool and the third reactor has a separate pcol.
The shared pool has an original capacity slightly greater than 12/3 cores and the single unit pool nad a capacity slightly less 1 1/3 cores.
(See Cuke power Company application to rerack Oconee 1 and 2 pool dated ebruary 2,1979.)
The design of the Ocenee pools has been addressed in the Final Safety Analysis Report for Oconee Nuclear Stations 1, 2 and 3.
The design basis has already been approved and the Oconee hearings have oeen conc'.uded.
I~e 62
. A positive cost-benefit analysis has been shown providing a need for the electrical production of the facility.
Thus, these factors a.re taken as a given in my analysis.
On four sece-ate occasions, the Occnee units nave excerienced unplanned full core off-loads. Althouch future full core discharges are not anticipated, the cccurrence cannot be, precluded.-- There is only one full
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core reserve maintained at the Oconee facility althougn Oconee has three units.
In conclusicn, jeocardizing the full core reserve, and subsecuently the aceration of the Oconee units is not war-anted if other alternatives exist in which One environmental imoacts are of equal or less magnitude.
Again overlooking the above describec considerations and continuing assuming that Ouke is able to acquire and install poison racks, the Oc0 nee facility wculd be able to handle routine spen: fuel discharges until 1987.
Curing tne interim, until 1987, Duke wculd necessarily have to obtain additional storage scace by construction of an additi:nal ocol or indecen-dent storage facility of sufficient s1:e on the Oconee site or at same other site.
This secarate sr.orage facility would allos Oconee to have sufficient storage cacacity through 19Cj.
At that time the permanenE storage facility is assumed to be available.
The construction of a new acci cc i de:endent storage facili:y ust l_
be handled as a secarate licensing action, and as crevicusly acdresied :y e
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t.he sta f f's E: A i s cas tl y.
Moreover, tre envir0cment31 imcacts to the air, c.
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. aquatic and terrestrial environment _resulting from construction of such
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,a facility are assumed to be of greater significance although an assess ent
_of such impacts from an ISFSI was not recuired for qurposes of the analysis in this case. -
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Recent studies by utilities and confirmed by the COE have indicated
,that costs for constructino a facility of this type range upward to approxi-mately $30,000_ cer assemoly. S.uch an expense does not seem to warrant-.-
consideration, in lish.t_of the expen_s_e_already incurred by _Cuk.e_enlar_ gins i_ts pools at other facilities.
In response to interrogatories from the applicant, NRDC has quoted portions of the COE report on " Preliminary Estimates of the Charge for Spent Fuel Stcrage and Disposal Services," CCE/ET-0055 which states:
"There is considerable 00E interest in minimizing AFR storage recuirements and shipments by encouraging the use of at-reactor storage by further densification and/or expansion.
It is assumed that there would be economic and other advantages :o the utilities of keeping tneir scent fuel at their own reactor sites rather tnan shipping it to interim AFR s torage basins. "
NRCC has failed to include the preceeding paragraph on page 3 which states:
"Many utilities are e xpanding their storage basin capacities through reracking for compactness.
Others are transferring fuel from one basin to another within their own system.
New nuclear :cwer plants are being built with larger and more comcact basins. While increased storage basin capacities will provide relief for a number of nuclear power plants, some plants still face the pros:ect of inadequate basin capacity for annual fuel discharge.
If this hapcens, the reactors must shut down."
)
The referenced document does not state the COE is encouraging only the use of at-reactor storage of spent fuel generated at that reactor, but rather that the utility keep control of spent fuel within its system through the use of the storage capabilities of the entire system.
DOE indicates this would include among other things, transshipment of spent fuel from one basin to another within a utili ty 's cwn sys tem.
COE is encouraging the utilities to consider the use of Federally sponsored AFR's only after all available storage space within the utility has been utilized.
The acolicant may be able to solve their spent fuel storage problem by increasing the onsite storage capacity at all of its reactor facilities in what it ter s a cost effective manner Their action presently includes
_ the use of non-poison high density storage racks in all spent fuel storage basins ane:her at reactors n:w in use, under construction, or planned.
In addi tion, the aoplicant t rougn this action is requesting approvai to transship spent fuel frcm Oconee to McGuire.
Furtner, the applicant in its request for an operating license for,he Catawba Station, has reouested a:: proval to store spent fuel generated at Oconee and McGuire at *he Cataw::a Nuclear Station. The lv i m Glawba nave been soecifically 2*
desicned with excess cacacity to Silcw for *he storice o# :his fuel.
The ap?licant's comit. rent to nuclear power couplec sita the number of reactors projected to be on line by 1993 places the applicant in a uni ue cositien available to very few utilities.
{nis position allcws
- hem to beco e inde: ender.: and sej '-:u##icient in terms of scent #uel storace g <,g. s
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Additionally, Duke is in_a_p_osition to evaluate all other options avail-able to their facilitips. such as rerackino, expansion of spent fue pools during construction, or the construction of an ISFSI.
7he present planned storage capacities at Duke's facilities and their estimated date of co mercial operation are cresenM_d in the following tabl [
The existing scheduled storage capacity is cacable of storing spent _
w fuel generated by Cuke's system until 1995.
The options open to the applicant could extend this date to beyond the year 2000.
Such options remain available for consideration of the need for additional spent fuel storage space.
Date of Co =ercial Present (Planned)
Station Oceration Storage Cacacity Oconee Unit 1 ar.d 2 73/74 336 (750)
Unit 3 1974
.3 7 a McGuire Unit 1 04/30 (500)
Unit 2 04/32
_(500)
Catawoa Unit 1 07/81
_(1218)
Unit 2 01/83 (lala)
Cherokee Unit 1 01/35 (593)
Unit 2 01/87 (593)
Unit 3 01/39
'(693) __
Perkins Unit 1 01/90 (593)
Unit 2 07/91 U93)
Unit 3 01/93
,{
L,
. ihe use of poison racks and the construction of a new facility to make Oconee independent in terms of spent fuel storage capacity would leave the applicant with two solutions to the same problem [i.e., (1) total capacity presently within their system, and (2) excess capacity at Ocenee.]
This cannot be considered cost effective <-
Other excenses at Oconee include the application for a license amendment to rerack the basin servinc Oconee Units i and 2 with its associated costs and the purchase of high density stainless steel racks.
A decision on the license amendment is estimated by the Commission in early June. A de:ision to negate the transshipment action and require jhe_use_of poison racks at Oconee would have as an added ;ost those costs already incurrod in procuring and licensing non-poisen racks.
Another consideration in the use of :oison racks is the tir lay required for licensing and procurement of these racks.
This has typically taken one year for prccurement, licensing and installation.
This time constraint would delay ccmpletion of the Oconee reracking action un.1 mid-1980. Jn May,1950, all usaole storage locations at Oconee.>ould be utilized leaving no space for relocation cf spent fuel assemblies durin; re racki ng.
Reracking with poison racks in 1930 would require the trans-shipment of spent fuel assemblies _t_o _an alternate site, to allcw working srace for reracking.
- s Ogi 2\\ u 33
The impacts of this transshipment would be of the magnitude requested in the subject licensing action to transship and store 300-270 day old spent fuel assemblies at McGuire.
Therefore, environmental impacts of accommodating reracking with poison racks will be at least equivalent to those of the subject transshipcent licensing action, which we have concluded will be nealigibly small, and therefore insig_nificant.
(3. Spitainy affidavit)
With regard to tne risks of trans shipment, the staf#'s affidavits
[ Carolina Environmental Study Group / Carolina Action (CESG-CA contention 2)]
and the EIA conclude the risks will be neglig"aly small and, therefore result in insignificant irrpacts.
The installation of poison racks in Oconee's spent fuel basin does not preclude 'he transshipment of fuel to Therefore._ei ther_;mposal._r_ssults.in__coccarable _ risks and, in Mcgre.
h relative environmental imoacts whic" are ir.significant.
In summary, generally, the use of poison racks is a technologically, economically and environmentally sound alter _nat_ive, as is the use of s'aibs steel high density racks.
However, the use of chis alternative techrology would not be the most cost-effective means of resolving Duke's immediate spent fuel storage crablem.-
Additionally, where it is found that tne impacts of a proposed
~
action (transshirent) are insignificant, and the asscciated risks are also fcund to be insignificant, the staff does not intervene in the selection of en cption, in wnich the decision is normally made by One management of a u'.41i ty.
l.. '8
. However, if the staff is required to consider the choice of alternatives available to Duke Power,.due to the time required to install poison racks, and the shortfall of their capability to carry Oconee to 1995, which would subsequently require the additional measure of constructing a new spent fuel storage facility, the use of poison racks is not a reasonable alternative to the proposed action. Additionally, the fact that a tecnnologically feasible, econcaically inex:ensive; and environmentally insignificant alternative does exist makes the proposed action the best one.
We hereby certify that the above statements are true and accurate to the best of my kncwledge and belief.
.~.
}gy Brett 5. Spitalny b
R. Canlei Glenn Suoscribed and s< crn to before me this /t ' aday of May, 1979 f'
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- Eesl=y D. Glenn, Senior Deveic: ent Encineer, Environmental Evaluations
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Encineering Technolc;y, Oklahoma Sta te Uni ver',ity 1971 M.S.
Environmental Health Sciences, Universi y of Michican 1972 txcerience 1
Mr. Glenn specializes in r:ealth Physics and has experience in tn, e folicwinc areas:
Radiolacical Er.cineerinc.
Mr. Glenn has professicnal experience in raciclegical encineering which includes evaluation of potential hac=rds, safccuards, sce:ial requirerents for new and unicue R&D crograms and traininc of heal th physics technicians.
Execsure Evalua' ion.
"r. Glenn has additional exterience as ex;csure evaica:1cn for tne."anford Frcjec;.
Duties as exocsure evaluat on inciuce; eva,uation of.,icassay, invivo and iL c.csimeter data in v
routine and non routine si'.uations to determine occupational radiation exacsure received in these situations.
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Duties included overseeing the eva,luation at. doses to various population grou:s rom routine and costulated accidental re,ieases.
r.d c..itional c.uties nciuced evaluation of environmental imps.ct associated with trascortation of scent fuel, fue' residues and ctler radicactive wastes.
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UNITED STATES CF AMERICA NUCLEAR REGULATCRY CC:4tISSION BEFCRE THE ATCMIC SAFETY AND LICENSING 3 CARD In the Matter of
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CUKE FCWER CC?tFANY
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Occket No. 70.-2c23
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License SNM-1173 for Oconee
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Nuclear Station Scent Fuei
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Trans::ortaticn and S:crage
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at McGuire Nuclear Station)
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1 I, Dr. Jchn '/. Nehemias, beirg duly sworn, do depose and state:
r =m a Senior Health Physicist in the Civisicn of Site Safety 1
and Envircemental Analysis, U.S. Nuclear Regulatcry Ccmmissicn (NRC).
2.
I have cre::ared a statement of professicnal ;ualifications '.4nicn is attached c :nis afficavit.
2.
This afficavit addresses in part, Natural Rescurces Defense Ccuncil 4
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Ccntanticn 2(a).
I 9ereby certify that the abcVe statements are true and accurate :: the best of my kncwie:ge and belief.
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Or. Jann '/. 'lehe i as Subscribed and sucen tc tefcre ce tnis/I day of 2,.
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Contention 4(a):
ALARA can be achieved by on-site expansien of spent fuel pool storage capacity at Oconee, including building another spent fuel pool.
This contenticn addresses the fact that the propcsed transshipment of Oconee spent nuclear fuel to MuGuire Nuclear Staticn for storage will involve scme radiation exposure to the public and to workers e
~
involved in the transshipment.
Intervencr's point is that these raciation ex;csures could te entirely eliminated by simply expanding the spent fuel storage ca:acity at Oconee, either by re-racking the present spent fuel ;cci to permit stcrage of a larger num er of fuel elements, or by building another spent fuel ;cci at Oconee.
-We understand that re-rickinc the cresent scent fuel :0c1 at Oconee wculd provide only encuch additicnal fuel stcrace ;t:acity to -
acccmmodate abcut two years' su:Oly of spent fuel.
At or before that time, additional spent fuel storage ca acity would be recuired, either by building incther s;ent ruel pool at Octnes, or :y trans-snipping the spent fuel, utilizing available space at YcGuire.
Thus, re-racking the cresent s:ent fuel ; col at Oconee would delay cnly slightly the necessity to transfer scent fuel to another Iccaticn, and would nct eliminate that necessi:y.
(2)
Re-racking the cresent Occnee s:ent fuel eccl Egperiencewithpriceone-timefuelOcclTcdificationsof this kinc incicates : hat such re-racking c;erations have 4/'
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of about 3 can-rems to te trorkers caus d
'a av'-=ce involved.
The hichest canulative occusational dose from such coerations has been 20 man-reas, which was iacutted_
durina the ' cdification of the see,t fuel neol at Maddam
~~
Se&. See a ttached Table l.
ijo public exposure should result.
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- - d e Cuke F0wer has estima ted, wa %14 =ye conservatively, that occu.:ational doses during rrodification of the spent fuel pool at Oconee would be 125 man-rems.. Eased on experience with simil ar adiFca tions a t o t':er ci an ts, e would expect that actual doses may be 50c2'.uhat Icwer_.
'de have requested the applicant to prepare a.mcre realistic Y
esti. mate, and to provide additional information about Scw dose rates and occuoational doses will be kept as icw as
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is raasonabl;. achievable. ( ALUA)
It seems reasonable to anu:le that the likely occupational
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radiation exposure frca the re-rackina cceration at Oconei wculd be in the range of 20 to 30 nan-rems.
(b)
Transshicme-t of Cconee scent fuel to "cS.u i re The radiaticn eses to the :ublic esultinc fran the
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portion of the total dose could be eliminated by construc-tion of a new spent fuel pool at Oconee.
The principal radiation dose resulting from this trans-
'rcc shipment, however, would be delivered to workers, and is.
In est1} mated at 16 can-rens to drivers for 300 shipments.
addition, occupational dose which would not be eliminated by construction of a new spent fuel pool at Oconee, results fran activities reilted to transfer of the scent fuel into -
,a shiocing cask, movement of the cask fecm the spent fuel pac 1 to the new location, and trans fer fr:m the shipping cask to the new storage facility.
It aens reascnable to assume that the likely occupational
-radiation exacsure frca transshi: cent to McGuire would be in the rance of 20 to 30 can-rems.
(c)
Construction of a new scent fuel cool at Oconee The actual activities involved in cens tructicn of a nei spent fuel pcol at Cconee wculd not involve any radiaticn exposure to the public, or to the ;erscnnel involved.
However, when the ncw spent heL_poollas_been cons _t_ructed, 2s in the case of transshi? ment to McGu.ce, fuel transfer tyculd still he repuired.
The scent fusi..culdlave_to be trans ferred, one fuel. Jssi.bly.a t a time frca the existing m
.v.rs nT e
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-4 spent fuel pcol into a shipping cask, mcVed in the cask frcm the spant fuel pool to the new location, and transferred from the shipning cask to the new storage facility.
These activities will involve radiation exposures to the
._rg:
personnel taking part in the transfers.
c Al though no estimate of the potential total dose fecm these operations has been provided,,_it seems reascnable to assume that such doses will also be in the rance of 20 to 30 man-rems.
T'r 2 total man-rem doses cro'ec.ted to resul t frca the three _acticns b a_i n c considered are estimated to be in the same general dose range.
~. -
any of the Tilerefore, t.here would be no. basis for concludinc tha t three is clearly to be preferred frca the coint of view of radiaticn m
risk, nor that any sicnificant dose savinc would be exnected to s._
resul t frcm the selection _a_f_ary one of the three.
je conclude that the exposures likely to resul t fecm the transship-ment of Oconee scent fuel to '4cGuire, as described by the acclicant, would be ALAPa.
Each aspect of the proposed actions have been considered feca the point of view of keeping raciation exposures ALA?A, elimina?.ing unreces sary exposures, and t2 king all reascnable precauticns to reduce exposuras.
Na have transmitted to the k,
aCplicant additional recuests for infarra tion cn the ;rc;osed,, s.,
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re-racking of the spent fuel pool at Oconee, in creer for us to be able to reach the conclusion that it too would be c nsistent with ALARA considerations.
S irail arly, if the applicant proposes to construct a new spent fuel storage facility at Oconee, we will w __,
- 1 9 review any such a;olication with regard to ALARA censiderations.
While the 1RC has not issued specific guidance related to ALARA c nsiderations involved with fuel storage cr transfer, we have issued Regulatory Guides 3.3, "Information Relevant to Ensuring That Occupational Radiation Excosures at Nuclear Power Stations Will Be As Law As Is Reasonably Achievable," and 3.5, Ceerating Philos 00hy for Maintaining Cccucaticnal Radiaticn As Lcw As !s 0.easonably Achieva:le." These guides s ell cut cur ALARA philoscony and describe tne ALARA a:pr0ach to reduction of exacsures.
These consideraticns have been 1:: lied in our review Of the a Clicant's proccsals
'^...
regarcing spent fuel transfer and stcrage at Cconee and McGuire.
I here:y certify that the abcve statements are true and ::rrect to the best of my kncwledge and belief.
w is(]C r n.'..i e n e'"i a s 3Un~cribeC and swCrn OO bef 0re 'Je this 0 day Of f
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John V. Nehemias PROFESSIONAL QUALIFICATIONS Radiological Assessment Branch Qivision of Site Safety and Environmental Analysis
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I am a Senior Health Physicist in the Radiological Assessment Branch, Division of Site Safety and Envircnmental Analysis, Office of Nuclear Reactor Regulation.
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My formal education consists of study in Physics at Rensselaer Polytechnic Institute where I received a B.S. in 1943 and at Columbia University where I received an A.M. in 1949.
I received a Ph.D. in Environmental Health (Radiological) frca the University of Michigan in 1950.
Before joining AEC/NRC, I served three years at Brookhaven National Laboratory as a health physicist, six years at the University of Michigan as health physicist and assistant director of a radiation effects labcratory, and three years as Directcr of Radiolcgical Health Surveys for the National Sanitation Foundation.
In the latter pcsition, I
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designed, organized, and directed the envirormental survey for the Enrico Fermi nuclear plant.
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I joined the AEC in September 1950, as a health physicist in the Office of Health and Safety.
My principal duties there related to develcpment of radiaticn protection standards. With the two excepticns noted below,
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I have continued with AEC (and NRC) since that time. My principal
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responsibility was in the development of Stancards until September 1972; during most of those years I served as a branch chief-thrcegh several name changes and reorganizations-most recently as Chief, Occupational He +1 n Standards Branch, March 1972 to September 1974.
Since Septamber 1974, I have served as Senior health chysicist in the Radioicgical Assessment Branch.
My principal function is the review of pcwer reactcr applications, boch at the ccnstruction permit and cperating I
license scage, to determine the adequacy of prcposed oc.;cational radiation protectica programs and the related efforts proposed to assure that occupational radiation exposures will be maintained as Icw as is
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From June 1963 to Septamber 1965, I took a leave of absence from AEC and served as principal member of the Occupational Safety and Health Divisicn of the International Labor Office in Geneva, Switzerland.
My work was principally in the development of international standards.
In December 1971, I was transferred to the Criteria and Standards 3@Qs Division, EPA, serving as Chief, Criteria and Standards Branch, until my return to AEC in March 1972.
I have published about 40 techni:al articles in professicnal journals and other publications in the general areas of icw-level counting, envircnmental monitoring, radiation effects on biological systems, and ccntrol of occupational radiatica exposure.
I have been a Certified Health Physicist since 1960, and am a Charter member of the Health Physics Society and of the Saltimore-Washington Chapter.
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UNITED STATES OF AMERICA NUCL9R REGULATCRY CCMMISSION BEFORE THE ATCMIC SAFETY AND LICENSING E0ARD In the Matter of
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CUKE POWER COMPANY
)
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(Anencment to Materials License
)
Docket No. 70-2623 SNM-1173 for Oconee Nuclear
)
Station Scent Fuel Transportation
)
and Storage at McGuire Nuclear
)
Station
)
AFFIDAVIT OF DR. MICHAEL A. PARSONT
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AFFIDAVIT OF DR. MICHAEL A. PAR $0NT My name is Michael A. Parsont.
I am Chief of the Radi] logical Health Standards Branch of the NRC Office of Standards Development.
As part of my duties in this position I am responsible for directing an NRC program to evaluate and assess the radiological health impacts to the public from NRC proposed and licensed facilities.
A copy of my Professional Qualifications is attached.
My affidavit responds to Petitioner's contention J Part b. which refers to residual health risks from the dose resulting from transshipment of spent fuel frem the Oconee facility as major costs tipping the balance against the precosal to transship and store Oconee agent nuclear fuel in the McGuire, Unit 1 scent fuel pcol.
Contenticn i is as follo is:
The crocosed action increases the exoosure to radiation of workers and the general public beyond what is ALARA.
a.
ALARA can be achieved by on-site exoansion of scent fuel storage capacity at Oconee, including building another spent fuel pool.
b.
The residual health risks which remain even if the present NRC cagulations on exoosures to workers are met are major costs of the proposed action.shich tip the balance against :he proposed action (Tr.77-85).
In the context of my testimony, Residual Health Risks fecm exoosure to ioni:ing radiatico are genetic risks and may be excressed in subsequent generations as congenital abnormalitics, constitutional and degenerative diseases and overall ill-neaith (other illnesses having S' %
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' scme degree of genetic determination).
In additicn, the cancer risk fecm exposure to ionizing radiation is of concern to Petitioner.
My response to this part of Contention 4 is based on the folicwing considerations:
1.
Somatic risks (i.e. the risk of cancer) and a significant portion of the genetic risks of health effects from ionizing radiation are directly and linearly oronn**'r=1 to " W at.i_on dpse and dose rate.
2.
Thara are 2 viable og* ions, both of which will be taken, for Duke Power Company to resolve its immediate shortfall in spent
- uel storace capacity--these being the expansion of storage capacity of Oconee Units 1 and 2 Spent fuel 2001 by re-racking ano at other nuclea: stations owned by Duke Power.
I have estimated the genetic effects for the range of doses involved in the 2 cptions fr r resc1ving the Oconee spent fuel storage cacacity shortage based on the 1972 National Academy of Science Report of the Comittee on the Biological Effects of Ionizing Radiation, SEIR.I)
(The recently published uadate of the 3EIR Comittee, SEIR-III,2) presents infor ation on genetic effeccs which does not significantly differ frca the 1972 SEIR Re:crt.)
I have estim.ated risk to cancer frem 3EIR-III data because it represents more recent considerations of radiation ef fects.
1)
Advisory Comittee on the Biological Effects of Ionizing Radiation.
"The Effects on occulations of Exposure to Los Levels of Ionizing 3aciaticn." National Acacemy of Sciences-Naticnal Research Council, Washington, D. C. Novemcer 1972.
2)Ccmittee on the Biological Effects o' Ionizing R-diations.
"The Effects on Poculations cf Expcsure to La. Levels of Ionizing Radiations, lational Academy of Sciences--c;i:nal Research Council. Washington, :. C.
1979.
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, The rs.ge of doses used in my calculation of the genetic effects is based on several considerations as follows:
- 1. The upper end uf the range of population dose is based on estimates of the applicant.
This was presented as 150 person-rem in Table 10-1 of the Environmental Impact Analysis for expanison of the Oconee spent fuel storage pool capacity by re * =cking.
This estimate was subsequently reestimated at 125 per301-rem.
- 2. Mr. Glen of Battelle Northwest Laboratories estimates that re-rackinc could start at about 60 cerson-rem but w'nly, 2
unlikely range ucward to 150 person-rem.
- 3. Dr. Nehemias states that, based on actual excerience, re-racking dose would be closer to 20 person-rem.
- 4. The acplicant's reestimated re-racking dose and the population dose from transshipment (120 person-rem) are effectively the same frcm the standpoint of effects.
Therefore, the range of doses from the 2 options extend frca 20-150 person-rem based on whichever information is accepted.
In addition, for perspective, these doses are cuite small (.0045.03%) comcared to the expected normal operation _pccucatienal_exposur.e at_0.: nee lu2 and 3 over the assumed _10Jear_ficUitylifetime.
The estima ed genetic effects from SEIR '> and frca the re-racking and l
transshipment options are presented in Tables I and II, respectively.
The range of cases brackets the dose estimates given above.
Altnough there is genera! agreement that a significar.' prcoortion of somatic and genetic health risks are directly proportional to the magnitude of the radiation dose, there is centreversy cver the magnitude Of the dose-effect res;cnse at Icw-radiaticn cose and dose rate.
This
- 0ntroversy is based an the results of studies of various exposed coculaticns.
These studies re: ort that execsure to low-level radi-ion c[h 2 s,
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4-may be about an order of magnitude (about 10 times) more effective in producing health effects than the estimates given in the SEIR Reocrt. '1, Applying the fac:or of 10 to the estimates of genetic effects given in Table II results in a maximum equilibrium estimate of 0.3 e f fec ts.
In my opinion, because of the small number of aenetic effects, even if the BEIR estimates were icw, this action does not reoresent a major genetic health cost.
Although cantention 4 does not specifically refer to scmatic effects, I have calculated the range of total and fatal cancers which might result from the cptions consicered.
I have used the risk estimate presented in BEIR-II! which are summarized in Table III.
The estimates for the option are given in Table I'/.
For a single excocare the maximum estimate of total cancers, assuming 3EIR-III was low by a factor of 10, would be 0.S, and the r. stimate for fatal cancers would be 0.2.
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GENETIC EFFECTS COMPARISON FOR TWO CPTIONS Cose Genetic Effects Total Genetic Oction 1/
(Person-rem)
First Generaticn Effects at Ecuilibrium 1
20-150 0.0006
.004 0.004 - 0.03 2
120 0.003 0.02 1/ Option 1 is reracking at Oconee.
Option 2 is transsni;; ment to McGuire.
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irc 4:parative Lif etize Cancer ?lsk isti=stes for the
. :eral Populatica f r = Excesures to Low-Dose, Low-LET Fadia: ion, Single Exposure
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I:gosure", Soth Sexes Cc=bined 1/
Source of Costitucus Esti=ates Single Exposure exposure (cer =11110 coculation exoosed eer rad) 3.
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-t=c<dence Kelati.c ?dsk 636-1031 592-946 Absolute Risk 263-399 (525P 254-373 (290)s s
Mortaliry Ealative Risk 177-353 150-293 Absolute Flsk 70-124 (157)h 63-119 (lll)D 3EIR 1972 Factors **
Martali:7
?. elative Risk 621 568 Absolute Risk 117 (270)b 115 (c,::,.3
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U'iSCEAR 1977 Mc:: alit 7 100 100
- D.e 3E*R 1979 single--expcsure estica:e was based ca a 10-rad dese and was divided by 10 for c =parison with :he other values; the esti:2:e fcr cc:-
tinu:us e:gesure is based := a lifeti=e exposure of I rad / year.
- 3EIR 1972 post-catal, age-specific risk fac: cts used with 1969-1971 life-tables, vich plateau extending throughou: :he fears of life re=aining af:er irradia:1 2,
estica:e (b) in the 1972 3EIR Report.
ine avera:e age of the 1969-1971 life-tables is olcer than that of the 1967 U.S. peculatier used in the 1972 SEIR re::cet.
For nis reascn, the nroers obtained here for continuous execsure are larger, on a :er rac basis, than : nose obtainable from 7 ables 3-3 anc 3-0 of the 1972 3E:R recort.
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Ccse Total 00: ion 1/
(Person-cen)
Incidence Fatal 1
20 - 150
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120
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.0002 1/ ption 1 is ceracking at Oconee.
O Option 2 i; transsnigment :a ficGuire.
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I hereby certify that the above statements are true and accurate to the best of my knowledge and belief.
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s Dr. ldicnael A. 73rsont Subscribed and sworn to before me nis litn day of May,1979, d
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//974 My Ccemission Expires:
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PROFESSIONAL QUALIFICATICNS of Dr. Michael A. Parson:
My name is Michael A. Parsont, I am Chief, of the Radiological Health Standards Branch in the Office of Standards Development of the U.S.
Nuclear Regulatory Commission.
I have served in this position since November 1978.
In this capacity, I supervise and direct the activities of six staff professionals in areas concerning the determination of health risks and effect from exposure to ionizing radiation, radiation epidemiology and regulation of the use of medical devices and pharmaceuticals containing radioactivity.
In addition I am responsible for developing radiological health standards and guides and for the evaluation and assessment of the radiobiological health impacts on the public from proposed and licensed facilities.
Such efforts include the determination of relationships between low-level radiation exposure and health effects from direct radiatica and racioactive materials emitted from planned or existing nuclear facilities and from the medical use of radioactive materials.
I am also responsible for directing, coordinating and evaluating technical support research performed by national laboratories and industrial contractors to establish the bases for regulations, standards and guides.
I serve as an advisor and coordinator in radiobiology for technical assistance contracts.
I represent the NRC at international symcosia, and other meetings in areas of radiological impact assessment.
From Septem0er 1972 until November 1978 I served as a radiobiologist and an environmental scientist on the staffs of tne Office of Standards Develop-ment and Nuclear Reactor Regulation, respectively.
In these positiens I performed evaluations of :ne health effects of ionizing radiation; crecared the Radiological Assessment and Radiological Monitoring Sections of Environmental Imcact Statements; and performed numerous studies related to the impact of NRC croposed and licensed facilities on the env.ronment.
I received a 3.5. in Public Health from -he University of California at Los Angeles (1955), a M.S. in Radiology fr;m Colorado State University (1952) and a Ph.D. in Radiation Biology from Colorado Sta'a University (1967).
I completed additional undergraduate studies in genetics and endocrinology at the University of California, Berkeley and graduate studies in Sanitation Engineering and Public Health at the University of California it Berkeley ano Los Angeles, respectively.
I have more than 15 years of professional ex;erience in Public Health, Radiaticn Biology, Environmental Sciences, research evaluation and ccordination and standards development.
This experience was gained at the Alameda County Health Department, Alameda, California; Sandia Labora-tories, Albuquerque, New Mexico (Aerospace Nuclear Safety); NUS Corporation, Rockville, Maryland (Environmental Studies); and the AEC-NRC.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of DUKE POWER COMPANY
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Docket No. 70-2623
)
(Amendment to Materials License
)
SNM-ll73 for Oconee Nuclear
)
Station Spent Fuel Transportation
)
and Storage at McGuire Nuclear
)
Station
)
AFFIDAVIT OF T. JERRELL CARTER, JR.
I, T. Jerrell Carter, Jr., being duly sworn, do depose and state:
1.
I am a Technical Assistant in the Division of Operating Reactors, U. S. Nuclear Regulatory Comission (NRC).
2.
I have prepared a statement of professional qualifications which is attached to this affidavit.
3.
This affidavit, address inpart, Natural Resources Defense Council Contention 5.
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Contention #5 Applicant overstates the need for action at this time by using the one-core discharge capacity reserve standard as if it were a requirement where in fact it is not a requirement of NRC regulations.
(a) Either Applicant should be bound to comply with the one-core discharge capacity standard [as a license condition] or it should have to demonstrate on a cost / benefit basis that holding that capability is more valuable than the costs of shipment off-site of one core of spent fuel (Tr.85-127).
There is no regulatory requirement for any particular spent fuel storage capacity nor is the regulatory staff aware of any :ompelling safety basis for requiring maintenance of a full core discharge capability.
The lack of a spent fuel storage capability can be costly in terms of extended reactor outage time, however, the benefits from orudent reactor plant design, in availability of the facility and reduction _o.f_ man.-rem exposures for inspections and repairs, are self evident. Therefore, the licensing staff plans to continue its past practice of pointing out these benefits to applicants and licensees.
This testimony is based in part on general conclusions reached as a result of numerous spent fuel _.itacage cev4ews-anLassoc4a_ted._ev.alua tions of al ternatives.
The specific alternatives and conclusions relative to the proposed shipment of spent fuel from the Oconee station to McGuire will be covered by others.
Historically, power reactor facilities have been designed and built with storage pools for irradiated fuel assemblies that could store the fuel discharged during the refueling, plus some additional space.
337 "Q2
Contention 5 cont'd Generally, utilities have followed the practice of providing additional space for a full core, so that if a need to unload the core should occur, space would be available to permit immediate unloading.
The staff has endorsed and encouraged this design philosophy. Our present practice, as described in the standard Review Plan is to require applicants to state the basis for the spent fuel storage capacity provided in the design.
(The Standard Review Plan is guidance for the staff which presents a well defined base for reviewers and a statement of regulatory policy.)
For example, the safety analysis reports for some recent light water reactor applications state that the storage space provided is consistent with the maximum number of spent fuel assemblies unloaded from the core, du ;3q the refueling t...e, plus the fuel contained in a full core load (e.g.,
1-1/3 core for a single unit plant and 1-2/3 core for a dual unit facility).
_The stafi_haliates_the above is an appropriate basis for selecting design storage capacity _, and has informed applicants to this effect, but we have no guides or regulations that require any specific basis for selecting design capaci ty.
The Oconee station censists of 3 reactors.
Two reactors share one pool and the third reactor has a separate pool.
The shared pool had an original capacity slightly greater than 12/3 cores and single unit pool had a capacity slightly less than 1 1/2 cores.
This was consistent with the then prevailing cesign practice.
Since then the license has
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Contention 45 cont'd requested and received approval to increase the storage capacity of the single unit pool to about 2.7 cores. Therefore the license has a total station storage capacity for the three units of about 4.5 cores.
Presently there is available storage for 265 fuel assemblies; each of the three units has a core that consists of 177 fuel assemblies.
The staff has previously (1975) considared the possible need for establishing requirements for design capacity of spent fuel storage
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pools and for the maintenance of available space suf ficient to permit storage of a full reactor core in the event the need should arise to s
unload the reactor (full core reserve). The staff considered various postulated situations that illustrate the benefits of being able to_
c_cmpletely unload the reactor, such as the need to perform repairs o
or modifications _(e.g. repair pipe cracks or replace steam generator tuces) or to reduce the accumulated man-rem dose to workers during certain maintenance or inspection activities ( e.o. insoect the reactor belt-line welds or reactor fuel). Jngl cases, however, the conditions that might require unloading the core could be
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permi tted toALan_Lthe_ unloading-put_of f.or_ del ayed until space was made available by shipping stored fuel to some other location.
No postul ated event _o_tsafety consi.derati_on_tequired _immediate core u_nl oad i n g.
The core cooling system with its redundancy and the
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Contention #5 cont'd reactor vessel with its integrity provide assurance that the reactor vessel is a safe location in which to keep fuel already in the core for an indefinite period, following shutdown of the reactor.
None of the postulated situations presented any compelling safety basis for recuiring maintenance of a full core reserve; however, lack of such capability can be costly in terms of extended outage time. The benefits frortptudent design, in availability of the f acility an_d recuctgn of man-rgsures for inspections and_
repairs, are self evid g.,
Therefore, the licensing staff points out these benefits to applicants and licensees, but has not established a basis for imposing a requirement to maintain full c' ore reserve fuel storage capability.
Licensees recognize the benefits of being able to unload the reactor but not all licensees have taken steps to assure that a full core reserve is available.
Possibly because there is no requirement for a particular spent fuel storage capability, the steps taken by licensees have not all been the same.
In the past some utilities requested increases in storage capacity of only a fraction of a core although most requested increases were for more than one core of storage capability..
Tocay only 2 reactor stations, with one or more reactors, are operating without a full core reserve (FCR).
But during the past four ye,ars, numerous other stations also have cperated without a FCR.
These actions show that not all licensees believe that full core reserve is necessary.
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Contention 55 cont'd The contention, simply stated, would require a licensee to demonstrate that it is better to rely on a full core storage capability than to rely on shipment of spent fuel.
Fuel may have to be discharged from the reactor to permit reactor vessel inspections or certain repairs.
The contention presupposes that shipment of spent fue_1 to another location is a viable option.
[n the particular case involving Duke Power, the McGuire spent ft:el storage pool does exist arid it could be used to receive spent fuel from the Oconee station.
In most proposals reviewed to date the option of shipping spent fuel between reactor sites did not exist; therefore, increasing the on-site storage pool capacity was the proposed option.
(The NRC assess-ment of case specific alternatives available to Duke Power is discussed in the Environmental Impact Appraisal and Staff affidavits with respect to Natural Resources Defense Council Contention No. 3 on Altcenatives and Carolina Environmental Study Group and Carolina Action Contention No. l.)
Assessments of cost benefit for those proposals that have been approved to date show that shutting down the plant is less_desi_rab.l_e than either increasing cn-site storage capability or sjl.pping_ spent fuel to another i
re_acter pool with space.
v The Conmissicn stated on September 10, 1975, in the Federal Reaister that acprovals for pool modifications can be granted, pending issuance of the generic environmental impact statment, gnvided that they are consistent with consideration of five specific fa ctors.
One of the
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Conten ti vn ?5 factors specifically covers the need for the increased storage capability.
It and other factors have been considered in an Environ-mental Impact Appraisal issued by the NRC in support of every licensing action on a storage pool modification.
We have approved on a case-by-case basis, approximately 40 proposals to increase on-site spent fuel storage capacity.
In these cases it was found that the cost associated with the reactor being unable to operate for a short time because of a lack of storage capability is far greater than either increasing on-site storage cap bility or shipping fuel to another site for storage if it were available.
NRC has been authorizing on-site spent fuel storage expansive well before the necessity to preclude a reactor shutdown. Our reasons ir lude:
(1) modifications to increase spent fuel storage capabilit with less per_sonnel exoosure to radia_tian_wh_en the pool has _r o
fuel in it or less tna% Com21; ment _of__ spent _.fue) and (2) regardless of tne amount of storage available the added storage capability will not be used until the need for storage exists - storage capability does not cause a utility to generate either a larger quantity of spent fuel ur spent fuel at a faster rate just to fill the pool. t odifications
,j po_on-site o001 storage capabil_ity can be m_ost easily done before_ spent fuel ha s._o_e_en di scha rged fremlhe reac tor to the pool,.__Al l.worL car _
be done wi.th_the_p. col _ dryince water does noineed to be in the pcol.
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Contention e5 7-When spent fuel is in the pool, water is required for shielding and cooling. Keening the amount of spent fuel in the pool to a minimum reduces the radiation field strength and increases the distance
_between ua wor ers and t_
ce the k
amourt of fuel handling, simplify _the_nodification pyc_edures and.
- s,y minimize the time that personnel are exposed.
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Thus, although there is no regulatory requirement for any particular spent fuel storage capacity, providing increased storage capability does not increase tne rate at which spent fuel is discharged from the reactor to the pool, but will instead provide the licensee with operational flex 'bility which the NRC staf f encourages.
NRC will review each proposed option and give approval, when necesary and appropriate.
I hereby certify tnat the above statements are true and accurate to the best of my knowledge and belief.
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C',4errell Carter, Jr.
Subscribed and sworn to before me this / C day of
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PROFESSIONAL QUALIFICATIONS OF T. JERRELL CARTER. JR.
I serve as technical expert in the nuclear engineering field as advisor and assistant to the Assistant Director for Engineering and P roj ec ts,
Division of Operating Reactors.
I coordinate technical reviews within the division As such I have been involved with spent fuel storage increases sinc e 975.
I have authored a paper on spent fuel storage given at the 9th Annual National Conference on Radiation Control in 1977 and another updated paper to be given to the June 1979 Meeting of the American Nuclear Society.
I have also participated in a joint NRC/IAEA Seminar on Spent Fuel Storage in 1978.
Prior to coning to the Commission in 1969, I was with Atomics International in California for 11 years.
I workea as a process design engineer for a power reactor.
As such I performed safety studies in support of a Safety Analysis Report, evaluated system designs and prepared system design discriptions and equipment specifica-tions.
I also designed and specified equipment for experimental loops installed in domestic and Canadian reactors.
I assisted loop operation and evaluated the performance.
In addition, two years were spent at a reactor site during preoperational testing and initial operation of a power reactor.
I was responsible for evaluating system performance and designing modifications that would improve performance.
Included
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were spent fuel storage pool systems including water purification.
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- I received a Bachelor of Arts from Amherst College and a Bachelor of Science in Chemical Engineering from Massachusetts Insititute of Technology in 1957 and a Master of Science in Chemical Engineering from Massachusetts Institute of Technology in 1958.
My master's degree included work at the MIT Practice School in Oak Ridge, Tennessee.
I an a Registered Professional Engineer in Nuclear Engineering in the State of California.
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