ML19275A467
| ML19275A467 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 09/07/1979 |
| From: | Roisman A National Resources Defense Council |
| To: | |
| Shared Package | |
| ML19275A461 | List: |
| References | |
| NUDOCS 7910040475 | |
| Download: ML19275A467 (8) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of
)
)
DUKE POWER COMPANY
) Dkt. No. 70-2623
)
(Amendment to Operati 'q License SNM-1773 )
for Oconee Spent Fue) ansportation and )
Storage at McGuire Nuviear Station)
)
- his submission is in response to the Board's request of August 9, 1979 (Transcript, p. 3715).
INTRODUCTION While a nu-her of options were discussed in the tran -
script (see pages 1059-1060), the c' ear-cut options available to Duke Power ab this time, independent of governmental or second party action, that were discussed in detail in the transcript are:
Transshipment, Reracking with poisoned racks and Constructing an ISFSF.
Other options were discussed that depended on second party or government action:
Reprocessing of spent fuel and Construction of AFR's.
These cptions are highly tentative both with respect to initiation and timeliness.
In this submission we shall only discuss the independent options of Duke Power.
1998 176 7 910 040 775~
DUKE POWER'S OBJECTIVE Duke Power states that the primary objective of their spent fuel management program is the retention of 1 FCR at each site (Oconee in this action).
(Transcript, p. 1036, lines 20-22).
This, of course, is not an NRC Regulation and the NR staff stated that they would approve a plant with anything from as little as 1/3 of a core storage to a full lifetime.
(Transcript, p. 3743, lines 4-10).
In this sub-mission, we shall consider the schedule for options both with retaining an FCR and without an FCR but with retaining suffi-cient space for refueling on a timely schedule., In this respect, it will be shown that the record indicates that Duke Power has the time available in which to exercise its options without
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transshipment and still maintaining an FCR.
DECISICS DATES Duke Power indicated that they chose to make a decision at the last moment.
(Transcript, p.
937, lines 3-9).
This last moment is the lead time decision date and represents that point in time when an option is exercised so that the project will be completed when needed.
The record has considerable discussion related to the I
lead times for both poisoned reracking and the construction of an ISFSF.
These lead times are relative to the maintenance of an FCR at Oconee but not to simply maintaining storage capacity until project completion.
As stated above, this submission will consider both cases.
Therefore, it is relevant to first 1098 1/7
discuss present storage capacity.
Present Storage Capacity Here we shall consider the limits of present storage capacity with and without transshipment of 300 assemblies.
Terminal Date Without Transshipment Transcript FCR September 1982 p.
842, lines 3-5 Loss of Storage September 1983 With Transshipment FCR September 1984 p.
842, lines 15-20 Loss of Storage September 1985 The terminal date for loss of storage was set 12 months 6
after the loss of FCR since Oconee 1 and 2 will be on an-18-month cycle and an FCR can tolerate the refueling of 2 reactors.
(Transcript, p. 782, lines 2-5).
The transshipment of 300 assemblies will allow some 4 reactor refuelings and we allowed 2 years for this since Oconee 3 is on a yearly cycle.
Lead Times The lead time for the construction of an ISFSF is indepen-dent of the reactor operations.
The lead time for reracking with poisoned racks is however dependent on the reactor operations since sufficient space must be allowed in the pools for the re-racking operation and this must also mesh with the refueling schedule.
(Transcript, pp. 3480-3486).
1098 178
Lead Times Transcript Reracking 16 months p.
1092, lines 5-12 p.
3480, lines 7-14 p.
3485, lines 1-4 Construction of ISFSF 45 months p.
1114, lines 10-13 The 16 months for reracking includes 12 months for licensing and 4 months for construction.
The Decision Dates As mentioned above, the decision dates for reracking are dependent upon the reactor operations.
Therefore the dates given below for reracking are based upon the dates given in the Transcript at pages 3480, _ lines 7-14.
Reracking with Poisoned Racks Decision Dates Without Transshipment December 1979 With Transshipment December 1981 ISFSF Construction Decision Dates Na reracking FCR No FCR Without Transshipment Not possible December 1979 With Transshipment December 1980 December 1981 Reracking with poison racks could add another 2-4 years to these decision dates.
The discussion in the Transcript at pages 3484-3486 suggest there may be some problems with reracking the Oconee Unit 3 pool.
The 2 year decision date increase is based upon the reracking of only Units 1 and 2.
1998 i/9
This filing is based upon the record and not upon an independent evaluation of the underlying factors.
Respectfully submitted,
/
.f oi.an R
Anthony
/
d t
10Y8 180
This filing is based upon the record and not upon an independent evaluation of the underlying factors.
Respectfully submitted, Anthony,. Reitman G
8 1098 181
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of
)
)
DUKE POWER COMPANY
)Dkt. No. 70-2623
)
\\ *~ : t es' '
(Amendment to Operating License SNM-1773
)
d for Oconee Spent F:al Transportation and
)
S Storage at McGuire Uuclear Station)
)
e$,c SEP 71378 D
g.s q M ce'b CERTIFICATE OF SERVICE b
d' Q>
This is to certify that on September 7, 1979, one copy each of the NRDC SulM ssion in Response to the Board Request
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and the NRDC Opposition To Staff Motion For Interim Protective Order were hand delivered to the individuals designated by an asterisk (*) on.the attached list and sent by U.S. mail to the other individuals on the attached list.
/
~a
/
' Anthony Z.,RoIsman
-'w t
1098 182
DUKE SERVICE LIST Marshall E. Miller Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission liashington, D.C.
20555 Dr. Cadet H. Hand, Jr. Director Bodega Marine Laboratory P.O. Box 247 Bodega Bay, California 94923 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 James Michael McGarry, III, Esq.
Joseph B.
Knotts, Jr., Esq.
Debevoise and Liberman
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1200 17th Street, N.W.
Washington, D.C.
20036 Richard K. Hoefling, Esq.
Office of Executive Legal Director U.S. Nuclear Regulatbry Commission Washington, D.C.
20555 William. Larry Porter Associate General Counsel Duke Power Company 422 South Church Street Charlotte, Ncrth Carolina 28242 Richard P. Wilson Assistant Attorney General 2600 Bull Street Columbia, South Carolina 29201 Jesse L.
Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207 Chuck Gaddy North Carolina Public Interest Research Group Davidson College Davidson, North Carolina 28036 Secretary of the Commission U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 ATTN:
Docketing and Service Section 1 0 9 8 i B'3
^
- Joseph Hendrie, Chairmag U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Peter Bradford, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Richard Kennedy, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- John Ahearne, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
'20555 Alan S.
Rosenthal, Esq.
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Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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Dr. John Duke Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Michael Ferrar,.Esq.
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 1998 184