ML19224D605
| ML19224D605 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/05/1979 |
| From: | Goldberg S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7907130128 | |
| Download: ML19224D605 (59) | |
Text
,I ]
4
.,,..-3
" Q ',N A D
'$.S YQ M
UNITED STATES OF AMERICA e 4 %W l
NUCLEAR REGULATORY COMMISSION 6/5/79 q
W aas y
/
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g
In the Matter of
)
)
Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(Proposed Amendnent to Facility (North Anna Nuclear Power Station,
)
Operating License NPF-4 to Permit Units 1 and 2)
)
Storage Pool Modification)
NRC STAFF RESPONSE TO VEPC0 sui"<ARY DISPOSITION MOTION On May 11, 1979, the Virginia Electric and Power Company (VEPC0 or Licensee) filed a motion for summary disposition regardina all contentions admitted in this proceeding pursuant to 10 CFR 52.749.
On the basis of the attached affi-davits, together with its safety evaluation and environmental impact appraisal issued in this matter cn January 29 and April 2,1979, respectively, the Staff supports the Licensee's summary disposition motion for all or portions of Contentions 1, 2, 4 5, 6 and 7.
The Staff expresses no coinion on the merits of the summary disposition motion with respect to the remainder of the contentions.
If the Board adopts the hearing schedule proposed in the Staff's " Motion to Reschedule Hearing," dated May 15, 1979, the Staff may be in a position to file an affirmative summary disposition on some or all of such remaining contentions.
Summary Disnosition Procedures The summary disposition procadures set forth in 10 CFR 52.749 are analogous to the summary judgment procedures contained in Rule 56 of the Federal Rules of Civil Procedure. Alabama Power Cr.coany (Joseph M. Farley Nuclear Plant, c
[ll pg
[3] '
7 00713 0 0g - f M
, Units 1 and 2), ALAB-182, AEC 210, 217 (1974). As explained by the Appeal Board, a motion for summary disposition:
enables the court to go beyond the complaint itself and to determine, on the basis of extensive matters such as affi-davits submitted by one or more of the parties, whether there is warrant for an evidentiary trial', i.e., whether there is "a genuine issue as to any material fact" bearing upon the claim or claims as to which sumnary resolution is sought. Id.
Although the burden of showing the absence of any genuine issue of fact is upon the moving party, and the record will be viewed in the light most favorable to the party opposing the motion, "a party opposing the motion...
must set forth specific facts showing that there is a genuine issue of fact."
10 CFR s2.749.
In this regard, it has been stated that-
[a]t this stage, mere allegations in the pleadings are not sufficient to establish the existence of an issue of material fact.
10 CFR 92.749(b) [ citations omitted].
To defeat summary disposition an opposing party must present facts in the proper form; conclusions of law will not suffice.
The opposing party's facts must be material, substantial, not fanciful, or merely suspicious.
[ footnotes omitted.]
One cannot avoid summary disposition "cn the mere hope that at trial he will be able to discredit revant's evidence; he must, at the hearing, be able to point out to the court some-thing indicating the existence of a triatle issue of material fact. " 6 Moore's Federal Practice 56.15[4].
One cannot "go to trial on the vague supposition that sc.nethino may turn up."
6 Moore's Federal Practice 56.15[3].
[ Citation omitted.] In Orvis v. Brickman, 95 F.Supp. 605 (D.O.C.1951), the Court, in granting the defendant's motion for summary judgment under the Federal Rules, said:
All the plaintiff has.in this case is the hope that on cross-examination.
. the defendants
.. will contradict their respective affidavits.
This is purely speculative, and to permit trial on such basis would nullify the purpose of Rule 56...
444.
081
. Gulf States Utilities Co.
(River Bend Station, Units 1 and 2), LBP-75-10, 1 NRC 246, 248 ('1975).
Thus, although the opposing party need not show that he will prevail on the factual ishes, he must show by competent evidence that such issues exist to be tried.-1/See, e.a., Public Service Comoany of New Hamoshire et al, (Sea-brook Station, Units 1 and 2), LBP-74-36, 7 AEC 877, 879 (1974).
In light of these principles, and for the reasons set forth below, the Staff urges the Board to grant tia Licensee's summary disposition motion on Conten-tions 1, 2 (in part), 4, 5, 6 and 7.
If the Board is unable to decide in favor of the Licensee on these contentions, summary disposition should be cranted on any portions of those contentions as to which there is no genuine issue of material fact.-2/
-1/ This is not inconsistent with the Staff's resoonsibilities under the National Environmental Policy Act (NEPA) as discussed in the case of
_ Consumers Power Co. v. Aeschliman. et al, 435 U.S. 519 (1978).
The Supreme Court therein, citing aporovingly from the " threshold test" prescribed by the Commission for evidentiary consideration of energy conse'.vation issues under NEPA, confirmed that an intervenor must make a "' showing... sufficient to require reasonable minds to inouire further.'"
Id.
Showing that a cenuine issue of material fact exists would seem to be the minimum required by this principle.
2f Section 2.749 authorizes a " decision by the presiding officer in tnat party's [movant's] favor as to all or any part of the matters insolved in the proceeding."
(Emphasis added.)
See, e.:.
Public Services Com-Dany of Oklahoma, et al.
(Black Fox Station, Units 1 and 2), LCP-TT 46, 7 NRC 167 (1977); The Toledo Edison Comoany (Davis-Besse Nuclear Power Station), LBP-73-30, 6 AEC 691, 699 (1973).
444 082
. Contention 1-Thermal Effects Paragraphs I through 53 of "VEPCO's Statement of Material Facts as to Which There is no Genuine Issue to be Heard" (Statement of Material Facts) attached tu its May ll,1979 su-rary disposition motion, as relesant to Contention 1, accurately summarize the salient facts not open to dispute.
Affidavit of Paul H. i.eech, Francis C. Kornegay, and Jared S. Wermiel on Contention 1 (Staff Affidavit on Contention 1).
The proposed modification would result in an incremental increase in the heat 6
load of 5.6 x 10 Btu /hr dissipated from the service water system.
This is about 5.5 percent more than the heat load on the service water reservoir under normal operation and about 4.6 percent of the heat load under abnormal conditions (unloading a full core), without the proposed modification.
Thc incremental effects of evoporating 12 gom to dissipate this additional heat would be minimal and would not be detectable at distances greater than 1 Km from the service water reservoir.
The service water reservoir is located onsite near the main structures of the station and any additional atmospheric effects of its operation such as fogging and icing are unlikely to occur offsite. Id.; see also EIA, R54.2, 4.3.
There is provisicn for discharge of the service water system to the waste 6
heat treatment facility if the aeed should arise.
The addition of 5.6 x 10 9
Btu /hr to the total discharge from Units 1 and 2 (13.5 x 10 Btu /hr) would be an increase of only 0.04%.
This would not have noticeable incremental effects on aquatic biota or the environment.
Id.: see also E M. s3,4, 444 08-3
. The spent fuel pool is designed to be virtually leak tight and has been tested to confirm its leak tigntness.
The pool is provided with means to detect leakage. Adequate redundant makeup sources are available to maintain the pool water at acceptable levels and prevent any temperature rise due to leakage.
Further, the spent fuel pool ccoling system will maintain the pool water tem-perature below 140 F under normal conditions and below 170 F under abnormal conditions.
The cooling system will be adequate to acct;mmodate the incremental heat load due to the proposed modification (SE, s2.5; EIA. 53. y and to prevent
" hot spots" or possible boiling in the spent fuel pool as a result of the pro-posed modification (Staff Affidavit on Contention 1).
As demonstrated above, no genuine issues of material fact remain to be resolved with regard to the environmental effects of the incremental heat load due to the proposed modification, the potential temperature rise in the spent fuel pool due to leakage, and the adequacy of the spent fuel cooling system to pi event " hot spots" and possible boiling.
Ther afore, the Board should grant sunnary disposition cad dismissal 'f Contention 1, 4D 084
' Contention 2: Radioactive Emissions Paragraphs 54 through 86 of VEPCO's Statement of "aterial Facts, as relevant to Contention 2, accurately summarize the salient facts not open to dispute.
Staff Affidavit of Henry E. P. Krug on Contention 2 (Krug Affidavit).
Plant radiological effluent technical specifications, which will be uncharged by the proposed modification, restrict total gaseous and liquid effluent releases from the plant to within regulatory limits.
Id., EIA, 564.4.3, 4.4.4.
The proposed modification will not add significantly to airborne radiation exposure or resultant health effects offsite.
Krug Affidavit; EIA, 54.4.3.
There should not be a significant increase in the liquid release of radionuclices from the station as a result of the proposed modification.
The amount of radioactivity on the spent fuel pool filters and demineralizers might siightly increase due to the additional spent fuel in the pool, but this increase of radioactivity would not be released in liouid effluents from the station.
Id.
In sum, the potential offsite radiological environmental impacts associated with the proposed modification were determined cu be environmentally insig-nificant.
Krug Affidavit; EIA. 34.4.1.
Accordingly, no genuine issues of material fact remain to be resolved with respect to whether the proposed modification will result in significant addi-tional gaseous or liquid radioactive emissions under normal operation.
There-fore, the Board should grant summary disposition and dismissal of the conten-tion with respect to normal operation.
444 085
. Contentions 4 and 5: Materials Intearity and Corrosion Paragraphs 78 through 86 and 127 through 134 of VEPCO's Statement of Material Facts, as relevant to Contentions 4 and 5, accurately summarize the salient facts not open to dispute.
Staff Affidavit of George B. Georgiev, M. D. Houston, and Jared S. Werniel on Contentions 4 and 5.
The low neutron flux in the spent fuel pool and the rapid decrease of decay heat indicate that little if any effect will be produced upon the spent fuel assemblies or stainless steel pool com-ponents, as the Zircaloy cladding and other stainless steel components endure far greater radiation and temperature conditions in the ractor vessel with negligible effect.
Galvanic corrosion will not occur as all components are closciy equivalent in electrogalvanic potential. As only minimal general corrosion will occur, the structural integrity of spent fuel pool components is not degraded.
As to the possibility of increased corrosion residues in the pool water, the existing spent fuel pool purification system will provide ade-quate purification capability; monitoring systems would detect such a con-dition, which could be remedied by more frequent replacement of filters and demineralizer resin beds.
Id.
As demonstrated above, no genuine issues of material fact remain to be resolved with respect to increased corrosive effects upon the store fuel and spent fuel pool components.
Therefore, the Board should grant summary disposition of Ccntentions 4 and 5.
444 086
. Contention 6: Occuoational Exoosure Paragraphs 135 through 156 of VEPCO's Statement of Material Facts, as rele-vant to Contention 6, accurately suicmarize the salient facts not open to dispute. Staff Affidavit of Thomas D. Murphy on Contention 6 (Murphy Affidavit).
In the event the nodification takes place after spent fuel is stored in the spent fuel pool, there will be some radiation exposure to plant personnel who replace the radioactively contaminated racks. Neither tne occupational exposure during the proposed modification nor the incre-ment in onsite occupaticnal dose resulting from the increase in stored fuel assemblies will affect the Licensee's ability to maintain individual occupa-tional doses within the linits of 10 CFR Part 20 and as low as reasonably achieved per 10 CFR H20.1.
Id., SE, 12.6; EIA, 54.4.6.
Based on information gathered on exposures to personnel from pressurized water reactors which have already modified their spent fuel pools, it is expected that the exposure at the North Anna Station will be less than 20 man-rem.
Id.
The health effects due to this incrementai 20 man-rem increase in occupational exposure are negligible.
EIA, 54.4.6.
As demonstrated above, no genuine issues of material fact remain to be re-solved with respect to whether the proposed modification will result in occu-pational exposures in excess of permissible levels.
Therefore, the Board should grant summary disposition and dismissal of Contention 6.
444 087
Contention 7: Alternatives This contention claims that certain proffered alternatives to the proposed action have not been addressed.
The following alternatives to the proposed modification have been considered.
(1) reprocessing of spent fuel; (2) storage at independent spent fuel storage installations; (3) offsite storage in spent fuel pools of other reactors; (4) lengthening the fuel cycles; (5) conservation measures; and (6) shutdown of the facility (EIA, 56.1-6.6).
The proposed modification will have an insignificant environmental impact (EIA, 56.7).
The proposed mcdification will not result in a significant commitment of resources (EIA, E57.3.2, 7.4).
The considered alternatives (which enccmpass proffered alternative (a)), as well as proffered alternatives (b) and (c), are unavailable within the neces-sary time-frame, are more expensive, and offer no environmental advantages over the proposed action.
EIA, s6.7; Staff Affidavit of Paul H. Leech Con-cerning Contention 7 (Leech Affidavit).
As a matter of law, the Appeal Board has expressly indicated that no considera-tion of alternatives is required under i; EPA in connection with comparable spent fuel pool modification applications given the fact that such a course of action will neither harm the environment nor involve unresolved conflicts concerning alternative uses of available resources.
Portland General Electric Co., et al. (Trojan iluclear Plant), ALAB-531, 9 i;RC
, slio. op. at 3-5 44k J
. (March 21, 1979); see also florthern States Power Co. (Prairie Island f:uclear Generating Plant, Units 1 and 2), ALAB-455, 7 : CR 41 (1978), remanded on ot.her grounds sub nom State of Minnesota v. ?1RC, tio. 78-1269 (D.C. Cir., "ay 23, 1979).
There are no distinguishing characteristics between this and the cited cases and the rulings in the latter should be applied with equal force to this proceeding.
Even assuming the existence of an obligation to consider alternatives, such alternatives must, nonetheless, pass scme threshold test of reasonableness.
See, e.n., Vermont Yankee T'uclear Power Coro. v. ?iRDC, et al., 435 U.S. 519 (1978), t1RDC v. Morton, 458 F2d 827, 837 (D.C. Cir. 1972).
The Staff believes that the alternatives considered in the EIA, which encompass proffered alter-native (a), more than satisfy such obligation.
The EIA, coupled with the Leech affidavit, demonstrates that the proffered alternatives are not viable alternatives to the proposed action or otherwise preferable from an environ-mental standpoint.
Cf. Consurers Power Co. (Midland Plant, Units 1 and 2),
ALAB-458, 7 t;RC 155 (1978)
Therefore, given the absence of any legal requirement to consider alternatives to the proposed action, the Board should grant sumary disposition and dis-missal of Contention 7.
P00ROHINAL mm CONCLUS10t1 On the basis of the above, the Staff supports the Licensee's summary dis-position motion regarding Contentions 1, 2 (in part), 4, 5, 6 and 7.
Respectfully submitted, b(:a. NK.JLf Steven C. Goldberg Counsel for NRC Staff Dated at Bethesda, f'aryland this 5th day of June,1979.
444 090
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Dor <et Nos. 50-333 SP VIRGINIA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(Proposed Amendment to Facility (North Anna Nuclear Power Station,
)
Operating License NPF-4 to Permit Units 1 and 2)
)
Storage Pool Modification)
AFFIDAVIT OF ALEXANDER W. DROMERICK I, Alexander W. Dromerick, being duly sworn, state as follows:
1.
I am employed by the U. S. Nuclear Regulatory Commission as a Project Manager, in the Jivision of Project Management, Office of Nuclear Reactor Regulation.
2.
I am the safety project manager assigned to the North Anna Station spent fuel pool modification application.
3.
The Safety Evaluation, dated January 29, 1979, was prepared under my direc-tion and supervision. As stated in our evaluation in support of Amendment No. 8 to the North Anna Power Station Unit i operating license, the 3250 pounds specified as the maximum load permitted to travel over irradiated fuel assemblies in the spent fuel is in error.
The value of 3250 pounds specified in pages 1-4 of the Safety Evaluation should be changed to 2500 which is the upper limit for the weight of the fuel and control rod assem-blies and associated handling tool.
qQQ 09 9 O 6
M 4.
Therefore, with this revisicn, its contents are true and correct to the
. best of my knowledge, and it is hereby adopted as evidence submitted by the NRC Staff in the captioned proceeding.
5.
A statement of my professional qualifications is attached.
I? /
A "U * /
Alexander W. Dromerick Subscribed and sworn to before me this 4th day of June, 1979.
>d ta
/
NotaryjPublic My Commission expires: July 1, 1982
. 444 092
0 ALEXANDER W. DRCMERICK PROFESSIONAL QUALIFICATIONS LIGHT WATER REACTORS 3RN'CH NO. 3 i
DIVISION OF PRCIECT MANAGDiENT I as a Senior Project Manager in Light Water Reactors Branch No. 3 of the Division of Project Management, U.S. Nuclear Regulatory Cocaission.
I as responsible for the evaluation of nuclear safety aspects of nuclear reactor facilities and serve as Project Manager for technical eva.'_uation of power reactor license applications.
I received a Bachelor's degree in Mechanical Engineering with honors frca Polytechnic Institute of Brooklyn, New York, in 1954 In addition, I have tak n graduate ccurses in Engineering Administraticn and have taken special courses in Nuclear Engincering and Stress Analysis.
In 1954, I took a position as an engineer with the Special Products Group of the American Can and Foundry Co=pany (ACF) Industries.
I was responsible for the design of various types of nuclear weapcas developed for the Atomic Energy Co= mission. I spent two years as supervisor of the Stress Ar.alysis Group which evaluated reactor components for various types of nuclear reactors.
In 1957, I was appointed Section Head of the Research and Develop-ment Section for the Expericental Gas Cooled Proj ect.
In this position I was responsible for all R&D work perf ormed by ACF Industries and in eddition was responsible for coordinating R&D progra=s with National Laboratories.
444 0%
~
In 1960, I became Section Head of the Reactor Design of the
~
Atomic Energy Division of Allis-Chalmers Manufacturing Company.
In this position I have had the responsibility of design and analysis of reactor components for various types of nucicar reactors. During this time I became a registered Professional Engineer in the State of Maryland.
O' In Nove=ber 1963, I joined the AFC Division of Reactor Licensing in the Containment and Cc=ponent Technology Branch as the Branch Chief, and I as presently with the Division of Project "anagement as a Senior Project Manager.
In this position, I have the primary responsibility for safety review of the Millstone Nuclear Power Station, Unit 3, the South Texas Project, and the North Anna Power Station, Units 1 and 2.
t 444 094
-e
-w-
UtlITED STATES OF AMERICA
!!UCLEAR REGULATORY COMMISS10t1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket !!os. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(Proposed Snendment to Facility (iiorth Anna Nuclear Power Station,
)
Operating License NPF-4 to Permit Units 1 and 2)
)
Storage Pool Modification)
AFFIDAVIT OF PAUL H. LEECH I, Paul H. Leech, being duly sworn, state as follows:
1.
I an employed by the U. S. fluclear Regulatory Commission as a Senior En-vironmental Project Manager, in the Division of Site Safety and Environ-mental Analysis, Office of Nuclear Reactor Regulation.
2.
I am the environmental project manager assigned to the North Anna Station spent fuel pool modification application.
3.
The Environmental Impact Appraisal, dated April 2,1979, was prepared under my direction and supervision.
Its contents, per the June 1 errata, are true and correct to the best of my knowledge, and it is hereby adopted as evi-dence submitted by the NRC Staff in the captioned proceeding.
4.
A statement of my professicnal qualifications is attached.
h L.
s Paul H. Leech Subscribed and sworn to before me 4
Oc)5 this 4th day of June 1979.
b?jd I t,c<
Notary fublic
/
My Commission expires: July 1,1982
PAUL H. LEECH PROFESSICNAL CUALIFICATIONS ENVIRONMENTAL PR.0JECTS BPJJiCH 2 DIVISION OF REACTOR LICENSING My formal college education was obtained at:
1939-40)
San Jose (California) State College (pre-engineering, University of Colorado, Boulder, Colorado (B.S. degree in Electrical Engineering,1943)
Columbia University, New York City (courses in psychology, world trade literature) y Since graduaticn frcm the University of Colorado, my experience has been predominantly in the application and sale of electrical apparatus, analyzing and reporting technical developments (including nuclear) and mental effects of all types of power plants and pcwer tran distribution systems.
Beginning in 1945, I was employed for 13 years by the General Electric Company in various assignments related to the desig Beginning in 1959, I was employed for eleven years as In this capacity I specialized in the fields of electric industry.
power transmission, system engineering and power generation.
During 1971, I was employed for eight months in the Be In September assurance and environmental effects of nuclear power plants.
of that year I left Bechtel to accept my present position.
In my capacity as an Envircnmental Project Manager, I have had the over responsibility for preparation of the Comission's environmental state-Fort Calhoun ments for s veral nuclear power plant projects, including:
Station near Cmaha, Nebraska; Millstone Nuclear Power Station at Waterford Connectictt; Surry Pcwer Station near Surry, Virginia; North Anna Pcwer Station near Mineral, Virginia; and the Skagit Nuclear Power Project near Sedro Woolley, Washington.
8 e
444 096
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI0tl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(Proposed Amendment to Facility (North Anna Nuclear Power Station,
)
Operating Licens L'aits 1 and 2)
)
Storage Pool Modification)
?
AFFIDAVIT OF PAUL H. LEECH, FRANCIS C. KORNEGA't AND JARED S. WERMIFL ON CONTENTION 1 THERlAL EFFECTS We, Paul H. Leech, Francis C. Kornegay, and Jared S. Wermiel, being duly sworn, state as follows:
We, Paul H. Leech and Jared S. Wermiel are employed by the Nuclear Regulatory Commission in the Division of Site Safety and Environmental Analysis and Divi-sion of Systems Safety, respectively.
Statements of professional q.
cations accompany our affidavits on other issues in this proceeding.
1, Francis C. Kornegay, am employed by the Oak Ridge National Laboratory in the Environ-mental Impact Section of the Energy Division.
A statement of my professional qualifications is attached to an accompanying affidavit.
Contention 1 (Thernal Effects) states:
Intervenor contends that the possible consequences caused by the additional heat to be discharged as a result of the proposed modifications have not been adequately addressed by the NRC Staff and the Applicant.
This contention em-braces the rate ~of temperature rise in the spent fuel storage 444 097
~
. facility as a result of an accidental leak in the spent fuel pool.
It further includes the affirmation that the sper,t fuel pool cooling system will be inadequate to prevent " hot spots" and possible boiling.
I,Jared S. Wermiel, have reviewed p_. agraphs 1 through 53 of "VEPCO's Statement of Material Pacts as to Which There is no Genuine Issue to be Heard" (herein-af ter referrt '
'o in separate Staff affidavits as "VEPCO's Statement of Material Facts") attached 4 May 11, 1979 summary disposition motion, as relevant to Contention 1, and concur in the statements contained therein.
Thermal Effects Intervenor contends that the possible consequences caused by the additional heat to be discharged as a result of the proposed modifications have not been adequately addressed by the NRC staff and the applicant.
The Staff Environmental Impact Appraisal (EIA) dated April 2,1979 indicates in Section 4.2 that the additional heat to be discharged as a result of the modi-6 fications is expected to be a maximum of 5.6 x 10 Btu /hr. This would be dis-sipated to the atmosphere from the service water resersoir (SWR). As described in Section 3.4 of the EIA, the service water, whi.h is used to cool the plant auxiliary systems (including the spent fuel pool), is drawn from and returned to the SWR. Aside from discharges to the waste heat treatment facility (WHTF) via the circulating water discharge canal in emergency situations, the only route for heat from the spent fuel pool (SFP) to reach Lake Anna is in the SWR blowdown. With a nominal blowdown of 50 gpm into the WHTF with a circulating 444 098
. (condenser cooling) water flow of 1,905,000 gpm, the effect of any additional heat due to axpansion of the SFP storage capacity would not be detectable.
As stated in Secti' 4.3 of the EIA, there is provision for discharge of the scrvice water system to the WHTF if the need should arise.
However, the addi-6 9
tion of 5.6 x 10 Btu /hr to the 13.5 x 10 Btu /hr discharged in the circulating water would be an increase of only 0.04%.
This would not have noticeable
?
incremental effects on aquatic biota or tt.' environment.
Dissipation of Additional Heat from the SWR The present heat load on the service water reservoir causes greater evaporation from the water surface than would occur without heating.
This evaporation results in higher water vapor concentrations downwind of the SWR than would normally occur.
Dissipating additional heat from the SWR as proposed by the Applicant will further increase the downwind water vapor concentrations.
To determine the magnitude of this increase, downwind concentrations of water vapor were calculated for typical summer and v Liter conditions for both the present heat load and for the proposed additional heat load.
ComDutational Technique The downwind water vapor concentrations were calculated by the method suggested by Turner,I using disper sion coefficients from the American Society of Mcc.lanical Engineers.
As some of the additional heat load would be dissipated as sensible
_ heat directly to the atmosphere by convection and thermal radiation, the con-servative assumption that all of the additional heat would be dissipated by a44 095f
, evaporation maximizes the downwind increase in water vapor concentrations.
Increases in water vapor concentrations were used to calculate relative humidity increases over ambient and predicted present values.
Ambient conditions were assumed for both summer and winter seasons.
These conditions are realistic values for the North Anna plant site.
Increasing (decreasing) the ambient temperature will decrease (increase) the predicted
?
change in relative humidity.
Varying the assumed ambient relative humidity value will have no effect on the predicted change in relative humidity.
Analysis Ambient Conditions Parameter Summer Winter Temperature 90*F 20*F Relative humidity 70%
80%
Wiyd speed 3 M sec 3 M sec~
~
Atmospheric stability unstable neutral Plume rise 10 M 10 M
'Present Conditions Evaporation 200 gps 150 gpa Proposed Conditions Evaporation 212 gpm
'62 gpm Dispersion Equation
~
444 100 1 rg 2
0 exp X
~ 5(o,)(c,)(u) 2 z,
x,o,o
. where Xx,o,o = concentration of water vapor at downwind distance x Q = vater vapor emission rate in gm sec e = horizontal stability parameter y
o = vertical stability paraceter u = horizontal wind speed in~M sec ~
h = plume rise in M
?
Results Maximum evaporation under present heat rejection rates is anticipated to occur during summer conditions.
Ambient conditions are assumed to be 90 F, with a 70% relative humidity. The operation of the SWR at present heat rejection rates is predicted to increase the water vapor concentration 1000 M downwind of the SWR by 0.08 gm M', which raises the relative humidity by less than 1% from 70%.
Maximum changes in relative humidity values due to present heat rejection rates are anticipated to occur during winter conditions. Ambient conditions are assumea to be 20 F, with an 80% relative humidity. The operation of the SWR at present heat rejection rates is predicted to increase the water vapor concentration 1000 M downwind of the SWR by 0.29 gm M', which raises the predicted relative humidity from 80% to 93%
444 101
. The proposed additional evaporation rate is conservatively assumed to be con-stant at the maximum proposed value throughout the year.
Curing summer, the proposed addition is predicted to increase the relative humidity less than 1/2 of 1%, so that the total predicted increase in relative humidity is from 70% to less than 71%.
During the winter, the proposed addition is calculated to increase the relative humidity from a predicted present level of 93% to 94%.
Due to the assumption of total heat removal by evapo, ration, these numbers are i
highly conservative.
The predicted increases in relative humidity would occur only when the point in question is directly downwind of the SWR.
Increases at locations not directly downwind of the SWR would be substantially less.
The additional evaporation resulting from the proposed increase in SWR heat rejection rate is negligible, and would not be detectable at distances greater than 1 kilometer (about 3,300 feet) from the SWR.
Temperature Rise in Event of Accidental Leak The spent fuel pool is designed to be virtually leak tight.
To accomplish this, the concrete walls of the pool are lined with a welded stainless steel liner. Channels are provided behind the liner seams to provide a means for testing the pool leak tightness prior to plant operation.
This test was com-pleted satisfactorily with no leakage detected.
The lines from these channels are run to a sump which is provided with automatic sump pumps and level indi-cation in the control room.
Since water may enter this sump fron other sources,
. _a visual examination of the channels is required to determine if the liner specifically is leaking.
A44 10~2
. All lines penetrating the spent fuel pool are located above the mininum accep-table water level for the pool. Therefore, their failure will not drain the pool belcw the level required to maintain proper cooling and radiation pro-tection of the spent fuel.
The spent fuel pool is also provided with redundant makeup sources in order to maintain the pool water at acceptable levels, thereby preventing an increase 7
in the pool water temperature.
iiormal water loss will occur from evaporation, and some slight leakage from the pool liner or spent fuel pool cooling pump seals may result over the life of the plant.
Seismic Category I makeup is provided by the boric acid blenders by means of the boric acid transfer pumps in either the Unit 1 or Unit 2 chemical and volume control system.
In addi-tion, non-borated makeup can be provided b y the seismic Category I plant fire protection system.
Either of these makeup sources will adequately main-
.tain the pool water level with the expected evaporation and leakage losses assumed.
" Hot Soots" and Possible Boiling The licensee has provided a stored fuel assembly thermal-hydraulic analysis in his " Summary of Proposed Modifications to the Spent Fuel Storage Pool Associated with Increasing Storage Capacity."
In this analysis, he makes certain conservative assumptions concerning the potential for local boiling at ""
spots" along the stored fuel assemblies.
The licensee concludes that
' for these conditions, the surface temperature of the hottest fuel assembly
__ is below the nucleate boiling temperature, with a resulting bulk pool water 4tj 103
. temperature of 170 F.
Therefore, no local boiling will occur. We have re-viewed the licensee s analysis and assumptions and agree that they are con-servative. We further concur that local boiling will not occur in the pool under the worst storage conditions assumed with the proposed increased spent fuel storage capacity design array. The normal stored fuel temperatures are below those determined in the above analysis.
.y n
a_dk M uelv Paul H. Leech
{
Ml-()
Jared S. Wermiel Subscribed and sworn to before me this 4th day of June, 1979
!% m h
/
Notary;Publ ic
/
My Commission expires: July 1, 1982 444 104
=-
_9_
References 1.
Turner, D.
B., 1970: Workbook of Atmospheric Dispersien Estimates Environ-mental Protection Agency, Research Triangle Park, North Carolina, Office of Air Programs, Publ. No. AP-26.
2.
Reccmmended Guide for the Prediction of the Dispension of Airborne Effluents, 1973: The American Society of Mechanical Engineering, New York, N. Y.
?
444 105 4
Ut41TLD 'i l A l l *i (nr AMLlitCA till(.i l' Alt is t.f.l li. AT o rt Y CCtiM 15 5 I n te lit i OHL l i ll' A l otil t *AFFTY Araf) i I C F t4 *. i tar. f10 A D O in t lie, Mis t. f.es e uf Dockut flus.60-330 SP V Iloit ta i A FIECTRIC Allo POWCR Cu ril' A t4 Y 50-339 LP (Proposed Anies ndinu n t to Fac111Ly (t&o s t il A s i r ve t4 sci sa s-Powu r S t.2 L l uss.
Opu s*a l l eien L i tuesse P4 P F - 4 to Pe t eui t l i ri i t =s I.. r.d 2)
'., t o r o gle Pool Moati fica tion)
AFF10AV1T OF t H,At4C [ $ C,, K(il4.f 4f G,Q 1
Us.sen.ls C.
F o rtie tj ay, b ing duty a wea rsi, statu as follows:
1.
I hen ns..p l oyu d by Lliu Qak Ridge fla ti ona l L. abo ra to ry in thu Cuvironmental
- ettton of the E. n. r j y O l v i s t unt.
1sup.4 c L
?
2.
I prop.a s est
- t. h c pottions of Llic S t a r t' A f f i d a v t t.
on Con t evill on 1 in this proceeding un L i t lud " W i s s i p a t. t o n of Additlosial llu a t.
I' r o u s L.iu
'SWH'."
" Con.pu t a t t osia l Techniqua." asid "Husults."
This information is trues and S e s res r. t to Lieu bust u l' nur knowledge.
/
Cbm_
~
,m cw Iranc1w C.
Kurieugay k.
- worn t.n bu fu ru suo Lli t s 5 sh.c ribud.g rid
's
'r' day ul '/ d e s-l
.c: t if..
'.r e..r -
e
!.n _ t t < <
e fiup a t y Pishite My I'.on na i t, r. i sin unpleua:
e 444 106
=-
9 Professional Qualifications of Francis C. Vornegay fir. Kornegay is a member of the Environmental fluid Dynamics Group of the Energy Division at ORNL.
His training includes atnepheric diversion analysis and meteorology, and be has experience in assessing the air 3
quali ty related impac;5 of various energy technologies.
l' Education Bachelor of Science in ficteorology,1973, Pr te University.
itaster of Science in Atmospheric Sciences, 1975. Purdue University.
/
P':cdc44(enaC Secic Cy berican fieteordogical Society L'eth Expc tience Years Employer Title Pagimen l
1978-Present Oak Ridge National Laboratory Research Associate E n v i rnnmen t a l fluid Dynamics 1978-1978 Argonne National Laboratory Assistant Env.
Env!,encental$
Scientist Fiuld Dynartici 1975-1978 Argonne National Laboratory Scientific Environmontai Assistant Fluid Dynamicj 1973-l975 Furdue University Research Assoc.
tieteorolooy Graduate Instructor g
th6(icatien4, (%c.sentations, mai EnvCicomental Impet Scacement)
Assessing the Air Quality Related Irpacts of Coal Conversion facilitips, Francis C. Kornegay, Symposium on Environmental and Clinatic In' pact of Coal Utiliza tion, IFAORS, April 17-19, 1979.
Will iamst org, VA.
Paper to be included in the Symposium papers.
Presonted a t the Symposium by F. C. Kornegay.
Determination of Dispersion of Small Particles by Natural Vorticos, Francis C. Kornegay, Nornan A. Fricerto, Palph S. S towe, and James E. Ca rson, Preprints, loth Conference on Severe I.ocal 5 terms, A.merican ?'e teornlogical Soc iety Oc tober 17-21, 1977.
Omaha, Nelir a s k a,
pp. 4n3-495.
Paper presented at the Conference by F. C. Mornegay.
Energy Gudget During Interaction of Tropical Storm Canity, 1068, with an Extratropical Cyclone System, Francis C.
Mornogay and H.
J.
Fdmon.
. paper presented by Kornenay at the Ninth Technical Con feronce on liurricane and Tropical t'eteorology, Key Riscayne, Fla., i'ay 19/5.
Sens i tivity of X f netic Ener';y Paraneters to Di r rerent Hor f ont il Vertical Resolutions of Data, Dayton G.
and Mosone teo ro l o gy, L a s Vega s, fla va da, May 19 75.Fcp Xinet h. Enerqy Gudget Analysis During the Candy, (196G) wi th an E.ttra tropical Frontal Sys te~,Interac tion of Trorical Morm i
and Dayton G. Vincent, f'on thly Nea ther Pev iew, Vol. 104, duty 19 /6.
l Francis C.
4:ornegay In the kiake of the tIoterspout, Trancis C. Kornerpy, 'f o r~.? n A.
Trigr-in, and Ralph S. Stowe, accepted for pub 1(cation in The Undersea Jr. 2rna l.
CoptrIson Petw en the NCAR StatistIca) Objec t I ve Analys is Sr. heme and Subjective Analyses in a Limited Region, Thomas J. Schlatter, Francis C. Xornenay, Dayton G. Vincent, Cietrage rur Phys t_k,llocent a t th and "a roir! J. Dfonen, J r.
i der Atr'ospha re, 50.
Ba n d, 1977, Se i t e 'Ti-203, Paper presented by '
e Interna tional Confcrcnce on j
4.1976, llamburg, Gerwny. Simulation of targe-Scale Atnospheric Proces 20- Se;wnb e r l
The Argonne Tcrnado, June 13, 1976.
Invi t ed S igma X 1 Lec tu re, Sac.neter 1976.
Environmental bpact Statements i4UREG Doc ket ';M us Phipps h wi FES 0160 STti 50-55J, 50-G54 Yellow Creet FE3 0365 STil 50-566,30-567 Dear Creek FES 0129 40-8452 Lucky tfc FES 03r7 40-22S9 Moab DE5 0 ", ' 1 40-3453 Swee twa te r DES 0403 40-858d i
Other AfiL Docwents Gulf General Atomic ?!egative Declaration, ST fi License - E96.
(
The Environment.at E f fects of using Coal j
for Genera ting Elec tric ity NMEG-0Z52.
1
{
The Environn*?ntal kpact Assessrent for Co-bust f on C<?mponent Mst and Integra tion fin i t DOC /CA-0014the Pressurired
}i I
Ecological Implications of the Use of Coal Plants, Of fice of Biological Services, U. S.in E10ctric Power Genor.it ion Fish an.i !!iltfl i fe Service.
I kk i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COM:11SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Decket Nos. 50-338 SP
)
50-339 SP VIRGINIA ELECTRIC AND POWER COMPANY
)
(Proposed Amendment to Facility
)
Operating License NPF-4 to Permit (North Anna Nuclear Power Station,
)
Stortge Pool Modification)
Units 1 and 2)
)
AFFIDAVIT OF HARRY E. P. KRUG ON CONTENTION 2: RADI0 ACTIVE EMMISSION I, Harry E. P. Krug, being duly sworn, depose and state:
Contention 2:
Radioactive ~ Emission states:
a.
Intervenor contends that VEPC0 has neglected to address the additional liquid and gaseous radioactive emissions which will result from the increased fuel storage ard the effects thereof. [In CEF's opinion,... apoli-cant's analysis of radiation released, and of possible releases, in the event of those accidents considered in Section 9.1 through 9.4 of the application, are superficial and insubstantial in the Summary of the Proposed Modifications.]
b.
Intervenor contends that the Applicant has failed to analyze adequately the liquid and gaseous radioactive emissions that will result from the proposed increase in fuel storage capacity, and has failed to demonstrate that significant adverse environmental effects will not result from such emissions.
I have reviewed paragraphs 54 through 86 of, "VEPCO's Statement of Material Facts as to Which There is no Genuine Issue to be Heard" attached to its summary disposition motion of May 11, 1979 as relevant to Contention 2(a) and (b) and concur with the statements contained therein.
444 109
. This affidavit addresses additional routine release during normal operation under the proposed modification. The " accidental release" aspects of Con-tention 2(a) will be addressed by a separate Staff member.
The potential offsite radiological enviromental impacts associated with the expansion of the spent fuel storage capacity were evaluated and determined to be environmentally insignificant as addressed below.
Radiation Sources The additional spent fuel which would be stored due to the expansion is the oldest fuel which has not been shipped from the plant.
This fuel will have decayed for at least three years.
During storage of a
the spent fuel under water, both volatile and nonvolatile radioactive i
nuclides may be released to the water from the surface of the assemblies or frem defects in the fuel cladding.
Most of the material released
' from the surface of the assemblies consists of activated corrosion products s
which are not volatile.
The radionuclides that might be released to the water through defects in the cladding are also predominately nonvolatile.
The volatile fission product nuclides of most concern that might be released through defects in the fuel cladding are the noble gases (xenon and krypton), tritium and the iodine isotopes.
The predominance of radionuclides in the spent fuel pool water appear to be radienuclides that were present in the reactor coolant system prior to refueling (which becomes mixed with water in the spent fuel pool during refueling operations) or crud dislodged from the surface of the spent fuel during transfer from the reactor core to the SFP.
During
. and af ter refueling, the spent fuel pool purification system reduces the radioactivity concentrations censiderably.
It is theorized that most failed fuel contains small, pinhole-like perforations in the V
d fuel cladding at the reactor operating condition of approximately 800 F.
The cladding temperature declines rapidly after the reactor is shutdown and the cladding continues to cool in the pool so that its temperature af ter several weeks is relatively low, less than 130 F.
This substantial temperature lowering reduces the rate of release of fission products from the fuel pellets and decreases the gas pressure in the gap between pellets and clad, thereby tending to retain the fission products within the gap.
In addition, most of the gaseous fission prcducts have short half-lives and decay to insignificant lev ~els within a few months.
Experience indicates that there is little radionuclide leakage from Zircaloy-clad spent fuel stored in pools for over a decade.
Operators at several reactors have discharged, stored, and/or shipped relatively large numbers of Zircaloy-clad fuel elements which developed defects during reactor exposures, e.g., Ginna, Oyster Creek, Nine Mile Point, and Dresden Units Nos. I and 2.
Based on the operational reports submitted by licensees and discussions with the operators, there has not be'en any significant leakage of fission products from spent reactor fuel stored in the M0 pool or the NFS pool.
Several hundred Zircaloy-clad assemblies which developed one or more defects in-reactor are stored in the Morris pool without need for isolation in special cans.
Detailed analysis of the radioactivity in the pool water indicates that the defects are not continuing to release significan; quantities of radio-activity.
- i1 Q Q 'a
,a
-t t
.I
. In handling defective fuel, a recent Battelle Northwest Laboratory (BNL) report, " Behavior of' Spent Nuclear fuel in b'ater Pcol Storage:
(BNUL-2256 dated September 1977), 'found that the vast majority of f ailed fue, does not require special handling and stored in the same manner as intact fuel. Two aspects of the defective fuel account for its favorable storage characteristics.
First, when a fuel rod perforates in-reactor, the radioactive gas inventory is released to the reactor primary coolant.
/,
Therefore, upon discharge, little additional gas release occurs.
Only if the failure occurs by mechanical damage in the basin are radioactive gases released in detectable counts, and this type of damage is extremely In addition, most of the gaseous fission products have short rare.
half-lives and decay to insignificant levels between refuelings.
The second favorable aspect is the inert character of the uranium oxide pellets in contoct with water.
This has been determined ie laboratory studies and also by observations of pellet behavior when broken rods are stored in pools.
Radioactive Material Released to, Atmosphere With respect to gaseous releases, the only significant noble gas isotope attributable to storing additional assemblies for a lenger period of time woJ1d be Krypton-85.
As previously discussed, experience has demonstrated that after spent fuel has decayed 4 to 6 months, there is no significant
~
release of fission products from defective fuel.
However, we have con-servatively postulated that an additional 80 curies per year of Krypton-85 be released from the two units when the modified pool is completely filled.
This increase would result in an additional total body dose of less than 0.0002 mrem / year to an individual at the site boundary.
This dose H4 112
. is insignificant when compared to the approximately 100 nren/ year that an individual receives from natural background radiation.
The additional total body dos' to the estimated population within a 50-mile radius of the plant would be less than 0.0005 man-rem / year.
Under our conservative assumptions, these exposures represent an increase of less than 0.1% of the exposures from the plant evaluated in the Final Environmental Statement
- . regarding the North Anna Station, dated April 1973 (FES) for the individual and the population (Table 5.8).
Thus, we conclude that the proposed modifi-cation will not add significantly to radiation exposures or resultant health effects offsite.
Assuming that the spent fuel will be stored onsite fer several years, IoIodine-131 releases from spent fuel as:,emblies to the SFP water will a
not be significantly increased because of the expansion of the fuel storage capacity since the Iodine-131 inventory in the fuel will decay to negligible levels between refuelings.
Storing additional spent fuel assemblies should not increase the bulk U
water temperature during normal refuelings above the 140 F used in the design analysis.
Therefore, it is not expected that there will be any significant change in tne annual release of tritium or iodine from that previously evaluated in the FES.
Most airborne releases from the plant result from leakage of reactor coolant which contains tritium and iodine in higher concentrations than in the spent fuel pool.
Therefore, even if there is a slightly 44k. )
. higher evaporation rate from the SFP, the increase in tritium and iodine released from the plant as a result of the increase in stored spent fuel would not be significantly greater than the amount previously evaluated in the FES for releases from the plant.
If levels of radio-iodine become too high, the air can be routed through charcoal filters for the removal of radiciodine before release to the environment.
(The pjant radiological effluent technical specifications, which are not being changed by this action, restrict the total releases of gaseous activity from the plant, including the SFP.to within regulatory limits.)
Radioactivity Released to Receiving Waters There should not be a significant increase in the liquid release of radionuclides from the station as a result of the proposed modification.
The amount of radioactivity on the SFP filters and demineralizer might slightly increase due to the additional spent fuel in the pool, but this increase of radioactivity would not be released in liquid effluents from the station, as discussed below.
The cartridge filters remove insoluble radioactive matter from the SFP water.
These filters are periodically removed to the waste disposal area in a shielded cask and placed in a shipping container. Any insoluble matter that remains in the SFP water will be too small to be trapped on the filters or not mobile encagh to be taken up in the SFP cooling loops.
e
_7_
The demineralizer resins (which remove some of the soluable radioactive matter through ion exchange) are periodically flushed with water to the spent resin tank.
The water,used to transfer the spent resin is returned to the liquid radwaste system for processing.
If any activity should,
be transferred from the spent resin to this flush water, it would be removed by the liquid radwaste system.
Finally, leakage from the SFP, if any, is collected in the fuel bui7 ding.flfor drain sumps.
This water is transferred to the liquid radwaste system and is processed by the syr tem before any water is discharged from the plant.
(All such releases are limited by the plant radiological effluent technical specifications, which will be unchanged by the proposed modification of the SFP to within regulatory limits.
'f f$
kW>T Harry E. P. Krud d \\
/
a Subscribed and sworn to before me this 1st day of June
, 1979.
tb
(
ds %
4L
[ftaryPublic
/
My Cemn.ission expires: July 1, 1982 444 115
PROFESSIONAL QUALIFICATIONS HARRY E. P. KRUG RADIOLOGICAL ASSESSMENT BRANCH _
DIVISION OF SITE SAFETY AND ENVIRONMENTAL ANALYSIS OFFICE OF NUCLEAR REACTOR REGULATION U. S. NUCLEAR REGULATORY COMMISSION I.
SUMMARY
I joined the U. S. Nuclear Regulatory Commission (NRC) in 1974 as a Project Manager responsible for the management, organization, technical coordination
?
and presentation bef 6re the Advisory Committee on Reactor Safeguards (ACRS),
and Atomic Safety and Licensing Boards (ASLB) of nuclear reactor safety reviews for assigned applications.
I have served as Project Manager for the San Joaquin Nuclear Project, Browns Ferry Unit 3, Hatch Unit 2, Hartsville Nuclear Power Station and the GESSAR 238 Nuclear Island Project and a number of technical review assignments.
In March 1976, I joined the Accident Analysis Branch of the NRC.
My work included the analysis of various postulated internal and external hazards to nuclear power stations with emphasis on aircraft hazards, anticipated transients without scram (ATWS), secondary side accidents and radiation environmental qualification of equipment and coatings.
Special assignments included testifying on plant capacity factors, Mark III drywell testing programs and projections of plant uranium requirements.
Since September of 1978, I have been assigned to the NRC Radiological Assessment Branch where I am responsible for the review and evaluation of environmental reports of existing and proposed nuclear power facilities; including, when necessary, special generic and case-by-case technical analysis and the presentation of the staff findings.
My background includes a B.S. in Marine-Mechanical Engineering (1955) and a M.S. in Nuclear Engineering (1961).
My 22 years of experience includes 4 years of power plant operation and 3 years of radiation methods development.
In 1969 I left Westinghouse Electric Corporation as a Fellow Engineer after 8 years of nuclear reactor analysis and reactor design and shielding methods development and technical project coordination.
In 1974, I completed two years as Supervisor of Nuclear Engineering for Illinois Power Cu.
I am a member of the American Nuclear Society and the American Society of Naval Engineers and the Health Physics Society.
I am a ccmmercial pilot with instrument, single engine land and sea, and multiengine ratings.
I hold a U.S. Coast Guard License as a Merchant Marine Engineering Officer and am a Professional Nuclear Engineer registered in the state of California.
~
kkk
\\\\
N
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0t1IC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-338.SP VIRGINIA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(Proposed Amendment to Facility (North Anna Nuclear Power Station,
)
Operating License NPF-4 to Permit Units 1 and 2)
)
Storage Pooi Modification) 2 AFFfDAVITOFGEORGEB.GEORGIEV, M. D. HOUSTON, AND JARED S. WERMIEL ON CONTENTIONS REGARDING MATERIALS INTEGRITY AND CORROSION We, George B. Georgiev, M. D. Houston, and Jared S. Wermiel, being duly sworn, state as follows:
We are employed by the Nuclear Regulatory Commission in the Division of Operating Reactors.
Statements of our professional qualifications accompanv this affidavit.
This effidavit addresses the following contentions:
Materials Integrity (Potcmac Alliance)
'ervenor contends that increasing the inventory of radio-ve materials in the spent fuel pool will increase the cv rosion of, the stress upon, and resultant problems con-cerning the components and contents of the pool.
The appli-cant has not adequately addressed such potential problems with respect to:
(a) the fuel cladding, as a result of exposure to decay heat and increased radiation levels during extended periods of pool storage; and (b) the racks and pool liner, as a result of exposure to higher levels of radiation during pool storage.
~
444 117
, Corrosion (CEF)
Intervenor contends that there has been ' inadequate examina-tion of the problems that may arise due to a potential incremental increase in the amc.nt of corrosion upon the spent fuel assemblies and racks over the duration of storage of fuel in the pool, including their eventual removal fro'm the pool.
Such problems include, but are not limited to, the ability of the spent fuel pool purification system to remove any potential incremental impurities.
We have read "VEPC0's Motion for fummary Disposition," and "VEPC0's State-ment of Material Facts As To Which There Is No Genuine Issue To Be Heard,"
dated May 11, 1979.
We concur in the statements contained therein relative to the two cited contentions as follows:
Statements Georgiev 127-132 Houston 127-133 Wermiel 78-86, 134 Materials Intearity (a) Fuel Ciadding Integrity:
The contention is concerned with the effect of the increased inventory of spent fuel upon the properties and integrity of the Zircaloy fuel cla.Jding as a result of exposure to decay heat and increased radiation evels. The effect of decay heat will be confined within the individual discharged fuel assembly and its storage cell due to the enclosure de-U sign of the racks.
A temperature limit of 170 F has been established for the pool water while a temperature of 120 F is the generally
~
Lh 1l8 gg yp7
, observed-1/
maximum value in practice.
During reactor operation, the fuel cladding reaches a temperature of 590 F and performs with no apparent problems or limitations at this temperature for periods of 3 to 5 years.
Upon discharge from the reactor, the heat generation within a fuel as-sembly diminishes-2/to 0.2% of its normal in-reactor power in 10 days, 0.08% in 100 days, and 0.03% in one year.
The cladding temperatures are approximately 13 F higher than the ambient water temperatures when first
?
removed to the pool and 1.8 F higher after four years.
On the basis of
~~
water temperature limits for the North Anna storage pool, the storage rack design and past operating history for spent fucl in storage, we conclude that additional decay heat will not affect individual.or.
adjacent fuel assemblies and, thus, will not raise additional safety concerns.
Likewise, the radiation levels within a fuel assembly diminish signifi-cantly when removed from the reactor core.
During power operation, the fast neutron flux, i.e., neutrons with sufficient energy to cause radiation I4 2
damage to Zircaloy cladding, is typically lx10 n/cm /sec.
At discharge, 21 2
the cladding has been exposed to 5.6x10 n/cm for a burnup of 33,000 mwd /tU.
Fuel cladding properties have been studied to an exposure of 1/
A. B. Johnson, Jr., " Behavior of Spent Muclear Fuel in Water Pool Storage,"
BNWL-2256, September 1977.
2/
A. S. Benjamin, D. J. McCloskey, D. A. Powers and S. A. Du,ree, " Spent Fuel Heatup Following Loss of Water During Storage," NUREG/LR-0649, SAND 77-1371, March 1979.
444 119
, 22 2
lx10 n/cm and show no abnormal behavior up to this level.
The neutron 2
flux in the spent fuel pool is calculated to be 1x10 n/cm /sec.
Due to uncertainties and multiplication factors, the flux in the pool will be 5
2 assumed to be lx10 n/sec/cm and all neutrons will be considered to be 9
fast.
At this flux, a period of 10 years would be required to expose the cladding to the study limit noted above.
On the basis of experimental studies with Zircaloy cladding, the low neutron flux in the storage pool and the length of time required to achieve high exposures, we conclude that any additional radiation level in tne North Anna storage pool will have a little if any effect upon stored fuel assemblies.
(b)
Racks and pool Liner:
The material used for construction of the storage racks and pool liner in the " orth Anna facility is Type 304 stainless steel.
The spent fuel storage pool environment consists of high purity demineralized water con-taining boron as boric acid, normally at temperature range of 70 F and a pH range of 4.5 to 6.
Stainless steel has performed satisfactorily in spent fuel pools without significant deterioration being detected over a 15-year period.
The expected corrosion rate of the stainless steel pool liner and the stain-less steel storage racks in the pool environments should be negligible during expected plant life, as reactor internals and stainless steel piping exposed to primary coolant at far higher temperatures demonstrate insignificant effects of general corrosion.
Galvanic corrosion is
~~
444 120 2
, avoided since there is no coupling of dissimilar metals by direct con-tact or an electrical conductor. The construction material for the base structure angle plates, embedment plates, spent fuel liner and spent fuel storage racks is Typa 304 stainless steel.
The increased levels of radiation in the fuel pool will not significantly effect the mechanical / physical properties of the material since altera-tion of microstructure is achieved only by metalingical processes (e.g.,
heat treating, welding fabrication, etc.) or by high levels of fast
~
10 neutron radiation such as those occurring in the reactor vessel, 10 2
n/cm /sec.
The reactor internals which are also fabricated from Type 304 stainless steel have been shown to perform satisfactorily over a 20-year period.
The storage racks and pool liner materials will experience significantly lower levels of irradiation than the reactor vessel inter-nals materials.
Furthermore, tne high fracture toughness of the 304 stainless steel racks would minimize the potential for brittle fracture.
The controls to be imposed upon the fabrication of the austenitic stain-less steel material used in the construction of the spent fuel storage racks satisfy the requirements of Regulatory Guide 1.31, " Control of Ferrite Content of Stainless Steel Weld Metal" and American National Standard Institute (ANSI) Standard N45.2.1, " Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plants." The weldir.g procedures and the welders are qualified in accordance
~~
444 121
, with the requirements of Section IX of the knerican Society of Mechanical Engineers Boiler and Pressure Vessel Code.
Based on the preceding discussion, there is reasonable assurance that the materials used in the construction of the storage racks and pool liner will provide satisfactory performance in service.
Corrosion The corrosion behavior of Zircaloy cladding has been extensively studied ~3/
for reactor application. These studies have been concerned mostly with the metal-water reaction and the oxidation behavior in air.
For spent fuel storage, the following aspects of corrosion have been evaluated ~4/
either by direct observations or extrapolation of the in-reactor behavior to lower temperatures:
(a) Boric acid chemical corrosion, (b) Radiation-induced corrosion (gamma),
(c) Biological corrosion, (d) Stress-induced corrosion, (e) Stress corrosion cracking, (f) Galvanic corrosion, (g) Crevice corrosion, (h) Galvanically-induced hydridino, (i) Pitting corrosion, 3/
D. L. Douglas, "The Metallurgy of Zirconium," International Atomic Energy Agency Vienna, 1971.
4/
See footnote 1, supra.
444 122
, (j) Corrosion behavior at fuel rod defects, and (k) 0xidation corrosion.
Spent fuel storage experience to date has shown that for fuel assemblies stored up to 20 years, significant cladding corrosion by these mechanisms has 5/
not been observedT Galvanic corrosion, as experimentally observed between Zircaloy and aluminum, would not be expected in the North Anna 1 and 2 pool since no aluminum components are present in the pool. Oxidation corrosNon will continue during storage but the rate of oxidation will be greatly diminished due to the lcwer temperatures.
Using the results from experimental studies parformed at 194 F, the calculated oxide layer would be 0.05 to 0.07% of the
-6/
cladding thickness after 100 years. '
Based on the experience to date with irradiated Zircaloy clad fuel stored up to 20 years and the greatly reduced rates for possible corrosion mechanisms due to low temperatures, we conclude that significant corrosion of discharged fue assemblies will not occur.
Spent Fuel Pool Purification System The spent fuel poal provided with a refueling purification system con-taining three pumps, two filters, and a demineralizer, as identified and dis-cussed in Applicant's Final Safety Analysis Report, 59.1.3, and the Staff's
" Safety Evaluation Report Related to Operation of North Anna Power Station, Units 1 and 2" (SER), NUREG-0053, June 1976, 99.1.3.
5/
See footnote 1, suora.
6/
See footnote 1, suora.
Igg 3g Ic.
6 G
. 19.1.3 of the SER follows:
Fuel Pit Cooling and Refueling Purification System The fuel pit cooling and refueling purification system is designed to remove the decay heat generated by the stored spent fuel assemblie's and to maintain the quality and clarity of the water in the spent fuel pit and refueling water storage tanks.
The system is shared by both units.
The cooling subsystem consists of two independent trains, each containing a spent fuel pit cooler and pump.
The cooling trains are designed to seismic Category I require-ments.
The spent fuel pit cooling pumps are powered by separate emergency electrical buse'.
?
Either cooling train can maintain the pit temperature at 140 degrees Fahrenheit or less with a total spent fuel inventory (both units) of 1/3 of a core, and a temperature of 170 degrees Fahrenheit with a total spent fuel inventory (both units) of 1-1/3 cores.
s Assuming that the fuel pit contains 2-2/3 spent cores and one train is out of service, the resulting pit tempera-ture would be 210 degrees Fahrenheit.
Assured maketa can be supplied from the seismic Category I service water system or the seismic Category I fire protection water system (see Section 9.5.1).
The fuel pit piping is so arranged that the pool cannot be inad-vertently drained to uncover the fuel.
We conclude that the system design is acceptable, based on its ccaformance with Criterion 61 of the General Design Criter ia, including provision of decay heat re-moval capability, and with applicable recommendations of Regulatory Guide 1.13 and Regulatory Guide 1.29, including seismic des 19c provisions to prevent un-covering the fuel, and provisions for assured makeup.
The system is designed to maintain the clarity of the spent fuel pool water and reduce its level of radioactivity b'y removing fission products and other impurities from the water.
This includes removal of any materials resulting from corrosion of the spent fuel assemblies or stainless steel racks.
444 124
, The purification system is subject to its maximum load during and just af ter refueling when fuel is being moved, or when larger than normal amounts of defective fuel is stored in the racks.
flormally, only one refueling purifi-cation pump :..:4 filter is expected to be in continuous use. The additional pumps, filter and demineralizer allow further flexibility in system operation by providing increased purification flow and cleanup capability as needed.
The aount of corrosion from the existing spent fuel storage arrangement is
?
expected to increase by a negligible increment, proportional to the proposed additional number of racks and fuel assemblies to be added to the pool, i.e.,
increasing by a factor of apprcximately 2-1/2.
The total amount of corrosion repi esented by the increased storage capability is still negligible, and the present purification system is adequately sized to handle the incremental increase. The amounts of additional corrosion experted should not affect the frequency of changes of tne demineralizer resin or the filters; however, to the extent that corrosion residues may increase, filters and demineralu.er resin beds would be replaced mor- "requently as indicated by the respective monitoring systems.
hbhAC
/
George M Georgiev k& NY M. D. Houston I
W A. N>&'
J Jared S. Wermiel Subscribed and sworn to before me ict <Lxy 9 g :< a, /17 '1
- this
(/,L<Av 444 125
/
'~ J2
? *). *e u
9 -
L.
Tictary Public
/
v My CommissiTn expires: ;*
/, / 7fA
a George B. Georgiev Professional Engineer - California #COR373 Materials Engineering Branch Division of Systems Safety Office of Nuclear Reactor Regulation I am a Senior Materials Engineer in ;he Materials Engineering Branch of the Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission.
In this capacity, I am responsible for safety reviews of materials used in the construction and operation of nuclear power plants.
I obtained a Bachelor Degree in Metallurgical Engineering in 1965 and a Master of Science Decree in Engineering Management in 1978. My professional experience includes 16 years of engineering experience related to the design, eng.'neering and construction of major industrial facilities and nuclear power plants.
I have been employed as a metallurgist or metallurgical engineer by Coasco Services, Inc., Burns and Roe, Inc., and the Ralph M. Parsons Company.
As a project metallurgical engineer my responsibities included corrosion con-trol, failure analysis, approval of material and welding spec fications for the Three Mile Island 2, Forked River, WPPSS 2 and Enrico Fermi 2 nuclear power plants.
I joined the U. S. Nuclear Regulatory Commission in May 1975 and conducted safety reviews concerning materials and fabrication procedures for V. C.
Summer, Yellow Creek, Skagit, San Onofre and E. I. Hatch Unit No. 2 nuclear power plants.
I am the assigned metallurgical engineering reviewer for 24 nuclear power plants.
f2b 9
=+
M. Dean Houston Professional Qualifications In 1953, I received a Bachelor of Science degree in Ceramic Engineering from Iowa State College.
In 1957, I received a Master of Science dogree in Ceramic Technology from Pennsylvania State University.
I joined the nuclear industry in 1961 as a Senior Ceramic Engineer at NUMEC (now Babcock and Wilcox) with responsibilities for the development of uranium-plutonium oxide fuel and fuel fabrication processes for Light Water Reactcrs (LWR) and Fast Breeder Reactors (LMFBR).
I continued with research and development programs involving the mixed oxide fuel at Westinghouse Atomic Power (with Battelle-Northwest), 1964-1966, and at the Battelle Columbus Laboratory, 1966-1972. These studies were concerned with the chemical, physical and electrical properties of reactor fuel material and cladding, both out-of-reactor and in-reactor.
Since June 1972, I have been a Reactor Engineer with the U. S. Nuclear Regulatory Commission.
I have been a member of the Reactor Fuels Section of the Core Performance Branch of Reactor Safety since November,1973.
In my present position, I am responsible for reviewing reactor fuel designs, fuel performance models and the fuel behavior research projects that are directed by Reactor Safety Research (RSR).
444 127
=.
Jared S. Wermiel Professional Qualifications Auxiliary Systems Branch Division of Systems Safety Office of Nuclear Reactor Regulation r
I am a Reactor Engineer in the Auxiliary Systems Branch in the Division of Systems Safety, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission.
In this position I perform technical reviews, analyses, and evalua-tions of reactor plant features pursuant to the construction and operation of reactors.
I received a Bachelor of Science Degree in Chemical Engineering from Drexel University in 1972.
Since 1972 I have taken courses in PWR and BWR System Operation, Reactor Safety, and Fire Protection.
My experience includes seven years with the Bechtel Power Corporation as a Systems Design Engineer engaged in the design of various nuclear power plant auxiliary and balance of plant systems. These have included cooling water systems, water treatment systems and fire protection systems.
I joined the Auxiliary Systems Branch of the Commission in March,1978.
Since joining the Commission I have performed safety evaluations on spent fuel storage facilities for the Virgil C. Summer Nuclear Station, Palo Verde Nuclear Generating Station, Units 4 and 5, Allens Creek Nuclear Generating Station, Byron /Braidwood Stations and Enrico Fermi Atomic Power Plant Unit 2.
I have responsibility for the review of the following nuclear power plant auxiliary systems: new and spent fuel storage, spent fuel pori cooling, fuel handling, service water, component cooling water, condensate storage, ultimate heat sink, instrument air, chemical and volume control, main steam isolation valve leakage control, heating ventilating and air conditioning, fire protection, portions of the main steam system, and auxiliary feedwater.
I am a registered Professional Engineer-in the State of Maryland.
I am an Associate Member of the American Institute of Chemical Engineers.
444 128
}
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION B_E_ FORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-338 SP VIRGINIA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(Proposed Amendment to Facility (North Anna Nuclear Power Station,
)
Operating License NPF-4 to Permit Units 1 and 2)
)
Storage Pool Modification)
AFFIDAVIT OF THOMAS D. MURPHY ON CONTENTION 6: GCCUPATIONAL EXPOSURE I, Thomas D. Murphy, beirg duly sworn, state the following:
Contention 6 (Occupational Exposure) states:
Intervenor contends that the Applicant has not demonstrated that it will prevent the increased occupational radiation levels which will result from the spent fuel pool modifica-tion from leading to occupational doses in excess of those permitted under NRC Regulations.
I have reviewed paragraphs 135 through 156 of VEPC0's Statement of Material Facts as relevant to Contention 6 and concur with the representations con-tained therein.
The licensee plans to perform the modification to the spent fuel pool storage capacity prior to any contact with radioactivity contaminated spent fuel pool storage coolant and shielding water.
If this takes place, there will be no personnel radiation exposure associated with the modification.
In the event that the mcdification takes place after spent fuel is stored in the spent fuel 4.44 129
~
. storage pool, then there will be some radiation exposure to the plant per-sonnel who replace the racks that have been exposed to radioactively contami-nated coolant.
Based on information that we have on exposures to personnel from r.essurized water reactors which already have modified their spent fuel storage pools, we would expect the exposure at the North Anna Power Station, Units 1 and 2, to be less than 20 man-rem.
This installation is expected to be performed only once during the lifetime of the station and, therefore, any resultant exposure would represent only a small fraction of the total man-rem burden from expected occupational exposure.
This small increase in radia-tion exposure will not affect the licensee's ability to maintain individual occupational doses as low as is reasonably achievable and within the limits of 10 CFR 20.
We have evaluated the radiation protection design features to assure that occupational radiation exposures to plant personnel due to the proposed modi-fication will not significantly increase.
Although it is expected that the additional spent fuel in the pool will in-crease the amount of corrosion and fission prodt' cts introduced into the cooling water to some extent, as noted in Section 2.5 of the safety evaluation issued in connection with this action on January 29, 1979, the existing purification system will provide adequate removal of those nuclides to assure that the radiation fields will not exceed 1.5 to 3.00 millirem per hour at waist level at the edge of the pool. We consider there radiation fields and resultant exposures during fuel handling operations to be acceptable.
Additionally, 444 130
- the licensee provided actual radiation field data and radiation exposure data from their Surry Power Station, Units 1 and 2 (Docket Nos. 50-280 and 50-281) which has a spent fuel storage capacity and design similar to that proposed for the North Anna Power Station, Units 1 and 2.
The radiation shield water in the storage pool will provide adequate shielding for the additional fuel elements. Based on operating experience at the Surry Power Station, Units 1 and 2, the exposure of personnel to airborne radioactivity will be within the limits of 10 CFR Part 20.
Accordingly, we conclude that storing additional fuel in the spent fuel pool will not result in any significant increase in doses received by occupational workers and that the radiation protection design is acceptable without change for the proposed nodification.
v t r eo
/
Thomas D. Murphy 0 [
Subscribed and sworn to before me this 4th day of June,1979
.9 LW fotaryPublic
/
My Commission expires: July 1, 1982 444 131 e
PROFESSIONAL QUALIFICATIONS 0F THOMAS D. MURPHY EXPERIENCE e
As a member of the Radiation Protection Section of the Of fice of Nuclear Reactor Regulation, USNRC since February 1973, and as leader of that group since February 1976, I have evaluated the adequacy of radiation protection programs in support of the licensing of commercial nuclear power plants.
I helped develop review programs, acceptance criteria, and solutions to managerial and technical activities associated with those evaluations.
For three years as Chief of the Quality Control Inspection Deparwem.,
at the Electric Boat division of General Dynamics Corporation, I '
managed a group of 200-300 personnel performing electrical, electronic, mechanical, piping and structural inspections and non-destructive test operatims to assure compliance with plan arid procedure requirements for all shipboard and shop work associated with the construction, test and overhaul of nuclear powered sub-marines. As Manager of the Radiological Control Department at Electric Boat, I supervised all radiological safety activities at the Groton shipyard for over four years.
For one year at Allis-Chalmers Manufacturing Company and four and one-half years as a civilian employee of the Army and Navy at Fort Belvoir, Virgir,a and Pearl Harbor Naval Shipyard, Hawaii, I managed audit, techn ical and operational radiological safety functions primarily associated with the construction, operation, test, overhaul and repair of nuclear power reactors.
For two and one-half years I worked as an Assistant Health Physicist on the staff of Brookhaven National Laboratory performing various research, training and monitoring activities.
EDUCATION M.S., Management,1972, Rensselaer Polytechnic Institute, Troy, N.Y.
M.S., Radiological Physics,1957, University of Rochester, Rochester, fl.Y.
B.S., Science,1956, Union College, Schenectady, N.Y..
SPECIAL TRAINING AIF Institub on OSHA Impact on Nuclear Industry,1975 Modern Managae,t and Supervision, USDA,1974
"'nagement by GSjectives, General Dynamics, i9/2 Sta tistical Quality Control Management Institute, Univ. of Conn.,1971 Nuclear Reactor Er:gineering and Operations, Ft. Belvoir, Va.,1964 Criticality Hazards Evaluation, ORNL,1959 Radiological. Defense Officer's Course, OCD,1958 SOCIETIES AND SPECIAL APP 0INTMENTS Health Physics Society; American Nuclear Society; L.rtified by the American Board of Health Physics; Member of the ABHP Pane' of Examiners; present or past member of American National Standards Institute ANS Working Group; ex-officio member of two AIF/NtiSP Task Forces concerned with occupational exposure; and served one year on the Wisconsin State Incustrial Commission
~
Radiation Protection Advisory Council.
444 132 '
yy
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI0t1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-338 SP VIRGIf1IA ELECTRIC AND POWER COMPANY
)
50-339 SP
)
(Proposed Amendment to Facility (North Anna Nuclear Power Station,
)
Operating License NPF ' to Permit Units 1 and 2)
)
Storage Pool "odification)
A'FFIDAVIT OF PAUL H. LEECH ON CONTEf1 TION 7: ALTERNATIVES I, Paul H. Leech, being duly sworn, state the following:
Contention 7 ( Alternatives) st.ates:
Intervenor contends that neither the Applicant nor the Staf' has adequately considered alternatives to the proposed action.
The alternatives which should be con-sidered are:
(a) the construction of a new spent fuel pool onsite; (b) the physical expansion of the existing spent fuel pool; (c) the use of the spent fuel pool at tiorth Anna Units 3 and 4 (including the completion of construction of such pool, if necessary) for storage of spent fuel frcm Units 1 and 2.
I have reviewed paragraphs 157 through 179 of VEPC0's Statement of Material Facts as relevant to Contention 7.
I concur with the statements contained in paragraphs 157-59, 163-64, 166-69, 171-73, and 176-79.
I have no basis to doubt the reasonableness of the raonetary and ti::e estimates contained in paragraphs 160-62, 165, 170, and 174-75.
444 133
~~
. With regard to proffered alternative (a), the construction of a new spent fuel pool (SFP) onsite is feasible but not in time to meet the licensee's need for adJitional storage capacity in 1981 to maintain full core discharge capability or in 1983 cc accomplish refueling.
As stated in paragraph 3 on page 15 of the Staff's Environmental Impact Appraisal (EIA), dated April 2,1979, we estimate that at least five years would be required for completion of an independent fuel storage facility (ISFSI), wh_ich could be constructed on the site.
Item V'
2b of Table 1 of the EIA lists the costs and benefits of this alternative.
~
As indicated, this alternative offers no environmental or cost advantage over the proposed SFP modification.
With regard to proffered alternative (b), physical expansion of the cxisting spent fuel pool is not a feasible alternative since the pool is bounded on all four sides by structures nacessary to operation of Units I and 2.
The struc-tures on one side of the pool would have to be relocated in order to increase the size of the pool and this work would have to be done with no spent fuel in the pool. The florth Anna spent fuel could probably be stored at the Surry tiuclear Power Station until 1983, as discussed in EIA Section 6.3, but one or both units would probably al.o have to be shut down during part of the con-struction. Consequently, one or both units would not be available to meet system load requirements during some portion of the time required for this effort.
The licensee states in Section 4.9 of the May.11,1979 amendment to its' license modification application (amended application) that "the work, time, and money
. involved including the moving of the structures on any side of the fuel pool would be in excess of building a new spent fuel pool." Transportation costs of $2,000 to $4,000 per spent fuel assembly stored at Surry would be incurred (36.3 of the EIA) and replacement electricity would cost about $250,000 per day for each unit shut down (EIA, 66.6).
In view of the greater construction effccts involved with this alternative, i
the lack of generating capability of one or both units during a portion of the construction time, and the necessity for transporting spent fuel to storage elsev nere, the staff concludes that the environmental impacts would clearly be greater than those of the proposed SFP modification.
With regard to proffered alternative (c), the use of the spent fuel pool at North Anna, Units 3 and 4, is not a feasible alternative since this facility will not be available in time to meet the licensee's need for additional storage capacity in 1981 to maintain full core discharge capability or in 1983 to ac-complish refueling.
fMither unit is expected to be completed before the mid-1980's and it would be difficult to utilize the spent fuel pool alone because of its dependence on the service watcr and component cooling water systems which will run throughout the facility (Amended Application,14.10).
- Lacking availability of the spent fuel pool at Units 3 and 4 in time to prevent shutdown of Units 1 and 2 would require shipment cf the excess spent fuel to e
444 135
~
_ 4-other storage facilities as discussed in 556.2 and 6.3 of the EIA.
Conse-quently, this alternative does not offer an environmental or cost advantage over the proposed action.
Q:
- sr~
Paul H. Leech Subscribed and sworn to before me this 4th day of June,1979.
t
/
),
l
. ifM WAH}
ff Notary Public
/
My Commission expires: July 1,1982 444 136
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.'.! MISSION BEFORE THE, ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Docket Nos. 50-338 SP
)
50-339 EP VIRGINIA ELECTRIC AND POWER COMPANY )
(Proposed Amendment to Facility
) Operating License NPF-4 to Permit (North Anna Nuclear Power Station,
)
Storage Pool Modification)
Units 1 and 2)
)
CERTIFICATE OF SERVICE y
I hereby certify that copies of "NRC STAFF RESPONSE TO VEPC0
SUMMARY
DIS-POSITION MOTION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, tnrough deoosit in the Nuclear Regulatory Commission's internal mail system, this 5th day of June,1979.
s Valentine B. Deale, Esq., Chairman Mr. Irwin B.
Kroot Atomic Safety and Licensing Board Citizens' Energy Forum 1001 Connect: cut Avenue, N. W.
P. O. B ox 138 Washington, D. C. 20036 McLean, Virginia 22101 Mr. Ernest Hill James B. Dougherty, Esq.
Lawrence Livermore Laboratory Potomac Alliance University of California 307 lith Street, N.E.
P. O. Box 800, L-123 Washington, D. C. 20002 Livermore, California 94550 Anthony J. Gambardella, Esq.
Dr. Quentin J. Stober Office of the Attorney General Fisheries Research Institute 11 South 12th Street, Suite 308 University of Washington Richmond, Virginia 23219 Seattle, Washington 98195 Atomic Safety and Licensing Michael W. Maupin, Esq.
Board Panel
- Hunton & Williams U.S. Nuclear Regulatory Commission P. O. Box 1538 Washington, D. C.
20555 Richmond, Virginia 23212 444 137
. Atomic Safety and Licensing Appeal Panel (5)*
U.S. I;uclear Regulatory Commission Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U.S. !'uclear Regualtory Commission Washington, D. C. 20555
/.bw 4:' l'~/
Steven C. Goldberg Counsel for NRC Staff s
444 i38
.