ML19241B194
| ML19241B194 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/14/1979 |
| From: | Christman J HUNTON & WILLIAMS |
| To: | |
| References | |
| NUDOCS 7907130082 | |
| Download: ML19241B194 (8) | |
Text
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May 14, 1979 NRC PDJ;r'IC DOCU3!LNT ROOM 6,
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UNITED STATES OF AMERICA Si.'J g d NUCLEAR REGULATORY COMMISSION f
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket Nos.50-338SP VIRGINIA ELECTRIC AND POWER COMPANY 50-339SP
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Proposed Amendment to (North Anna Nuclear Power Station
)
Operating License Units 1 and 2)
)
NPF-4 p:FCO'S ANSWER TO NOTICE OF HEARING 1.
The atomic safety and licensing board designated for this proceeding (the Board) has issued a Notice of Hearing dated May 4, 1979.
The applicant, Virginia Electric and Power Company (Vepco), makes this answer to that Notice pursuant to the Commis-sion's regulation 10 CFR S 2.705.
2.
The nature of Veoco's cosition.
Vepco't osition is that the proposed amendment to Facility Operating License No.
NPF-4, which would permit an increase in the fuel storage capacity of the North Anna 1 and 2 spent fuel sto age pool from 400 to 966 fuel assemblies, should be issued.
Vepco contends tb istal-lation and use of the high-density spent fuel storage _mtks at issue in this proceeding will be in conformity with the license amendment application, as amended, the provisions of the Atomic Energy A,at of 1954, as amended, and the rules and regulations of tne Cc mission; that there is reasonable assurance that the in-
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. stallation and use of the high-density racks ccr be done without endangering the health and safety of the public and in compliance with tae regulations in 10 CFR Part 50; and that the issuance or the license amendment will not be inimical to the health and safe-ty of the public.
Vepco further contends that the installation and use of the h;gh-density spent fuel storage racks will have an insignificant effect on the quality of the human environment and chat the issuance of the proposed amendment is -,e a ".iaj or C-mission action significantly affecting the quality of the human environment."
In short, Vepco contends that the issuance of cn.
proposed amendment will be in full compliance with the Atomic Energy Act of 1954, as amended, the Commission's rules and regu-lations, and the National Environmental Policy Act of 1969.
3.
Specification of issues.
The contentions at issue in thic proceeding were set out in the Board's " Order Granting In-terventLon, Providing for a Hearing and Designating Contentions of Intervenors," dated April 21, 1979.
The items in those con-tentions that Vepco controverts and those that it does not con-trovert are the following:
a.
Thermal Effects (CEF).
Vepco denies that the possible consequences caused by the additional heat to be discharged as a asult of the proposed modifications have been adequately addressed by the NRC Staff and the not Applicant.
Vepco asserts that the possibility of an ac-cidental leak in the spent fuel pool is extremely small and that,even were such a leak to oc;ur, the consequences, 515 344
. including the rate of temperature rise (if any) in the spent fuel storage facility, would not be inimical to the public health and safety.
Vepco denies that the spent fuel pool cooling system will be inadequate to prevent " hot spots" and possible boiling.
b.
Radioactive Emission (CEF).
Vepco denies that Ic has neglected to address the additional liquid and gasecus radioactive emissions which will result from the increased fuel storage and the effects thereof.
Vepco denies that its analyses of radiation released, and of possibla releases, in the event of those accidents con-sidered in Sections 9.1-9.4 of the application are super-ficial and insubstantial in the Summary of the Proposed Mocifications.
Vepco denies that it has failed to analyze adequately the liquid and gaseous radioactive emis-sions that will result from the proposed increase in fuel storage capacity, and Vepco denies that it has failed to demcnstrate thct significant adverse environmental ef-fects will not result from such emissions.
c.
Miscile Accidents (Potomac Alliance)
Vepco denies that the proposed modification of the spert fuel pool will materially increase the consequences of an ac-cident involving missiles, and Vepco contends that it has demonstrated that the pool, as modified, will withstand such accidents within the limits set forth in NRC Regulations, d.
Materials ITtecrity (Potomac Alliance)
Vepco gr 53 515
. denies that increasing the inventory of radioactive materials in the spent fuel pool will materially increase the corrosion of, the strass upon, and resultant problems concerning the components and contents of the pool.
v pco contends that it has adequately addressed e
such potential problems with respect to (1) the fuel cladding, as a result of exposare to decay heat and in-creased radiation levels during extended periods of pool storage, and (2) the racks and pool liner, as a result of exposure to higher levels of radiation during pool
- storage,
- e. Corrosion (CEF).
Vepco cenies that there has been inadequate examination of the problems that may arise due to a potential incremental increase in the amount of corrosion on the spent fuel assemblies and racks over the duration of storage of fuel in the pool, including their even.al removal from the pool.
Vepco contends that the spen fuel pool purificatiot, system will be fully capable of removing any potential incre-mental impurities.
Vepco further contends that a poten-tial incremental increase in the amount of corrosion upon the spent fuel assemblies will not give rise to any pro-blems that cannot be adequately dealt with by existing plant systems or to any conditions that will be inimical to the public health and safety.
f.
Occupational Exposure (Potomac Alliance) 515 346
. Vepco contends that it has demonstrated that it will prevent any increased occupational radiat_sn levels that may result frea the spent fuel pool modification from leading to oc :upational doses in excess of those per-mitted under NRC Regulations.
Vepco contends that oc-cupational exposure is not an admissible contention in this proceeding but requests that the Board mcke findings on it all the same so as to create an adequate record for review.
g.
Alternatives (Potomac Alliance)
Vepco denies the Potomac Alliance's contention that neither Vepco nor the NRC Staff has adequately considered alternatives to the proposed action.
Vepco contends that the alternatives to the proposed action are inferior to the proposed ac-tion, including the following alternatives:
(1) the con-struction of a new spent fuel pool onsite, (2) the physi-cal expansion of the existing spent fuel pool, and (3) the use of Lae spent fuel pool at North Anna Units 3 and 4 (including the completion of construction of such pool, if necessary) for storage of spent fuel from Units 1 and 2.
4.
Participation in Hearing.
Vepco proposes to appear at the public hearing and present evidence, if a public hearing is held.
5.
Vepco believes, however, that no public hearing will be necessary in this proceeding, because all of the contentions are subject to summary disposition under the Commission's regu-lation 10 CFR S 2.749.
Vepco filed a motion for summar~ disnosi-
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347
. tien on May 11, 1979, and will supplement that motion, with the Board's permission, if it becomes necessary to do so.
6 The Board's Order of May 4 says that the Board is amenable to a motic.
' reschedule the hearing at a later date for good cause shown.
Vepco appreciates the Board's efforts to accommodate the wishes of the parties in this manner.
At this time, however, Vepco is opposed to any delay in the hearing schedule.
Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY
/s/ James N.
Christman James N.
Christman Of Counsel Michael W. Maupin James N.
Christman James M.
Rinaca Hunton & Williams P.O.
Box 1535 Richmond, VA 23212 DATED:
May 14, 1979 515 348
CERTIFICATE OF SERVICE I certify that I have served a copy of Vepco's Answer to Notice of Hearing on each of the persons named below by first-class mail, postage prepaid.
Sectetary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Chief, Docketing & Service Section Valentine B.
Deale, Esquire 1001 Connecticut Avenue, N.W.
Washington, D.C.
20036 Dr. Quentin J.
Stober Fisheries Research Institute University of Washington Seattle, Washington 98195 Mr. Ernest E. Hill Lawrence Liverr, ore Laboratory University of California Li vermore, California 94550 Mr. Irwin B.
Kroot Citizens' Energy Forum, Inc.
P.0 Box 138 McLean, Virginia 22101 James B. Dougherty, Esquire 307 Eleventh Street, N.E.
Uashington, D.C.
20007 Gloria M. Gilman, Esquire 1508 28th Street, N.W.
Washington, D.C.
20007 Steven C. Goldberg, Esquire U.S.
Nuclear Regulatory Commissic Washington, D.C.
20555 515 349
. Anthony J.
Gambardella, Esquire Office of the Attorney General Suite 308 11 South Twelfth Street Richmond, Virginia 23219 Atomic Safety and Licensing Board Panel U.S.
Nv.: lear Regulatory Commission Washin; ton, D.C.
20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 By
/s/ James N.
Christman James N.
Christman Counsel for Virginia Electric and Power Company DATEC:
May 14, 1979 515 350