State of Wi Answers to Licensee'S First Set of Interrogatories.Responds to Interrogatories 1-22,except for Interrogatory 5 Re Proposed Increase in Spent Fuel StorageML19263C632 |
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Kewaunee |
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Issue date: |
12/26/1978 |
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From: |
Walsh P WISCONSIN, STATE OF |
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To: |
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Shared Package |
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ML19263C631 |
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References |
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NUDOCS 7902280060 |
Download: ML19263C632 (5) |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML19263C6321978-12-26026 December 1978 State of Wi Answers to Licensee'S First Set of Interrogatories.Responds to Interrogatories 1-22,except for Interrogatory 5 Re Proposed Increase in Spent Fuel Storage ML19259B0391978-12-19019 December 1978 Licensee Response to Interrogatories Submitted by Wi. Interrogatories Concern Radioactive Releases,Integrity & Burnup of Spent Fuel.Affidavit & Certificate of Svc Encl ML19289C3491978-12-15015 December 1978 Responses by Intervenors Lakeshore Citizens for Safe Energy to NRC Interrogatories Re ASLB Questions.Asserts That Licensee Evaluation Is Inadequate Since There Is No Separate Monitoring of the Spent Fuel Pool ML20062F9431978-12-0101 December 1978 St of Wi'S Answers to NRC Staff'S First Set of Interrogs & Request for Production of Documents.St Does Not Anticipate Utilizing in Its cross-exam Any Documents Not Already Listed by Staff & Applicant Wips.Cert of Svc Encl ML20062F9391978-11-30030 November 1978 Interrogs Propounded by St of Wi to NRC Staff.Interrogs Concern Staff'S Position Re Tech Merit of Each of Intervenor'S Admitted Contentions ML20062F9321978-11-30030 November 1978 Interrogs Propounded by St of Wi to Applicants Wips,Wi Pwr & Light & Madison Gas & Elec Re Appl to Mod Spent Fuel Pool. Interrogs Concern Contentions 2 & 13 ML20062F7641978-11-28028 November 1978 Intervenors Responses to Licensees' First Set of Interrogs a Thermo-Inversion Around the Plant Sites May Cause a Higher Level of Radiat to Be present.Thermo-Inversion Prevents Emissions Escaping to Higher Atmosphere.Cert of Svc Encl ML20062F4191978-11-28028 November 1978 Response by Intervenors Bast & W Schaefer to NRC Staff'S First Set of Interrogs.Cert of Svc Encl ML20062E9271978-11-20020 November 1978 Licensee Wi Pub Svc First Set of Interrogs to & Request for Production of Documents From,Intervenors Lace & St of Wi. Interrogs Concern,Inter Alia,Identification of Intervenors Contentions & Presentation of Evidence ML20062E0841978-11-0909 November 1978 NRC Staff Interrogs To,& Request for Production of Documents From,Intervenors Citizens for Safe Energy/Safe Haven Ltd. Interrogs Concern Testimony to Be Presented,Admitted Contentions & ASLB Questions 1978-12-26
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20077M5791995-01-0303 January 1995 Comment Supporting Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Np Reactors.Expresses Concern Over Basis for Pr Not Recognizing Improvements in Outage Planning,Flawed Regulatory Analysis & Unneeded Restrictions ML20077G2991994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal,Proposed Amends.Util Believes That Amends as Modified by NEI Comments Will Lead to Stable & Predictable License Renewal Process ML20059F6161994-01-0404 January 1994 Comment Opposing Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at NPP ML20059J6831993-10-27027 October 1993 Comment Supporting Proposed Rule 10CFR171 Re Restoration of Generic Exemption from Annual Fees for Nonprofit Educational Institutions ML20100Q7351992-03-13013 March 1992 Comment Endorsing NUMARC Comments on Proposed Rule 10CFR51 Re Geis,Particularly Comments Re Continued Rights of States to Regulate Utilities Based on state-level Economic Objectives,Energy Needs & Mix of Generation Requirements ML20090J8411992-03-10010 March 1992 Comment Supporting Proposed Rules 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML20073B3211991-04-15015 April 1991 Comment Re Proposed Amend to 10CFR50.55a.Retaining Requirements of Subsection Iwv for Leakage Rate Analysis & Corrective Action for Specific Valve Is Not Necessary ML20066A0981990-12-20020 December 1990 Comments on Proposed Rule 10CFR50 Re Erds.Nrc Adoption of Cumbersome Hardware & Software Design to Establish ERDS Link Connection Discouraging ML20058G0311990-10-23023 October 1990 Comment Supporting Proposed Rule 10CFR51 Re License Renewal for Nuclear Power Plants ML20062B0841990-10-15015 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Supports Comments Submitted by NUMARC ML19353B2021989-12-0101 December 1989 Comment on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Although Draft Closely Resembles Rev 1 to INPO 85-038,some Aspects Overly Prescriptive ML20236A5341989-03-0909 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Recent Improvements in Qualifications & Training Adequately Addresses Safety ML20235V7721989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint at Nuclear Plants.Supports NUMARC Comments.Rule Unnecessary to Improve Maint at Nuclear Power Plants & Will Be Detrimental to Plants W/Effective Maint Programs ML20235P1271989-02-13013 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educational & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235N6971989-02-10010 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Proposed Degree Requirement.No Specific Data to Indicate That Rule Will Improve Plant Safety Exists ML20206M7961988-11-21021 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program,Per NUMARC Comments.Addl Comments Provided ML20205Q1501988-10-28028 October 1988 Comment on Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear Plant License Renewal. Safety Sys Functional Insps & Configuration Mgt Programs Support Renewal Basis as Opposed to Relicensing Process ML20195E6031988-10-27027 October 1988 Comment Supporting Proposed Rule 10CFR20 Re Disposal of Waste Oil by Incineration.Proposed Rule Would Provide Several Benefits,Including Reservation of Limited Capacity in Licensed Disposal Sites for Wastes W/Higher Activities ML20205N0471988-10-20020 October 1988 Comments on Proposed Rule 10CFR50 Re Extension of Time for Implementation of Decontamination Priority & Trusteeship Provisions of Property Insurance Requirements.Util Requests Response to ML20154P1391988-09-0202 September 1988 Comment Opposing Petition for Rulemaking 50-51 Re Property Insurance for NRC Licensed Power Plants ML20154N9961988-08-22022 August 1988 Comment on Petition for Rulemaking 50-51 Re Property Insurance for NRC Licensed Power Plants.Nrc Urged to Accept Petition & Grant Relief Requested ML20154G7481988-04-15015 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Employee Not Announcing or Otherwise Communicating to Other Persons Arrival & Presence of NRC Inspector.Rule Will Introduce Unintended Antagonism in Nrc/Licensee Relationship ML20154H4981988-03-29029 March 1988 Comment Supporting Proposed Rule 10CFR50 Re Use of ANSI/ANS-56.8-1987 to Calculate Containment Leakage Rates ML19270H1541979-05-24024 May 1979 Answer to 790430 Notice of Hearing.Util Will Appear Before Administrative Law Judge & Present Evidence.No Matl Facts Are in Dispute.No Violations Occurred & No Civil Penalties Can Be Imposed.Certificate of Svc Encl ML19270H1521979-05-24024 May 1979 Notice of Appearance on Behalf of Util.Certificate of Svc Encl ML19276E5211979-02-0808 February 1979 Resolution Opposing Const of Nuclear Power Plant in Putnam County,Due to Safety & Environ Reasons ML19263C6321978-12-26026 December 1978 State of Wi Answers to Licensee'S First Set of Interrogatories.Responds to Interrogatories 1-22,except for Interrogatory 5 Re Proposed Increase in Spent Fuel Storage ML19259B0391978-12-19019 December 1978 Licensee Response to Interrogatories Submitted by Wi. Interrogatories Concern Radioactive Releases,Integrity & Burnup of Spent Fuel.Affidavit & Certificate of Svc Encl ML19289C3491978-12-15015 December 1978 Responses by Intervenors Lakeshore Citizens for Safe Energy to NRC Interrogatories Re ASLB Questions.Asserts That Licensee Evaluation Is Inadequate Since There Is No Separate Monitoring of the Spent Fuel Pool ML19289C3221978-12-13013 December 1978 Provides Notice That SA Bast Withdraws Her Name from Mail & Svc List in Proceeding.All Further Correspondence Should Be Addressed to W Cordaro,1412 New York Avenue,Manitowoc,Wi ML20062F9431978-12-0101 December 1978 St of Wi'S Answers to NRC Staff'S First Set of Interrogs & Request for Production of Documents.St Does Not Anticipate Utilizing in Its cross-exam Any Documents Not Already Listed by Staff & Applicant Wips.Cert of Svc Encl ML20062F9391978-11-30030 November 1978 Interrogs Propounded by St of Wi to NRC Staff.Interrogs Concern Staff'S Position Re Tech Merit of Each of Intervenor'S Admitted Contentions ML20062F9321978-11-30030 November 1978 Interrogs Propounded by St of Wi to Applicants Wips,Wi Pwr & Light & Madison Gas & Elec Re Appl to Mod Spent Fuel Pool. Interrogs Concern Contentions 2 & 13 ML20062F7641978-11-28028 November 1978 Intervenors Responses to Licensees' First Set of Interrogs a Thermo-Inversion Around the Plant Sites May Cause a Higher Level of Radiat to Be present.Thermo-Inversion Prevents Emissions Escaping to Higher Atmosphere.Cert of Svc Encl ML20062F4191978-11-28028 November 1978 Response by Intervenors Bast & W Schaefer to NRC Staff'S First Set of Interrogs.Cert of Svc Encl ML20062E9271978-11-20020 November 1978 Licensee Wi Pub Svc First Set of Interrogs to & Request for Production of Documents From,Intervenors Lace & St of Wi. Interrogs Concern,Inter Alia,Identification of Intervenors Contentions & Presentation of Evidence ML20062D7251978-11-13013 November 1978 Notice of W/Drawal by J Lawrence as Counsel Representing NRC in Proc Re Increase Spent Fuel Storage Capacity at Subj Facil.Future Correspondence Should Be Addressed to W Olmstead.Cert of Svc Encl ML20062E7091978-11-11011 November 1978 Interrogs Submitted by Intervenor Lacse to Applicant Wpsc Re Lacse Contentions on Such Topics as Radioactive Emissions, Experiments on Deterioration of Neutron Absorber Plates & Removal of Radioactive Wastes.Certificate of Svc Encl ML20062E2031978-11-0909 November 1978 NRC Request for Production of Documents from & Interrogs to State of Wi Re Planned Testimony & Witnesses ML20062E1311978-11-0909 November 1978 NRC Staff Interrogs to & Request for the Production of Documents from Intervenors Lakeshore Citizens for Safe Energy/Safe Haven Ltd ML20062E0841978-11-0909 November 1978 NRC Staff Interrogs To,& Request for Production of Documents From,Intervenors Citizens for Safe Energy/Safe Haven Ltd. Interrogs Concern Testimony to Be Presented,Admitted Contentions & ASLB Questions 1995-01-03
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- 5. Answering interrogatory number six (6), the state does not knew whether the neutron absorber materials pro-posed for use in the Kewaunee spent fuel pcol are similar to those used at the Connecticut-Yankee facility.
- 6. Answering interrogatory number seven (7), there is an insufficient scientific and experimental basis for assuming long-term integrity of the neutron absorber placed over the life of the license. To the state's knowledge spent fuel has not been stored in pools for periods of time longer than approximately twenty (20) years, considerably less than the (forty) 40-year period of the proposed license.
Therefore, cumulative, long-term effects on spent fuel and associated components such as neutron absorber plates are unknown at this time.
- 7. Answering interrogatory number eight (8), the answer is "yes."
- 8. Answering interrogatory number nine (9), monitoring is botb. dcsirable and necessary to insure the integrity of the neutron absorber plates over the life of the license.
Monitoring could include visual inspections of absorber plates through the use of TV cameras or other remote sensing, if necessary, to continual monitoring of pool water to determine if degradation, swelling or other effects are occuring, andthroug$ periodic,perhapsquarterly,withdrawalof specific neutron absorber plates for testing purposes.
- 9. Answering interrogatory number ten (10), this interrgatory refers to the intervenor's own definition of its contention twelve (12), to which the state is not a party.
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- 10. Arswering interrogatroy number eleven (11), based upo'n your answer to intervenor's interrogatory number one (1), contention twelve (12), there will be a small increase in the level of generated wastes due to the proposed modifi-cation.
- 11. Answering interrogatory number twelve (12), based upon your answer to intervenor's interrogatory number one .
(1) , contention twelve (12), this number cannot be calcu-lated, but will be small.
12, Answering interrogatory number thirteen (13),
any increase in wastes due to the spent fuel pool must be considered and balanced by the hearing board in its deter-mination concerning whether to issue a license for the pro-posed modification.
- 13. Answering interrogatory number fourteen (14),
it is unclear what effect borated water will have upon the materials in the spent fuel pool over the life of the license.
._ 14. Answering interrogatory number fifteen (15), gal-vanic corrosion could occur over the long-term due to inter-actions in the Zircaloy-stainless steel-boric acid environ-ment, which will be present in the pool. Over the long-term, deterioration of these materials could occur. Radiation and temperature may also affect long-term corrosion rates.
- 15. Answering interrogatory number sixteen (16),'a testing program to determine the effect of corrosion rate upon the integrity of materials in the spent fuel pcol over the period of the license is needed.
- 16. Answering interrogatory number sevenreen (17),
the specific effects detailed in intervenor's contention 6 -
13b may become significant due to the cumulative effects of radiation, temperature, pool chemistry, etc. Experimental data concerning the effect of the time of pool residence upon the rates of reactions of effects listed in contention 13b is at present insufficient to state that these effects will be insignificant over the entire time period of the license.
- 17. Answering interrogatory number eighteen (18),
there is potential for electrolysis to occur where the Zircaloy and stainless steel come in contact.
- 18. Answering interrogatory number nineteen (19),
Zircaloy and stainless steel could be subject to electrolytic affects. The effect of the borated water, the temperature, and surface area ratio on the rate of reaction over the long-term is unknown.
- 19. Answering interrogatory number twenty (20), cor-rosive affects due to concentration of corrosive species
- such as chlorides could occur. Corrosive rates could also be influenced by the formation of differential aeration cells, leading to electro-chemical potentials between areas of high and low oxygen concentration. Effect on fuel rod integrity over the long-term due to such conditions in the crud layers has not been experimentally determined.
- 20. Answering interrogatory number twenty-one (21),
it is impossible to predict the thickness of crud layer which will build up in the Kewaunee spent fuel pool.
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- 21. Answering interrogatory number twenty-two (22),
oxygen or oxides could be trapped within the crud layers, forming a differential aeration cell. Electrochemical poten-tials between areas of high and low oxygen concentration could create a situation where the fuel clad would become anodic and be subject to corrosive attack.
Dated this U /, day of W! w/ 4; , 1978.
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~P'ATRICK WALSH Assistant Attorney General Department of Justice 114 East, State Capitol Madison, Wisconsin 53702 M M