ML19241B380
| ML19241B380 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 06/04/1979 |
| From: | Roisman A National Resources Defense Council |
| To: | |
| Shared Package | |
| ML19241B379 | List: |
| References | |
| NUDOCS 7907160287 | |
| Download: ML19241B380 (57) | |
Text
.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of
)
)
DUKE POWER COMPANY
)Dkt. No. 70-2623
)
(Amendment to Operating License SNM-1773 )
for Oconee Spent Fuel Transportation and )
Storage at McGuire Nuclear Station)
)
NATURAL RESOURCES DEFENSE COUNCIL STATEMENT OF FACTS WHICH ARE DISPUTED ON STAFF MOTIONS FOR
SUMMARY
DISPOSITION Contention I With respect to the specific listing of indisputable facts, the Staff's recitation of the Commission policy statement, either verbatim or by summary, is not acceptable.
That document speaks for itself.
Thus, facts 1-10 should be rejected.
We agree the Commission statement exists and until it is overturned by a court it is legally binding here.
Facts 11 and 12 are legal conclusions,which we dispute.
Fact 13 is erroneous since reracking of Oconee Units 1 and 2 will extend FCR life through May 1982 and use of spent fuel casks would also extend the FCR availability.
Affidavit of Arthur Tamplin (II).
Facts 14 and 15 confirm the reracking availbility, and we agree with them.
We accept Fact 16.
The first sentence of Fact 17 as werded is acc 7 table, but the second sentence is a legal conclusion and disputed.
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2 Fact 18 is disputed because a short term solution does not address the problem as we define it.
Fact 19 is a legal conclusion and speculates on Commission motives.
The Commission statement speaks for itself.
Fact 20 is disputed because a proper interpretation of 10 CFR S 20.l(c) could require retention of an FCR and use of shipping casks could obviate the need to keep an FCR in the spent fuel pool.
Fact 21 is a legal conclusion and disputed.
Fact 22 is a legal conclusion and disputed.
Fact 23 is a legal conclusion and disputed.
Fact 24 is correct through the first 14 words, but the remainder is disputed.
Fact 25 is not disputed.
Fact 26 is disputed.
The public will be harmed if the proposal is approved without the careful evaluation required by law.
Fact 27 is disputed as a distortion of our position.
Fact 28 is disputed en too many grounds to list.
Fact 29 is disputed as concrary to the Cg-mission state-ment en interim spent fuel storage and is also a legal conclusion.
Contention 2 Fact 1 is disputed because it is a legal conclusion.
Fact 2 is not disputed.
Fact 3 is disputed primarily because of the failure to view the entire cascade program.
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3 Fact 4 is not disputed.
Fact 5 is not disputed and not relevant.
In Fact 6, the first sentence is not disputed.
The second sentence is disputed.
Fact is 7 is disputed because " negligibly small" is meaningless.
Fact 8 is disputed.
Fact 9 is disputed.
Fact 10 is disputed because there is no quantitative value placed on "unlikely" but it is agreed scr.e accidents were postulated and evaluated.
Fact 11 is disputed because " insignificant" is not quantitative, there is no evidence that the range of accidents examined is sufficiently extensive and the detectability of accident consequences depends upon the nature of the devices used to measure those consequences.
Fact 12 is disputed as not being ccmprehensible.
The mere use of 270 days cooldown does not guarantee that all possible impacts will be negligible or that all worker and public exposures will be ALARA.
Contentien 4 Fact 1 is not disputed if it is limited to the specific application new pending.
Fact 2 is disputed.
At best this spent fuel shipment will not be better than other routine spent fuel shipments of 270-day-old fuel.
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4 Fact 3 is disputed because " insignificant" is not quan-tified.
Fact 4 is disputed because " negligibly small" is not quanitfied, comparison with background doses is not legally relevant and the dose calculations are not properly verified.
Fact 5 is disputed.
Any radiation exposure is potentially harmful and is not insignificant to the person receiving it.
Fact 6 is disputed.
Any radiation exposure is potentially harmful and is not insignificant to the person receiving it.
Fact 7 is not disputed.
Fact 8 is disputed because the "unlikely" is unquanti-fied and it is not established that a worst case was identified.
Fact 9 is not disputed.
Fact 10 is disputed because the comparison to background is not a relevant basis for judging the severity of the con-sequences.
Fact 11 is disputed for the same reason as Fact 10 but the fact that using the SEIR model produces a less in quantity and no different in kind effect than natural background is not disputed.
Fact 12 is disputed because the proposed action does not ecmply with ALAFa.
Fact 13 is disputed both as to the public and workers, including the imprecision of the term negligible.
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5 Fact 14, sentence 2, is disputed for the reasons discussed in more detail elsewhere in our filings.
Fact 15 is disputed as irrelevant because average exposures are not relevant and because the Nehemias chart does not purport to include all spent fuel pool modification.
Fact 16 is disputed because the data relied on is selected spent fuel modifications and the quality and nature of measuring devices and procedures are not given.
Fact 17 is disputed.
Fact 18 is disputed as to the second sentence because the quantity of reduction is not "very minor" particularly to the persons involved.
Fact 19 is disputed as being an irrelevant comparison and without a factual basis for the assumptions that the workers who get the spent fuel storage doses are getting the average occupational dose-or-not.
Fact 20 is disputed as to each sentence because the comparisons are meaningless and the " negligibly small" phrase is not quantitative.
Centention 5 Fact 1 is disputed.
The record is insufficient to conclude whether FCR is needed for environmental or health and safety reascns.
Fact 2, sentence 1, is not disputed.
Sentence 2 is disputed as speculative and the Commission statement speaks for itself.
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6 Fact 3 is disputed.
Fact 4 is not disputed.
Respectfully submitted,
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. /. s knthony Z. Rofs' man Natural Resocrces Defense Council 917 15th gtreet, N.W.
Washington, D.C.
20005 (202)737-5000 Dated:
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION In The Matter of
)
)
DUKE POWER COMPANY
)
Dkt. No. 70-2623
)
(Amendment to Operating License SNM-1773 )
for Cconee Spent Fuel Transportation and )
Storage at McGuire Nuclear Station)
)
AFFIDAVIT OF ARTHUR R.
TAMPLIN (II)
City of Washington
)) ss:
District of Columbia )
Arthur R. Tamplin, being first duly sworn, hereby deposes and says:
1.
The description of my conversation with Morton B.
Fairtile contained on page 5 of NRDC's Response to Staff Motions for Summary Disposition is true and correct to the best of my personal knowledge.
2.
The BEIR Committee and most radiation health physicists agree that it must be assumed tnat there is no safe level of radiation and even very small doses mus be assumed to be har=ful.
All above statements are true and correct to the best of my kncwledge.
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j Arthur R.
Tamplin<
Signed and sworn to before me this 4th day of June 1979.
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arr:saas r >==a m memarrxwwm EXHIBIT A t
'h hi t,...mb.r 29, 1978 Mr. K. S. Canady Attention:
Mr. K. R. Wilson
Subject:
Oconce Nuclear Station Unit 1 and 2 Spent Fuel Modification File No. OS 514.27
Reference:
Letter Dated December 18, 1978, Mr. K. R. Wilson to
~
Mr. H. T. Snead, Same Subject as Above This letter should serve to provide you with the information requested in the subject letter to be used in the preparation of the licensing submittal. In response to your request for a schedule of refueling dates, a t te.c hment 1 to this letter shows our current best esti= ate of the re-fueling dates for the three Oconee units through 1981.
If the planned pool expansion were not to occur and, assuming that no off-site fuci shipments were allowed and, further, if all non fuel items now in place at the Oconce pools were to re=ain, the station would lose full core discharge capability in May, 1979. If all non fuel items now at the Oconee pools were removed, the station would lose full core discharge capabili:y in November, 1979.
In either case, wie.hout the pool expansion and assuming no offsite shipments, the Oconee units sould be unable to refuel in 1981. Thus, unit I would be forced to shut down in April, 1981,.ni: 2 in May, 1981 and unit 3 in August, 1981.
Assuming that no offsite shipment of fuel is allowed and assuming that the current planned uni: 1 and 2 pool modification were ecmpleted, :he station full core discharge capability would be lost for a short time during :he reracking operation but would be regained with :he installa:icn of the new
=odules. Af:cr the completion of the modification, Cconee would lose 1:s full core discharge capability in mid 1982 and :he Oconee units would be forced to shut down due to lack of pool space during their respective refueling outages in 1984 This schedule does not include consideration of removal of all non fuel 1: ems now in the pool, because these 1: ems would have to be removed the accomplish the planned modification.
At tac hment 2 will provide you with the proposed schedule for reracking f
eperations. It is our opinion that :he proposed schedule does not preclude the installation of poison type storane racks. Our informntion does indicate, however, that the selection of poison type storage racks would require the modification to be performed in two phases, one phase 3
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Mr. K. S. Canady December 29, 1978 to be completed prior to the unit 1 and 2 refuelings in late 1979 and the necon.! ph me to be completed in 1980, af ter the completion of these refueling ontanes. Thus, the process of modification of the fuel pool would be greatly exteneled. TE sverriding consideration in selection of the racks, however, vu tho
.an of the Stcam Production Licensing Section that the selection racks would greatly increase the probability of licensing delays, which would in turn postpone the date at which modification wcrk could be dune.
In light of the fact that some nodification work must be completed prior to the unit 1 and 2 outages in 1979 or else no type of modification would be pussible due to the number of assemblies in the pool, it was decided that the selection of a high density non-poison type rack provided the best chance of completion in the required time.
With respect to your request for cost estimates, the estimated total project cost for the reracking of the unit 1 and 2 pool with the non poison high density racks is $2,985,000.00. A cost estimate for the poison rack option is not readily available since firm proposals for this type of rack were not solicited, but our information at hand suggests that the cost of pursuing the poison rack option would have been somewhat higher.
Regarding the cost and availability of reprocessing facilittua, Duke has a reprocessing contract with Allied General Nuclear Services, hcvever, their facility at Barnwell, South Carolina does not h.ve an NRC license to reprocess or store spent fuel.
Regarding your request for information on cost of shipment, the most recent estimate of truck shipment cost from Oconee to McGuire in 1979 dollars would be $2,102.00 per shipment. Our best estimate for cost of truck shipment frco Oconee to Catawba in 1982 dollars would be $2,450.00 per shipment. This estimated cost per shipment to Catawba assumes that the labor charges and standing charges will be the same as those arrived at for ship =cnt to McGuire and that the only difference in cost will be the reduced mileage charge due to the shorter distance f rem Oconee to Catawba versus McGuire. The current best estimate date for the availability of the Catawba 1 spent fuel storage pool is June,1981.
I hope that this information will satisfy your needs in preparing the licensing submittal, however, if you have any further questions or if I can be of any assistance, please call.
- /7 William R. McCollum Associate Engineer Core Performance WRMe:mo CC:
Mr. R. M. Clover (w/a)
Mr. H. T. Sncad (w/a)
Mr. D. C. Holt (w/o att) s ' [G 1
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ATTAClIMENT 1 OCONEE NUCLEAR STATION FIANNED REFUELING OUTAGES THROUCll 1981 Oconec 3 - June 1, 1979 - July 20, 1979 Oconee 1 - December 1, 1979 - January 17, 1930 Oconee 2 - January 25, 1980 - March 10, 1980 Oconee 3 - July 6,1980 - August 24, 1980 Oconce 1 - April 2, 1981 - May 17, 1981 Oconee 2 - May 25, 1981 - July 11, 1981 Gennec 3 - August 10, 1981 - September 28, 1981 o
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The design mix of fuel, based on out-of-core storage time, is also shown on Fig. 7.
The quantity and previou,s storage history of the spent fuel are based largely on engineering judgment.
These parameters have been discussed with several utilities and are believed to be generally acceptable and conservative.
To provide a
degree of flexibility,
- however, the arrangement of the facility permits doubling the storage capacity either by doubling the pool length early in the detailed design or by adding a parallel pool of the same size at a later date.
Fig. 8 shews an isometric view of the facility.
There are three prinary areas, the rail bay area, the spent fuel storage pool
- area, and the auxiliary equipment area.
Fig. 9 through 13 show plan and elevation views of the facility.
The facility yard grade plan view is shown in Fig.
9.
The spe.nt fuel pool bottom is approximately 25 ft below yard grade so that the spent fuel racks and spent fuel are located below yard grade.
The fuel storage area is considered the only nuclear safety-related portion of the facility.
The fuel pool and fuel pool structural enclosure above grade are the only portions of the facility which must be designed to meet Seismic Category I requirements.
The pool width was determined based on standard fuel handling platforms which have been seismically qualified by the major NSSS ::unufacturers.
A specific fuel rack design has not been developed.
High-density racks of the flux trap type have been assumed for this facility for arrange:nent and storage purposes.
Poison type racks could also be provided.
In either case, rack selection would he based on the owner's requirements and competitive. bidding.
A separate spent fuel shipping cask area is provided adjacent to the pool.
The location of this cask area in the rail bay precludes travel of the 130 ten cask handling crane over any portion of the spent fuel storage pool.
Various fluid and electrical system components occupy most of the remainder of the facility in the auxiliary equipment area at the yard grade elevation.
Other key areas at the grade elevation include the security station, health physics, locker room
- areas, and the facilities monitoring area.
Additional system components are located in the auxiliary equipment area at El 15 ft (Fig. 10).
The largest components are the demineralized water tank and fuel pool cooling water heat exchangers.
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FACILITY SYSTEMS AND I ?TTERFACES 7.
list of the systems incorporated in the ISFSF is given in Fig. 14 Consistent with the objectives for the design of the
- facility, most of these systens have been incorporated in the facility.
Existing parent plant
- systems, however, have been utilized while considering the universal siting criterion.
Major f acility systems are described in the following paragraphs.
The cooling water system removes heat from the fuel pool cooling system and ventilation condensing units.
Major system components include two half-size pt=ps 'and a mechanical draft cooling tower.
We fuel pool cooling system maintains the fuel pool temperature at 120 F or less with the design basis heat load of approxi:nately 30 x 106 Btu /hr.
Principal system components include two half-size pumps and two half-size heat exchangers.
DE. fuel pool purification system maintains purity and Clarity of the fuel pool water.
It removes suspended and dissolved radionuclides.
It is capable of filtering and purifying the fuel pool in 24 hr.
Principal system components include two full sire pu=ps, two filters, and a mixed bed de:nineralizer.
The facility heating, ventilation, and air conditioning systems limit temperatures in the pool area and equipment cubicles to less than 104 F.
Of fices and the facility monitorin : areas are maintained at approximately 75 F and a relative humidity below 50 percent.
Principal components include two 50 percent air conditioning and condensing units for the auxiliary equipment area.
Three supply fans and three exhaust fans are provided for the rail bay and pool areas.
A HEPA filter is provided. in the event high radiation is detected.
Either truck or rail spent fuel storage casks can be accommodated in the facility.
A 130-ton capacity cask handling crane moves the cask to the cask pool after approoriate inspections and initial cask cleanup.
The cask head is removed, and the spent fuel is moved from cask to the spent fuel racks by the fuel nunipulator platform.
A fuel cask decontamination area is provided adjacent to the rail bay.
Although the facility arrangement is based on a wet cask handling system, a dry cask handling system could be accommodated with minimal structural modifications.
A summary of the principal interfaces between the ISFSF and the parent plant is shown in Fig. 15.
Engineering evaluations will be made to assure that interf aces result in mini:aal impacts on the parent plant.
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Solid waste consists primarily of spent resins which are sluiced into a cask at the spent fuel storage facility.
After removal of excess water from the
- cask, it is transported to the parent facility for solidification.
Approximately 60 cu ft of such resin is expected annually.
Liquid waste generated in the facility is stored initially in waste tanks located within the facility.
The contents of the then pumped to the parent plant for batch processing.
tanks are Less than 25,000 gal per year are expected to be processed by the parent plant.
A seismically qualified source of makeup water of approximately 100 gpm should be available from the parent f acility.
The fire protection system should be capable of providing approximately 1,300 gpm for a minimum duration of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for the f acility fire protection system.
Electric power estimated at 1,000 kVA (total for two sources) is required for the facility.
This power is expected to come via the two parent plant off site power sources.
Direct extensions of portions of the parent plants communications systems and security systems for the f acility are also assumed.
SCHEDULE A cceprehensive schedule for the licensing, design, equipment procurement, and construction of the facility is under development.
The total duration for the schedule is expected to be 3 to 4 years from engineering authorization to completion of preoperation testing.
The duration will be governed largely by the procurement and delivery cycle for the spent fuel pool liner and cask handling crane, both of which are currently projected to require a 2 year period.
As mentioned
- earlier, the principal schedule benefits of-the facility accrue from the use of an existing nuclear power plant site and an NRC approved design based on a topical report.
These savings are conservatively estimated at 12 to 18 months.
SUmARY One method of providing additional spent fuel storage capacity is by means of an interim spent fuel storage facility (ISFSF) at an existing nuclear power plant site.
A preapproved design based on a topical report should minimize the licensing time for such a
facility.
The facility design is based on approximately seven F.2 cores or twelve full Ps2 cores of spent fuel. This stor:go capacity could be doubled with =inimal impact on the facility arrange =ent.
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The ISFSF is nominally an independent facility, but it uses existing parent plant systems and personnel to ministize cost where possible consistent with a near universal siting criteria.
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p FOR RELEASE:
Immediate Boston, July 26 --
Stone & Webster Engineering Corporation announced today that it has received a notification of acceptance from the Nuclear Regulatory Commission (NRC) for its standard design of an interim This is the facility to store spent fuel from nuclear power plants.
first design of such a facility to be submitted to the NRC for pre-licensing.
It can be utilized for installations at almost all existing nuclear sites.
The nation's utilities f ace a growing shortage of spent-fuel storage capacity because of the Administration's deferral of reprocessing of spent f uel f rom conventional light-water reactors.
"Our standard facility could become an integral part of the Department of Energy's (DOE) proposed plans to buy and store spent fuel to prevent shutdcwns of some nuclear plants whose storage pools will be filled to capacity in the mid-1980s," a Stone & Webster spokesman said.
"Standardi:ing the facility and locating it on an existing nuclear site should enable the NRC to cut its licensing-review pericd by an estimated 12-13 months."
The Stone & Webster facility can store 1,300 metric tons of spent-fuel assemblies--the result of about thirty years of operatien for a 1300 Mwe reactor--and can accom.odate both pressurized-water-reactor and bcilinc-water-reactor fuel.
It meets NRC guidelines for earthquakes and weather conditions for most areas of the country.
Utilizing makeup-water, securit; pcwer and other systems of the parent nuclear plant helps to minimize
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, Stone & Webster Engineering Corporation, the largest subsidiary of Stone & Webster, Inc. of New York, engineers and constructs electric power, petrochemical, chemical, industrial, and civil works projects around the world.
A leader in power plant standardization, Stone &
Webster was the nation's first architect-engineer to have a standard (reference) plant approved by the NRC, and last year received a con-tract to design and construct the first such plant to be built by a utility company.
The firm is headquartered in Bosten and has operations centers in Cherry Hill, N.J.; Denver, Colo., and New York, N.Y.
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EXHIBIT C noci..,4,,,,,ne,co,po,,non 24 Exceuleve Park WCT Attanta Georgoi 30329 (404) 325 4200 Teies $49C67
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Mr.
H. T.
Snead, Manager Nuclear Fuel Services Duke Power Ccapany 422 South Church Street Charlotte, North Carolina 28242
Dear Tom:
Please accept our thanks for the time and effort you, Dave and Steve gave Ralph and I last Wednesday.
As discussed, I am enclosing a draft pin storage proposal which covers many of the points regarding the licensing and development of this concept.
I fully recognize that your company has the in-house capability and talent to perform much of the safety analyses and the licensing work.
When the appropriate time arrives, this can be worked out.
In the meanwhile, I thought that the
. ?,c proposal spells out the tasks that we feel will have to be performed.
Best regards, NUCLEARASSURANCECORPOPITICN Eff L
T John 1 Ecuston, Jr.
Assistant General Manager Salss and Markering JVH: mas Enclosure
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PROPOSAL TO TO INCPIASE SPENT FUEL STORAGE AT THE NUCLEAR GENERATING STATION O
October 7, 1977 (Proposal Valid Through
)
NUCLEAR ASSURANCE CCRPORATICM 24 E::ecutive Park West Weinbergstrasse 9 Atlanta, Cecrgia 30329 8001 Zurich, Switzerland Telephone:
(404) 325-4200 Telephone:
(01) 47 08 44 Telex:
549567 Telex:
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TADLC OF CONTENTS Page 1.0 Introductica 1
2.0 Scope of Work 2
2.1 Program Objectives 2
2.2 Major Program Tasks 2
2.3 Customer Responsibilities 4
2.4 Program Phases 5
3.0 Price and Schedule 7
4.0 Terms 8
4.1 Pay =ents 8
4.2 Taxes 8
O' 4.3 Termination 8
5.0 General Terms and Conditions 9
5.1 Warranty 9
5.2 Codes and Standards 9
5.3 Cemonstration at Plant Site 9
5.4 Fcree Majeure 9
5.5 General Limitations of Liability 10 5.6 Prcrerty Damage Waiver 11 5.7 Centract Changes and Extra Work 11 5.8 Assignment and subcontracting 12 5.9 Non-Discrimination in Employment 12 5.10 Notices 12
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APPENDICES A
NAC Qualifications and Experience B
Technical Supplement C
NAC Personnel Resumes O
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1.0 INTRODUCTION
NAC proposes to increase the storage capability of reactor spent fuel storage pool by up to 80% #
utilizing NAC's pin storage plan and equipment.
The proposal is directed specifically to offering NAC's services in designing, manufacturing, installing and operating equipment to disassemble irradiated fuel bundles and repackage the fuel pins or rods for storage and eventual shipment.
The non-fuel ccmponents of the assembly would be packaged for burial off-site.
The existing pool and racks would be utilized.
NAC would also provide technical support to assist you in the icensing of this equipment for use in your plant.
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2.1 Program Objectives 2.1.1 To increase the storage capacity of your existing racks and pool by up to 752 by disassembling and repackaging irradiated -
fuel bundles.
2.1.2 To package and dispose of (through burial) the non-fuel components.
2.1.3 To increase the amount of fuel per shipment by approximately 80%.
2.2 Major Program Tasks 2.2.1 Task 1 - NRC Accrovals NAC will perform safety analyses, prepare dccumentation and provide support necessary for the utility to seek NRC approval for storage of fuel pins in a high density arrangement.
This effort will be directed toward the use of existing storage racks and structures with only minor modi-
'M fications, if any.
Nuclear criticality safety, structural, heat transfer, pcol support systems, SNM accountability, ALARA and other regulatory issues will be addressed in these efforts.
NAC will also~ perform the necessary analyses, prepare dccumentation and seek NRC approval for shipment of a large number of individual fuel pins in the NAC-1 cash.
NAC has carefully analy:cd cne existing spent fuel pcol and its stored fucl.
NAC also has internally reviewed cther LW2 fuels.
Criticality safety, heat removal, pccl support systems, RAM inventory and acccuntability factors are all believed to be well within the acceptable range and shculd not be a major licensing concern.
The structural analysis, including scismic, will prcbably require the majcr effort.
Hcwever, structural problems can usually be " designed around".
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2.2.2 Task 2 - Safty Anorovals for Fuel Disassembly N+'
NAC will perform safety analyses, preparc documentation and seek necessary safety approvals from the Plant for disassembly of fuel, high density packaging of lcose fuel pins and storage of the high density
. packages at the reactor pool.
Fuel disassembly operations have been performed at many reactor f acilitics.
NAC partially-disassembled irradiated fuel bundles at Maine Yankee using equipment designed and built by NAC.
Fuel manu-factured by all four U.S.
reactor vendors has been disassembled in the past.
Necessary safety approvals for these activities are the responsibility of the reactor Plant Operation Review Committee (PORC), and do not require NRC review.
PORC approvals are not obtained without careful and thorough evaluations of the procedures; but, such approvals are not unreasonably withheld.
On the basis of
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these experiences, there is a high degree of confidence that approvals for fuel O';.
disassembly operations will be forthccming.
Regarding the packaging of individual fuel pins for shipment, similar operations have also been performed at various reactor plants using procedures and.packagings approved by the Plant Cperations Review Ccamittee.
NAC casks with MRC approval have been used to transport many such individual. pin packages.
The preposed individual pin high density packaging differs from these past cperatiens ecstly in degree, thus NAC believes they will also be within the safecy jurisdictica of PORC.
2.2.3 Task 3 - Ecuiement Fabricaticn and Tes t Onera tions NAC will provide equipment and precedures necessary to disassemble fuel bundles and to repackagu the individual pins in a high dencity arrangement (in a container O
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for storage at the reactor site and for (m%
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package for disposal the remaining non-fuel parts of the reactor fuel assemblics.
Equipment and procedurcs to be used for fucl disassembly will be similar to those which have been used by Ni,C to perform related~
cecrations at reactor sites.
NAC will also disassemble and repacr. age the necessary number of accemblics to check out the equip-ment and procedures.
2.2.4 Task 4 - Disposal of Non-Fuel Bearing Components NAC will provide disposal containers, shipping casks services and arrange for transportation and burial of non-fuel components generated in Task ; above.
(one shipment) 2.3 Customer Responsibilities 2.3.1 Previde data on fuel necessary fer MAC to prepare safety analyses on criticality, heat lead, RAM inventory, etc.
2.3.2 Provide drawings and engineering data on pool structure and spent fuel racks to permit NAC to make general structural and seismic evaluaticas.
2.3.3 Provide nece<sary data and drawings on pool support systems to enable NAC to analyze the water quality system, ven-tilation equipment, heat exchangers and cask handling equipment.
2.3.4 Previde crane service during installatien and cperation.
2.3.5 Provide health physics personnel as required.
2.3.6 Previde necessary utility connecticas and service.
2.3.7 Previde limited use of plant machinc shop and personnel if required.
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2.3.8 Preparc submittal to NRC for approval w
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2.3.9 Review operationc procedures and cafety
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Committce.
2.4 Program Phases 2.4.1 Phase 1 Preliminary analysis of pool loading, criticality, heat leads, etc. sufficient to determine if pin storage can probably be licensed.
The completion of Phase 1 provides an active decision point for the utility to decide whether or not to con-tinue.
Includes 20S of, Task 1 - 3 months to complete.
2.4.2 Phase 2 Encompasses the bulk of the detailed analyses and the support to enable the utility to seek approval by NRC of pin storage at the particular site.
By end of Phase 2, NRC will have indicated whether pin storage is acceptable.
Some additional Task 1 work, answers to questions, additional analyses, clarifications, etc. will be 0",O necessary for formal approval; but, the certainty is great enough that we can mcve into the equipment phase.
Includes 60S of Task 1 - 4 months to cceplete.
2.4.3 Phase 3 Completion of licensing activitics frem Phase 2.
Phase 3 is concerned uith the development of operating precedures and the approval of these precedures and of the safety analyses by the Plant Operations Revicw Commit:ce ( P O.'.C ).
Cuality assurance requirements will be established fer the equipment manufacturer, along with pre-liminary engineering drawings so that firm fabrication ecs ts can ba determined.
Includes 200 of Tack 1, 1]Ci of Tack 2, and 200 of Task 3 - 8 :: 13 mcuths to ecmpletc.
2.4.4 Phace 4 Completion of dctailed engineering drawings, manufacture, accep ance and delivery follcwed by test cperation of the equipment at the O"I reactor pool.
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ity of a satisfactory working syr.tcme Phase 4 also includes the removal from site and burial of one shipment of non-fuel bearing components generated during
.the test operations.
Includes 80% of Task 3, 100S of Task 4 - 6 months to complete.
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3.0 PRICC AMD SCIIEOULE
.ar The preliminary to tal price and program schedule for each phase is shown belcw:
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Phase Scope Time Cum.
Price 1
20% of Task 1 3 months S 40,000 2
60% of Task 1 7 months 110,000 3
20% of Task 1-)
100% of Task 2 )
15-20 =cnths 100,000 20% of Task 3 )
4 80% of Task 3 )
21-26 months 150,000 (est.)
100% of Task 4 )
Estimated Total 21-26 monchs
$400,000 (1) After receipt of necessary engineering drawings and
'E data frca Customer.
The prices quoted for Phase 1, 2 and 3 are firm prices, except for increases resulting frc= changes in regulatory and PORC requirements.
The preliminary price of Phase 4 will be subject to change based on~ the-final design-and -
on the fabrication costs estimated using engineering drawings.
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4.1 Payments Phase 1
$40,000
$20,000 due 30 days after commencement of program phase.
$20,000 duc 30 days after completion of program phase.
Phase 2 S110,000 S30,000 due 30 days af ter com=encement of program phase.
S40,000 due 90 d,ys aft'r commencement e
of progbam phase.
S40,000 due 30 days after completion of program phase.
Phase 3
$100,000 530,000 due 30 days after ccmmencement of program phase.
S40,000 due 90 days after cc=mencement of program phase.
$30,000 due 30 days after completion of program phase.
Phase 4 S150,000 0,9
$40,000 due 30 days after cc=mencement of program phase.
$40,000 due 90 days after commenec=ent of program phase.
S40,000 due 150 days after cccmence-ment of program phase.
$30,000 due 30 days after
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ccmpletion of program phase.
4.2 Taxes Custcmer shall be liable for and shall reimburse NAC fer any sales and use taxes and any licence or registration fees levied er based upon the previsica of criuipment and services by NAC hereundcr.
Such ta::cs and fees shall not include incccc taxes or franchise taxes required to be paid by SAC hereundcr.
4.3 Terminatien Custcrcr hat. the eption to can cl at any point in the program.
Payment in full vill be made for all ccmpleted phases.
Custcmer will also be 1.able for all costs incurred by NAC including, but not limited tc, engineering time (including cverhead),
matertal costs, contractor cancellation chargas, travel expenscu, etc., plus 205 to cover handling
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s 5.0 CENCP.AL TCPRS AMD CONDITIONS 5.1 Warranty NAC warrants that all materials and equipment furnishcd pursuant to Section 2.2.3 shall be free frca defects in materials and workmanship for a period of ninety (90) days following delivery.
NAC shall, at its own expense, repair or replace any materials or equipment uith exception of the consum-able material which prove defective during the warranty period.
Purchaser shall make availabic, at no charge to NAC, maintenance personnel and standard tools required to assist MAC in the repair or replacement of defective materials and equipment.
THE FOREGOING ARE IN LIEU OF ALL UARRANTIES, UHETHER STATUTORY, EXPRESSED OR IMPLIED.
INCLUDING, WITHOUT LIMITATION, WARRANTIES OF MERCHANTAEILITY AND FITNESS FOR A PARTICULAR PURPOSE AND WARRANTIES ARISING FROM A COURSE OF DEALING OR USAGE OF TRADE.
5.2 Codes _and Standards There are no generally accepted codes.or standards applicable to the equipment provided hereunder.
E The equipment will be manufactured in accordance with NAC's Quality Assurance ?rocurement Fredecure and to quality standards to be established by NAC which represent good shop practice.
NAC shall, upon request, following receipt of order, provide Purchaser with a ccpy of the NAC standards.
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5.3 Demonstration at Plant Site After set up of the equipment at the plant site, the operation of the equipment will be demonstrated.
5.4 Force Majeure If, as a result of a force majeure, NAC is mnabic to carry cut fully or in part its obligaticns hercunder, NAC shall give Purchaser prompt written notice of the force majeure describing the same in reasonable detail.
Thercupen, the cblj.;ations of NAC, so far as thay arc affcc:cd by tha force majeure, shall be suspended during, but no longer than, the continuance of the force majeure.
NAC shall use all reasonable dilicence to rcmove the foren majcure as quickly as possilbe, but shall not be required te settic strikes cr labor dif ficultics
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The tern "forco majeurc" s
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as employed herein chall mean an act of God; strike
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or other labor dis turbances; act of war; blockage; public riot; firc; clorm; flood; cxplosion; action or inaction by government or other parties; unavail-ability of equipment; and any other cause, whether of the kind specifically enu= crated or otherwise, which is not reasonably within the centrols of NAC.
5.5 General Limitationc of Liability 5.5.1 NAC's total liability for all claims of any kind, whether based upon contract, tort (including negligence) cr otherwise, for any loss or damage arising out of, connected with, or resulting from the performance or breach of this agreement shall in no case exceed the amount of the price of the specific services or equipment supplied which give rise to the claim, or ten thousand dollars
($10,000.00) whichever is greater.
In applying the monetary limitation of NAC's total liability, such liability shall be reduced by the sum of (1) any damages paid to Purchaser by NAC, and (2) any refund of the price for the services or equipment involved.
5.5.2 In no event, whether as a result of breach of contract, tort liability (including negligence) or otherwice, and whether arising before, during or after ccmpletion of NAC'c obligations hereunder or any. Purchase Order pursuant thereto, shall NAC be liable for lesses or damages caused by reason of unavail ability of Purchaser's equipment (including, but not limited to, loss of us-2, profits or revenue, inventory c: use charges, interest charges or cost of capital, or clainc cf Purchaser's custc=ers), or special, consequen-tial er penal damages of any nacure.
5.5.3 The liability of NAC fcr any claims, whether based upon contract, tort (including negligence) er otherwice, for any 10:s or damage arising out of, connected with, er resciting frem, the per2cr=ance or breach cf this agreement shall be limited to specifically identificd written claims submitted by Purchaser to MAC prior to the expiratica of ena (1) year after the cccurrence cf the evenc cr events O
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upon which the claim is based uith respect r -)
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5.5.4 The prevision of this Section 5.5 and of the other Sections of this agreement providing for limitation of or protection against
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liability of NAC shall also protect its suppliers and shall apply to the full ex tent permitted by law and regardleas of fault and shall survive either termination pursuant to this agreement or cancellation, as well as the completion of the services hereunder.
5.5.5 The provisions of this Section 5.5 shall apply notwithstanding ahy other provisions of this agreement.
5.6 Propertv Damage Maiver Neither MAC nor its suppliers shall have any liability to Purchaser or its insurers for nuclear damage to any property located at the site.
To the extent that Purchaser or its insurers recover damages from a third party for nuclear damage to which the foregoing waiver applies, Purchaser shall indemnify O^~
NAC and its suppliers against any liability for any damages which such third party recovers over from NAC or its suppliers for such nuclear damage.
As used herein, " liability" means liability of any kind at any time whether in contract, tort (including negligence) or otherwise; " nuclear damage" means any less, damage, or loss of use, which in whcic.cr in part is caused by, arises cut of, results frem, or is in any way related, directly er indirectly, to the hazardous properties of scurce, special nucicar or bypr duct material, as those materials are defined in the Atomic Enargy Act of 1954; and
" site" means the area identified as the "locatien" in either (1) the nuclear liability insurance policy, or (2) the gcvernmencal agreement of indcenity issued to Purchaser pursuant te che Act and aL salicabic regulations t hereunder, er (3) bo:h.
At NAC's requent, Purchaser will furnish any supplict with a statement of the protectica available to the supplier.
5.7 Contrnet chances and Extra Nerk The terms.of this agreement shall not be changed, superseded, or supplemented except by written contract change crder duly enecuted by officers or
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designated representatives of NAC and Purchaser and
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no claim for extra equipment or services shall be valid unicss authorized by written contract order fully executed by authort:cd officces or designated representativc3 of NAC and Purchaser.
5.8 Assianment and Subcontracting 5.8.1 Assignment - Any assignment by NAC of this agreement or any right hereunder without the prior written approval of Purchaser shall be void and not merely voidabic.
5.8.2. Subcontracti.ng - Should MAC desire to subcon-tract any portion of this contract to another party, NAC shall first secure Purchaser's approval of the proposed subcontractor.
Such approval shall not be un'rcasonably withheld.
5.9 Non-Discrimination in Employment NAC shall comply with the provisions of Paragraph 1 through 7 set forth in Section 02 of the United States Presidential Executive Crder No. 11246 of September 24, 1965 as may be modified or substituted for from time to time.
5.10 Notices All notices, requests, and approvals rcquired under this agrcement shall be in writing and shall be served personally or by certified mail upon Purchaser and upon NAC at 24 Executive Park West, Atlanta, Georgia 30329, ATTN:
Mr. Jack D.
Rollins, Vice President, or at such cther address as any party may frcm time to time designate in writing.
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NAC OUALIFICATIONS AND E7.?ERIC::CE
-a Nuclear Accurance Corporation is a ccmbination of informa-tion services, data analysis and field support organized to serve the nuclear energy industry:
utilities, reactor vendorn, equipment rrpplicrs, uranium mining anc, milling companies, converters anc, rcpcocessors, government agencies, financial institutions, and re-search organi ations.
Founded in 1968 in Atlanta, Georgia, NAC c:cpanded to include a Eurcpean Operations Office in Zurich, Switzerland in 1972 and a Uranium Cperations Office in Grand Junc:ior., Colorado in 1974.
It now serves clients frcm virtually every cpuntry with an interest in the nuclear industry.
In' addition to basic fuel cycle data and custom analyses, NAC provides uranium property managemenc and a variety of on-site servies such as spent fuel shipping, fuel inspection, and non-fuel ~ waste disposal.
Sites where NAC hardware services have been used include Ft. Calhoun, Big Rock Point, Palisades, Oyster Creek, Turkey Point, Cconee, H. B.
Robinson, Kcuaunce, Point Beach, San Cnofre, Indian Point, Battelle-Columbus, Aerojet-Idaho, B&W-Lynchburg, GE-Morris, NFS-West Valley, Dresden, Maine Yankee, and Quad Cities.
NAC will execute its portion of the indicated work scope using exicting staff from its Engineering and Transportation Services (ETS) Division and its Fuel-Traco Division.
NAC's ETS Division is responsible for the maintenance and cperation of NAC's spent fuel shipping cask fleet.
The-division --- -----
also provides speciali:cd on-site services, such as fuel inspec-tion; non-fuel waste compaction, packaging and disposal; and design and development of special-purpose underwater tools.
In the area of transportation of radicactive material, NAC's experience is cenprchencive.
NAC cwns and operates fcur legal weight truck (::AC-1) casks, cieng tith assccia:ed transport trailers and special au.:iliary handling equipment.
NAC is the most experienced shipnn of irradiated fuel and ccmpenents in the Ca ;.ted Sta tcu.
In 1975 and 197G alece, over 150 individual shipments were made; in 1977, over 200 are planned.
Tha casks have in:crf aced at scme 10 different nuclear facilitics in the land transport of irradiated fuel frca late-generatica PW2 and EUR nuclear rcacters.
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MAC personnel have more than 30 years' cumulative c>:perience s
in the design, certificaticn and operation of radioactive matcrial transportation packagings.
They have been responsible under centract or in-house funding for:
Fabrication and operation of the ::AC-1 casks, including the implecuntation of a quality assurance program ccvering fabrication and operation.
Ucrk was internally funded and was performed by J.
D.
- Rollins, C.
C.
Hoffman, and D.
M.
Collier.
Conceptual design study of an underground plutonium storage facility in granite plutcr.s.
Work internally was funded at approximately $25],000 and was performed by J.
D.
Rollins and C.
B. Ucodhall, with support of outside engineers and scientists specialicing in earth sciences.
Conceptual design of a large-capacity (7 PUR/lS LUR elements) rail shipping cask incorporating innovative features such as redundant trunniens, detachable fins, and all-steel shielding.
Work was internally funded and was performed by J.
D.
- Rollins, R.
E.
Best, M.
E.
- Mason, H.
R.
Panter, and R.
A.
Schreiber.
O-Thermal analysis of a dry spent fuel storage facility.
Work done in 1975 for Atlantic Richfield Company.
Work performed by J.
D.
Rollins, M.
E.
- Mason, and C, C. Hoffman.
Cost-benefit analysis cf alternative dispositions of plutonica on LMR fuel cycle operations, including spent fuel transportation, plutonium s:crage, spent fuel storage; and wastc management fer cases of prcmpt recycle deferred reprocessing, and no reprocessing.
Ccusidera-tion; inclu. led envircomental as.:cccs, fuel cycle ccats, and raterial and plan protecticn.
Ucrk cone in 1974 for the AEC as cart cf GECMO.
J.
O.
Rollins and D.
M. Collier w'ere key contributcrs to work.
Study of an optimum irradicted fuci trancportatica system for Swede"., including corp'latica of ecriduido ca ':
syntems, identificaticn of f uture casa des.:.gn and upcrating paranatcrs, cvaluaticn cf cierations requirement. for handling casks and selectica of Optimur cask design.
Work was done in 1976 for Swedish :acicar Fuel Ccmpany.
Ucrk was performed by R.
E.
Best, :*.
E.
Masca, J.
0
, Rollins, and C.
C.
Mcffman.
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- ' Design, fabrication, and operation of equincent for the disassembly of irradiated PUR fuel.
Work was donc in 1977 for Maine Yankce.
Work was performed by J.
M.
- Vicbrcck, R.
E.
Best, M.
E.
- Mason, H.
R.
Panter, and R.
A.
Schrciber.
Analysis and conceptual design of hardwarc which would allow an increase in the storage capacity of a reactor spent fuel psol by approximately 75% over the capacity possible
..it'. high density fuel storage racks.
Werk was done in 1976.
Work was performed by J. M. Vicbrock, C.
C.
- Hoffman, R.
E.
Best, H.
R.
- Panter, M.
E. Mason, J.
D.
Rollins, and R.
A.
Schrciber.
Design, fabrication and operation of equipment to cut and package EUR fuel channels, LPRM's and poisca curtains for shipment to a burial ground.
Work was done in 1976/77 for Jersey Central Power and Light at a cost of $347,000.
Similar services are also being provided to TVA at a cost of Sll6,000.
Work was perferred by J.
M.
- Vicbrock, R.
t.
- Best, H.
R.
- Panter, M.
E.
- Mason, J.
D.
Rollins, and R.
A.
Schreiber.
Design study for fuel storage pool modification, including O;_.T criticality studies.
Work was done in 1975 for Nuclear Fuel Services.
Work was performed by J.
D.
Rollins.
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