ML19254F028

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Testimony in Response to ASLB Question Raised at 790921 Prehearing Conference Re Need for Power Cost/Benefit Analysis on Spent Fuel Pool Mod.Discusses Licensing Requirements.Prof Qualifications & Certificate of Svc Encl
ML19254F028
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 09/28/1979
From: James Shea
Office of Nuclear Reactor Regulation
To:
References
NUDOCS 7911050409
Download: ML19254F028 (8)


Text

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NRC PUBLIC DOCUMENT ROOM UilITED STATES OF AfiERICA fiUCLEAR REG!!LATORY COM!ilSSION (v

BEFORE THE ATOMIC SAFETY AND LICEllSING BOARD

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A In the Matter of g

DAIRYLAtlD POWER COOPERATIVE

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Docket No. 50-409 Y

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(SFP License Amendment D [#e#

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TESTIM 0!!Y OF JAt1ES J. SHEA UN THE BOA: D QUESTIO!I CONCER'llfiG A NEED FOR P04ER COST-BENEFIT ANALYSIS FOR THE SPENT FUEL POOL MODIFICATION My name is James J. Shea.

I am employed by the Nuclear Regulatory Commission in the Division ef Operating Reactors as a project manager, assigned to the LACBWR plant. My professional qualifications are attached.

The purpose of my testimony is to provide answer to the Board question raised at the prehear:ag conference on September 21, 1979.

The question asked for a connarison of:

The need for power produced at LACBt!R halanced against the environmental inpacts described in the NRC EIA and economic costs. _l]

Since the Staff has no current information available regarding the specific economic costs at LACBWR described in the Board's question, nor the specific need for LACB9R power in the service area, ny testimony will be limited to a description of licensina requirements which will require expenditures by the licensee for the next three years.

S e Staff has summarized from the transcript what it believes to be the Til essence of the Beard's question.

Tr. 422-423, also Tr. 413-414.

1268 175 7 9110 5 0 4 C) 7 G

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. The Provisional Operating License issued to the Allis Chalmers Company and Dairyland Power Cooperative (DPC), DPR-45, on July 3,1967,2] for the La Crosse Boiling Water Reactor (LACBWR) authorizes DPC to possess, use and operate the facility in accordance with procedures, limitations and special conditions described in the Operating Technical Specifications and Comission regulations.

The license also requires that DPC maintain in effect and fully implement Comission approved physical security requirements.

Acc ngly, DPC is required to naintain a minimum operating shift crew of four (T.S. Table 3.2-1) with at least one licensed operator in the control room when fuel is in the reactor vessel.

T.S. 3.2.2(a)(b)(d)(f).

An individual qualified in radiation protection procedures must be on site when there is fuel in the reactor vessel.

A fire brigade of five members must be maintained on site at all times and there must be a minimum of five armed guards per shift.

T.S. 3.5.1 requires an Operations Review Committee with defined responsibilities in T.S. 3.

' S that must meet at least once per year.

There must also be an independent Safety Review Committee (T.S. 3.5.2) to review, amongst other items (T.S. 3.5.2.7(d)), proposed changes to Technical Specifications and Licenses.

In general, as long as POL DPR-45 is in effect, all of the conditions in the License and Operating Technical Specifications must be satisfied including inspecticn, surveillance and testing requirements.

Therefore, even if the plant were to be in cold shutdown for a period of three years, it would be necessary to maintain the staff to continue the activities normally associated with an operating plant, i.e., repair and maintenance as required, since DPC cannot offload the core into the FESW.

S e POL was transferred to DPC as sole licensee on October 31, 1969.

Th 1268 176

.s Unless the spent fuel storage rack capacity, as requested by DPC, is authorized or a new proposal is submitted to flRC for sufficient expansion of the spent fuel storage racks to permit off-loading the fuel assemblies in the reactor vessel to the Fuel Element Storage Wall (FESW), the DPC license to " possess, use, and operate" cannot be changed to a license for " possession only." A change to a " possession only" license would permit a significant reduction in the site staffing requirements because it would no longer be required that the plant be maintained in condition for safe generation of power, i.e., operation of the plant would no longer be authorized or possible, since fuel assemblies would not be permitted in the reactor vessel.

Based on the time and resources required to change licenses as described above, it is unlikely that such could be completed, i.e., a change to " possession only" and return to " possess, use and operate," in time to resume power generation on December 31, 1982, with any net benefit in the present costs at LACBWR.

There is no precedent for such action so that the time to prepare and review the safety and environmental evaluations and authorize changes to the license would be extensive under current NRC Staff practices.

In effect, if LACBWR is to be maintained in cold shutdown with fuel assemblies in the reactor vessel for a period of three years with the intention of resuming power generation at the end of that period, the plant must abide by the existing 1268 177

... technical specifications to prevent degradation of the plant.

Therefore, the LACBWR economic operating costs are nearly the same whether or not power is produced.

The only economic saving would be the costs of the FESW modification and the uranium 235 fuel for three years.

The operating airborne gaseous releases from the stack average about 400 Ci per month. At the site boundary this dose is less than.l. mr.'

The gaseous releases are less than one percent of levels permitted by 10 CFR 6%0, and the license technical specifications.

Radiation worker exposure is heavily dependent on whether or not refueling is done and the amount of maintenance and inspection done, so that operation of the plant could double worker exposure from the exposures incurred during cold shiLdown.

But if any insnections or maintenance were done during shutdown, these activities could change or eliminate the difference.

The annual worker exposures at LACBUR have ranged from about 110 to 240 man-rem, i.e.,1-2 rem per worker per year.

With these comparisons in mind, it seems clear that the benefits of producing power, given the high cost of maintaining the plant in cold shutdown, outweigh the costs of the FESW modification.

Otherwise, it seems that the area ratepayer would be paying high costs to staff and maintain the plant with no benefit of additional power in the area.

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. In summary, I am providing a table of comparisons.

Costs of Operation Costs of Shutdowa 1.

NRC License staffing and 1.

Fuel for 3 years.

maintenance requirements.

2.

Cost of FESW modification.

2.

55-120 man rem worker exposure

(.5-1 rem / worker).

(This could increase significantly if repairs, inspections done.)

3.

NRC License staffing and maintenance requirements.

4.

400 Ci/mo. offgas releases

(.1 mr).

5.

110-240 man rem worker exposure (1-2 rem / worker).

Dated at Bethesda, Maryland, this 28th day of September,1979.

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PROFESSIONAL QUALIFICATIONS OF JAMES J. SHEA I am the Nuclear Regulatory Comnission Project Manager for the La Crosse Boiling Water Reactor as well as two other nuclear power plants.

I have served the Comnission in this capacity for more than 15 years having at one time or another been Project Manager for 12 of the nuclear power plants now licensed to operate in the United States. As a Project Manager I manage and participate in the review and evaluation of safety and environmental considerations associated with the design and operation of nuclear power facilities, especially those licensed for operation.

I also currently manage and participate in the Systematic Evaluation Program which involves a comprehensive review and evaluation o# oider operating facilities to detennine and document the acceptability of their departures from current licensing requirements.

I have contributed to two special studies performed by the NRC.

The reports. titled " Generic Environmental Statenent on Mixed 0xide (GESMO - 1976)

Fuel and Nuclear Energy Center Site Suryey (NECSS 1975).

Prior to government service, as a manager and engineer in industry, I was responsible for thermal hydraulics, heat transfer, instrumentation and controls design and testing of nuclear reactor prototypes for the Navy nuclear program.

I have a BS and MS in Chemical Engineering from Worcester Polytechnic Institute of Technology, Worcester, Nassachusetts,1944 and 1947, and am a registered professional engineer in the state of New York.

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UNITED STATES OF AMERICA NUCLEAR RECULAT0kY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

g DAIRYLAfiO POWER COOPERATIVE Docket No. 50-409 (La Crosse Soiling Water Reactor)

)

(SFP License Amendment)

CERTIFICATE OF SERVICE _

I hereby certify that copies of " TESTIMONY OF JAMES J. SHEA ON 'lHE BOARD QUESIION CONCER' LING A NEED FOR POWER COST-BENEFIT ANALYSIS FOR THE SPENT FUEL POOL MODIFICATION" in the above-captioned proceedinq have been served on the following by deoosit in the United States mail, first class, or, as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system t is 28th day of September,1979:

Charles Bechhoefer, Esq., Chairman *

~

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washingtons D. C.

20555 Dr. George C. Anderson

0. S. Hiestand, Esq.

Department of Oceanography George L. Edgar, Esq.

University of Washington Morgan, Lewis & Bockius Seattle, Washington 98195 1800 M Street, fl.W.

Washington, D. C.

20036 Mr. Ralph S. Decker Route 4, Box 1900 Fritz Schuoert, Esq.

Cambridge, Maryland 21613 Staff Attorney Dairyland Power Cooperative 2615 East Ave., South George R. Nygaard La Crosse, Wisconsin 54601 Mark Burmaster Anne K. Morse Atomic Safety and Licensing Coulee Region Energy Coalition Appeal Board

  • P.O. Box 1583 U.S. Nuclear Regulatory Commission La Crosse, Wisconsin 54601 Washi ngton, D. C.

20555 Frank Linder Atomic Safety and Licensing General Manager Board Panel

  • Dairyland Power Cooperative U.S. Nuclear Regulatory Commission 2615 East Ave., South Washington, D. C.

20555 La Crosse, Wisconsin 54601 1268 181

Docketing and Service Section*

U.S. Nuclear Regulatory Coranission Washington, D. C.

20555

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\\N Colleen P. Woodhead Counsel for NRC Staff 1268 182 9

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