ML19289F087
| ML19289F087 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 05/11/1979 |
| From: | Hoefling R, Ketchen E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19289F083 | List: |
| References | |
| NUDOCS 7906010339 | |
| Download: ML19289F087 (10) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY.cND LICENSING BOARD In the Matter of
)
)
DUKE POWER COMPANY
)
Docket No. 70-2625
)
(Amendment to Materials License
)
SNM-1773 for Oconee Nuclear Station
)
Spent Fuel Transportation and Storage )
at McGuire Nuclear Station)
)
NRC STAFF'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS N0 GENUINE ISSUE TO BE HEARD WITH RESPECT TO CONTENTIONS 1 AND 3 0F THE CAROLINA ENVIRONMENTAL STUDY GROUP AND (CESG) AND CAROLINA ACTION Caroli.ca Environmental Study Group Contention No.1 and Carolina Action Contention No. I read as follows:
Shipment of Oconee spent fuel to McGuire for storage is unacceptable as compared to other al terna tives:
Modification of the existing Oconee spent fuel pocls to provide additional storage capacity.
b.
Construction of a new separate spent fuel storage facility at the Oconee site.
c.
Construction of a new separate spent 2235 042 fuel storage facility away from the Oconee site bet otner than McGuire.
- 1. Approval of the pending application for re-racking at Oconee (dated February 2,1979), if approved befare June,1979, (see the transmittal letter from Duke Power Company dated February 2,1979 which submitted an application to modify tne Oconee spent fuel pool) would provide, with the existing storage capacity at the site, sufficient spent fuel storage space to discharge the spent fuel generated by the Oconee reac ars through June, 1983, based on the current Duke Power Company discharge schedule
'!90601053 %
. for Oconee, Units 1, 2, and 3, assuming that one full-core discharge capability for all three rez.ctors is not retained.
"NRC Staff Response to Natural Resource Defense Council Request to Applicant and Staff for Admissions dated April 2,1979 (April 17,1979)',' p.1.
2.
Duke Power Company's requests of February 7,1979 to expand the capacity of the spent fuel pool at the Oconee facility is being reviewed in accordance with NRC Staff environmental, and health and safety re/iew procedures.
Based generally on the NRC Staff's review and approval of similar requests from other utilities at other nuclear generating facilities in the past involving re-racking with spent fuel in the spent fuel pool, as a general matter, it would appear that re-racking of the Oconee spent fuel racks, with an approved procedure, will not cause undue risks to the health and safety of the public or workers and will not cause substantial adverse environmental inpacts.
Staff Responses to NRDC Request for Admissions of April 17, 1979, Nehemias Affidavit (re:
NRDC Contention 4(a)); Parsont Affidavit (re:
NRDC Contention 4(b)); Spitalny Affidavit (re:
CESG and CA +3).
3.
If the Staff keeps its present schedule of its review of the re-racking proposal, the Staff review would be completed prior to June 8,1979.
Staff response to NRDC request for admissions, p. 2.
4 Operation of the Oconee reactors without a full-core discharge capability does not endanger the health and safety of the public or workers or cause substantial udverse environmental impacts.
Ibid, p. 2.
2235 043
. 5.
Modification, that is, re-racking of the existing Oconee spent fuel pools to provide additional storage capacity will result in higher occupational or radiation dose exposure, approximately 125 man-rems.
Applicant's Response of March 28, 1979 to NRDC Interrogatories of March 8,1979. See EIA page 53.
This is roughly comparable to the range of man-rem exposure estimated by the Staff of 60 man-rems to 120 man-rems. Affidavit of Dr. J. Nehemias; Affidavit of Dr. Michael Parsont.
6.
The radiation dose exposure from re-racking is approximately comparable, although higher than,the radiation dose exposure calculated for trans-shipment and storage at McGuire. However, the economic costs of expansion of the storage capacity of Oconee spent fuel storage pools for Units 1 and 2 by re-racking at an estimated $6,000/ assembly to
$8300/ assembly and approximate exposure of 125-150 man-rems is greater than the transshipment and storage at McGuire proposal at a cost of
$2,000/ assembly for shipping and exposure of approximately 120 man-rems.
EIA 58. Applicant's March 27, 1979 response at p.13 to NRDC's Interrogatories of March 8,1979. Spitalny Affidavit (re:
CESG
& CA Contention 1).
7.
There is no regulatory requirement for any particular spent fuel storage capacity nor is the Regulatory Staff aware of any compelling safety basis for requiring maintenance of a full-core discharge capability.
Affidavit of T. Jerrell Carter.
2235 044
. 8.
The loss of full-core discharge capability is not an alternative to either re-racking or transshipment of spent nuclear fuel to McGuire for storage. dor is it a temporary alternative with respect to affecting the feasibility of the re-racking option.
EIA page 58.
Spitalny Affidavit (re:
NRDC #3); Spitalny Affidavit (re:
CESG & CA #2); Carter Affidavit.
9.
Reactor shutdown for lack of full-core discharge capability would cost 8
approximately 10 /yr or 100 million dollars per year.
Tnis includes the cost of maintaining the plant in a standby condition and buying alternative power.
EIA page 54. Applicant response of March 27, 1979, p.11, to NRDC interrogatories of March 8,1979.
- 10. Modification or re-racking of the existing Oconee spent fuel pools to provide additional storage capacity could be completed a year from the present date as a reasonable length of time estimated for installing compacted racks, (CESG Response to Staff Interrogatory No, dated April 11, 1979), or within three to six months after a license amendment approval according to the Applicant, (Applicant's Response of March 27,1979 to NRDC Interrogatories of March 8,1979).
The Staff review would be completed prior to June 8,1979 and installation could proceed after that time if the Staff keeps its present schedule for completion of its review of the re-racking proposal and that review is completed by June 8,1979.
(NRC Staff response of April 17, 1979 to NRDC's request for admission of April 2,1979.)
11.
Re-racking the Oconee spent fuel pools with poison rac<s will most likely require two to five months longer than re-racking with currently available non-poison rack technology. Applicant's Response dated March 27, 1979, page 9 to NRDC Interrogatories of March 8,1979.
2235 045
-S-
- 12. Re-racking with currently available non-poison rack technology will take approximately three to six months after approval by the NRC Staff of the application for amendment of the Oconee spent fuel pools to re-rack.
See Duke Power Company application for amendment to Oconee operating license to expand the spent fuel storage capacity of the Oconee spent fuels 1 and 2 by re-racking dated February 2,1979.
- 13. Applicant estimates that the cost of re-racking is now 125 man-rems.
Applicant response dated March 27, 1978 to discovery of NRDC of March 2, 1978: Duke Power Company application of February 2,1979 to re-rack th : Oconee spent fuel pools.
- 14. The transshipment option of the Oconee spent nuclear fuel to McGuire for storage is the preferred alternative when compared to the re-racking al terna tive.
EIA pages 52, 54, Table 10-1, page 58 and page 57 through 59. Spitalny Affidavit (re: CESG Contention 1); Spitalny Affidavit (re:
CESG & CA Contention 3).
Contention CESG 1(b) and Carolina Action Contention 1(b) and CESG Contention 1(c and Carolina Action 1(c.1/
Carolina Environmental Study Group Ceontention 1(b) and Carolina Action Contention 1(b) state as follows:
_1/ On April 12, 1979, in response to Staff's Motion to Compel, the Atomic Safety and Licensing Board issued an Order compelling Carolina Action to respond to discovery.
" Order Concerning Interrogatories, Determination of Discovery, and Schedule" ( April 12,1979).
To date, Carolina Action has not responded with material facts in response to Staff's interrogatories in accordance with the Licensing Board's Order to Compel.
2235 046
. Shipment of Oconee spent fuel to McGuire for storage is unacceptable as compared to other alternatives:
b.
Construct'.on of a new and separate spent fuel storage facility at the Oconee site.
Shipment of Oconee spent fuel to McGuire for storage is unacceptable as compared to other al ternatives:
Construction of a new and separate spent c.
fuel storage facility away from Oconee site but other than McGuire.
1.
Construction of a new and separate spent fuel storage facility at the Oconee site is an alternative since space exists at the site, and engineering and architectural devices could be used to devise a contiguous structure. CESG's Responses to Interrogatories of the Staff dated April 11, 1979, Duke Power Company's Responses of March 27, 1979 to NRDC interrogatories of March 8,1979.
The alternative of construction of a new and separate spent fuel storage facility could be constructed at the Oconee site from two years from the present date of April,1979 if Applicant uses its large work force on an expedited basis to participate in construction of a separate spent fuel pool at Oconee, (CESG Response to NRC Staff Interrogatories of April 11,1979) to five years (EIA, pp. 49-59).
2.
A new and separate spent fuel pool storage facility could be constructed in about two years from the present date of April,1980 at away from the Oconee site other than at McGuire to up to as much as five years. See, respectively,CESG Response to Staff Interrogatories of April 11, 1979 and EIA pages 50-52; Table 10-1, page 58 of the EIA.
2235 047
. 3.
Construction of an independent spent fuel storage installation by the Applicant is estimated to be from $10,000 per assembly to $34,000 per assembly plus shipping costs; and this option is not available for a number of years.
EIA Table 10-1; page 58. Applicant's Response of March 27, 1978 to NRDC Interrogatories of March 8,1979; CESG Response of April 11, 1979 to Staff Interrogatory le.
4.
Construction of a new and separate spent fuel storage facility away from the Oconee site but other than at the McGuire site as an alternative would involve extra handling which would be comparable to that required for McGuire storage. CESG Response of April 11, 1979 to Staff Interrogatory le. Nehemias Affidavit (re: NRDC Contention #4(a)
EIA, pp. 49-59.
5.
Since an on-s;te storage installation at Oconee could not be connected to the existing basins, it would be necessary to make transfers of fuel on site similar to transshipment to McGuire that would require trans-shipment from the Oconee spent fuel pool to the separate installation using shipping casks. The dose saving from transshipment to an ISFSI at Oconee is orily 10 percent of the total received or about 15 man-rems from the proposed action to transship to McGuire, largely attributable to the reduced dose to the truck drivers that would not be necessary if there were an available ISFSI facility at the Oconee site.
The 2235 048
. environmental impacts and costs of construction of an independent spent fuel storage installation (ISFSI) by the Applicant are greater than transshipping the spent fuel to McGuire Nuclear Station or re-racking the basin serving Oconee Units 1 and 2.
Although this option would meet the future need for spent fuel storage, it would not aid in solving the immediate shortfall of spent fuel storage capacity by the Duke Power Company at the Oconee site.
Spitalny Affidavit (re:
- CESG, Contentions 1 & 3; Nehemias Affidavit.
EIA, page 52.
6.
On a short-term basis, an ISFSI away from the Oconee site is not a viable alternative because Oconee will lose the retention of a full-core reserve in mid-1979 which will result in the ne'd to shut down in 1980 if no additional spent fuel storage is obtained.
EIA, page 51.
Spitalny Affidavits (re:
CESG & CA Contentions 1 anc 3.
Applicant's response of March 27, 1979 to NRDC interrogatories of March 8,1979; Spitalny Affidavit (re: NRDC Contention #3).
7.
Spent fuel storage fees for an ISFSI offsiet have been estimated to vary from $7,000 to $12,000 per year per assembly.
These costs include amortization of construction costs, handling costs, and other operational expenses. EIA, pages 51-52. Cost estimates of approximately $34,000 per year per assembly to construct an ISFSI at the Oconee site have been given.
Applicant's Response of March 27, 1979 to NRDC Discovery Request of March 8,1979.
2235 049
. 8.
Presumably, the costs of construction of an ISFSI by Applicant offsite could be even more expensive if on property, as yet unidentified by CESG, not owned by Duke Power Company. Applicant's responses of March 27,1979, pages 13-14 to Natural Resources Defense Council (NRDC)
Interrogatories to Applicant of March 8,1979.
9.
Use of an onsite, but separate spent fuel storage installation at Oconee would not significantly reduce the total dose received from similar ship-ments to offsite storage installations such as at McGuire.
See CESG Response of April 11, 1979 to Staff Interrogatory le.
EIA, pp. 49-59; Nehemias Affidavit; Spitalny Affidavit (re: CESG & CA Contention 1).
10.
The option of an onsite Oconee spent fuel storage installation versus transshipment to McGuire of one spent fuel assembly from Oconee to McGuire is estimated to result in a cumulative dose of 0.45 man-rems. Of this total, 0.4 man-rems is due to loading and unloading of the shipping casks.
An offsite storage installation at Oconee could not be connected to the existing basin; therefore, it would be necessary to make similar transfers using a shipping cask.
Thus, the dose saving between an onsite spent fuel storage installation at Oconee versus transshipment to McGuire would only be 10 percent of the total received, or about 15 man-rems, largely attributable to the reduced dose to the truck drivers. Assuming any degree of transshipment offsite to the offsite independent spent fuel storage installation, suggested by CESG's Contention ic, the savings in radiation dose between the transshipment to McGuire and the Oconee onsite ISFSI would be even less.
EIA, Chs. 5-6; EIA, pp. 49-59; Nehemias Affidavit.
2235 050
Spitalny Affidavit (re: CESG & CA Contention d3); Spitalny Affidavit (re: CESG & CA Contention #1).
11.
Dose exposure from transshipment of Oconee fuel to McGuire and trans-shipment cf Ocor:ae fuel to an ISFSI away from the Oconee site would be comparable, and the impacts insignificant.
Parsont Affidavit; Nehemias Affidavit.
See CESG Response of April 11, 1979 to NRC Interrogatory le.
2235 051
.