ML19289F413
| ML19289F413 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 04/11/1979 |
| From: | Cochran T, Roisman A, Tamplin A National Resources Defense Council |
| To: | |
| Shared Package | |
| ML19289F407 | List: |
| References | |
| NUDOCS 7906070341 | |
| Download: ML19289F413 (12) | |
Text
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9 UNITED STATES OF AMERICA 6[
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$ +h. I NUCLEAR REGULATORY COMMISSION
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7 In The Matter Of
)
DUKE POWER COMPANY
)
)
Docket No. 70-2623 (Amendment to Materials License SNM-1773 )
for Oconee Nuclear Station Spent Fuel
)
Transportation and Storage at McGuire
)
Nuclear Station)
)
NATURAL RESOURCES DEFEFSE COUNCIL 4 NSWER TO INTERROGATORIES OF THE REGULATQRY STAFF 1.A.
The proposed program is a DOE proposal to build away-from-reactor storage capability for the nuclear industry.
The detailed are contained in an October 18, 1977, DOE press release, the DOE draft impact statements on that proposal (Storage of U.S. Spent Power Reactor Fuel, DOE /E.'S-0015-D, August 1978; Supplement, DOE /EIS-0015-DS, Decerber 1978 ;
Preliminary Estimates of the Charge for Spent-Fuel Storage and Disposal Services, DOE /ET-0055, July 1978; Charge for Spent Fuel Storage, DOE /EIS-0041-D, Decerter 1978), and the DOE legislative proposal sent to Congress on creation of a re-volving fund for construction of an AFR.
1.B-E.
The proposed act.on is to transship spent fuel 4
from Oconee to McGuire.
To have independent value, that transshipment would have to be capable of solving the spent fuel storage problem without depending upon use of another interim measure.
Solving the spent fuel storage problem means having storage space sufficient to receive all spent fuel to 2231 245 79060703pf
2 be generated by the reactor (in this case Oconee) between now and when the spent fuel can be disposed of in a permanent repository.
The earliest date for such a repository is, in our judgment, not until the mid-to late 1990s.
Prior to that time Oconee will need another spent fuel storage solution.
The present transshipment is merely a short-term solution waiting for that long-term solution.
The long-term solution which transshipment encourages is construction of an AFR.
The solutions which will tend to be foreclosed by transshipment are maximum compaction and re-racking at both Oconee and McGuire and construction of new spent fuel storage capability at Oconee.
In our view, the solution to spent fuel storage problems other than by plant shutdown is influenced primarily by technology and economics.
The cost of building a new spent fuel storage pool at Oconee is a fixed dollar amount.
If the utility transships before it adopts that option, then the cost of at-reactor storage becomes the cost of trans-shipment plus the cost of the new pool.
In addition, the failure to move now to expand at-reactor storage with a new pool creates an apparent "need" for the AFR.
In addition, the McGuire pools are not radioactive.
They could be modified or expanded now without any of the risks identified by the Staff in the EIA for Oconee where changes are made to a pool which has already had spent fuel in it.
Allowing Oconee spent fuel to go into the McGuire spent fuel pool inhibits the maximum utilization of at-reactor storage for McGuire spent fuel at McGuire.
2231 246
3 1.F.
Documents include those identified in 1.A. plus the EIA for Oconee, pp, l.G.
Arthur R.
Tamplin, Thomas B.
Cochran, Dimitri Rotow.
1.H.
No specific plans now exist.
l.I.
None have been determined at this time.
l.J.
Not applicable at this time.
2.A&B.
The quantity of spent fuel to be moved, the number of casks, trucks and shipments required, the number of members of the public and workers which will be and could be exposed to radiation due to routine, accidental or intentional releases from handling and shipping spent fuel, the alleged dollar and environmental benefits of the proposed action over allowir.g the Oconee reactor to be shut down, the increased risks to the health and safety of the public living in the vicinity of the McGuire facility without any comparacle increase in benefi.s to that public, the foreclosing of the environ-mentally preferable option of expanded storage of spent fuel at Oconee, and the long-term implications of another spent fuel storage half-measure which allows increasing nuclear wastes without a solution and without progress toward a solution for the permanent and safe storage of such waste are all factors which make approval of the proposed action a major federal action with significant impact on the environment.
2.C&D.
We have not completed our review of the EIA.
But by definition the document is incomplete because it is not 2231 247
4 an EIS and did not have the benefit of the public and agency comment on a draft which would have served to enlighten the Staff and the record in this proceeding.
2.E.
None 2.F.
Arthur R.
Tamplin, Thomas B.
Cochran.
2.G.
None at this time.
2.H.
None have been determined at this time.
2.I.
Not applicable at this time.
3.A.
No.
We contend it has not been adequately explored to answer the question posed.
3.B.
Not applicable.
3.C.
No.
We contend the Applicant and Staff assertions that this option is untenable are not thoroughly analyzed or well documented.
3.D.
Not applicable.
3.E.
Expand the existing spent fuel storage pools at the Oconee site to their maximum capacity using state-of-the-art compaction techniques, including, for example, use of high density racks made of neutron absorbing materials (poison racks).
Then, further expand the storage capability at the site by expanding the pools themselves and constructing new pools.
We believe this alternative is superior because it will reduce the risks of routine, accidental and intentional (sabotage) releases of radioactivity.
We are unaware of any adequate studies of this alternative or any analyses comparing this alternative with the proposed action.
2231 248
5 3.F.a.
Reduction in occupational exposure to low levels of ionizing radiation.
b.
Reduction in the public exposure to low levels of
'anizing radiation during off-site transportation of spent fuel.
~
c.
Reduction in the probability of accidents involving the transport of spent fuel casks.
d.
Reduction in the probability of industrial sabotage of spent fuel casks during shipment and the probability of highjacking and subsequent threats of malevolent acts involving these shipments.
3.G.
As discussed in response to 3.E.
above, we are referring to the use of state-of-the-art high density racks made of neutron absorbing materials (poison racks).
3.H.
Same as answer to 3.F.
above.
3.I.a.
Letter of Feb.
2, 1979, from William O. Parker, Jr.,
to Harold R. Denton, with Attachment 1,
" Proposed Technical Specification Revision."
b.
" Environmental Impact Appraisal Related to Spent Fuel Storage of Oconee Spent Fuel at McGuire Nuclear Station -
Unit 1 Spent Fuel Pool," Docket No. 70-2623, USNRC Dec. 1978.
c.
" Generic Environmental Assessment on Transportation of Radioactive Materials Near or Through a Large Densely Pcpulated Area," Preliminary Report, Ducharme, et al.,
Sandia Laboratories, SAND 77-1927.
d.
Proposed Final Environmental Statement, Liquid Metal Fast Breeder Reactor Program, WASH-1535, USAEC, Dec. 1974, Vol.
VI, pp. VI. 38-53 through VI. 38-85.
2231 249
6 e.
" Domestic Safeguards," USNRC, NUREG-0524, Jan. 1979.
f.
Letter of April 13, 1978, to Senator John Glenn from Thomas B.
Cochran and enclosures.
g.
Numerous documents related to the health effects of ionizing radiation, in particular those cited in NRDC's submissions to NRC associated with NRDC's Petition to Amend 10 CFR 20.101 - Exposures of Individuals to Radiation in Restricted Areas (pending).
3.J.
Thomas B. Cochran and Arthur R.
Tamplin.
3.K.
None at this time.
3.L.
The individuals have not been identified at this time.
3.M.
Since witnesses have not been identified, the substance of their testimony cannot be provided at this time.
4.A.
We find it somewhat disconcerting that the NRC should pose this interrogatory since it appears that NRC itself has not addressed the question but simply accepted the Applicant's views:
The applicant has estimated that the cost of reracking of the spent fuel pool serving Unit 1 and 2 will be S6,000 per fuel assembly and the radiation dose to the work force to be 150 man-rem.
[EIA, p. 53.]
The NRC Staff seems to prefer basing its judgments on the Applicant's snalysis and thereby bypass the effort required to do the requisite analysis on its own.
No analysis is presented to demonstrate the consequences of the probable situation wherein the utilities will have to 2231 250
7 maintain management of their spent fuel over time periods greater than the lifespan of the reactor.
There is no guar-antee that any ISFSI will become available for domestic spent fuel.
Moreover, there is no substantial evidence to indicate that a means of disposal of spent fuel can be developed over the lifetime of the reactor.
In these cases, utilities would be required to construct additional storage pools at their reactors.
The plan proposed here is not responsive to this potential but simply imposes the need for additional fuel handling and transportation in the event that these likely circumstances will prevail.
Even setting aside these likely events, the DOE states:
There is considerable DOE interest in minimizing AFR storage requirements and shipments by encouraging the use of at-reactor storage by further densifica-tion and/or expansion.
It is assumed that there would be economic and other advantages to the utilities of keeping their spent fuel at their own reactor sites rather than shipping it to interim AFR storage basins.
[ DOE /ET-0055, July 1978, p.
3.]
Since ALARA requires a cost / benefit analysis, the above state-ment by DOE indicates that there are monetary benefits avail-able to reduce exposures associated with at-reactor storage.
This necessary analysis is not presented in any satisfactory manner by the NRC Staff.
4.B.
It is our contention that the induction of cancer and genetic effects represents major costs.
We further propose that these costs, while very high, are unquantifiable.
Nevertheless, referring to the answer to 4.A.
above indicates 2231 251
8 that there are dollar benefits available from use of at-reactor storage that could be applied to ALARA.
4.C.
We refer here to those references cited above and to those cited relative to Interrogatory 3.
4.D.
Thomas B. Cochran, Ph.D.,
and Arthur R.
- Tamplin, Ph.D., Natural Resources Defense Council.
4.E.
Not determined at this time.
4.F.
Not determined at this time.
4.G.
Not determined at this time.
5.A.
NRDC does not so contend.
5.B.
None.
5.C.
None 5.D.
Thomas B.
- Cochran, Ph.D., and Arthur R.
- Tamplin, Ph.D., Natural Resources Defense Council.
5.E.
None planned at this time.
5.F.
None have been identified at this time.
5.G.
Witnesses have not been identified as yet and consequently the substance of their testimony cannot be provided at this time.
6.A.
An act or process tending to hamper or hurt.
6.B.
The shipping casks are vulnerable to the current NRC threat characterization for industrial sabotage against nuclear, cower reactors and facilities handling strategic quan-tities of SUM, as contained in 10 CFR Part 73 (see NUREG-0254, 2231 252
9
- p. B-1, 2).
This represents a serious risk because credible threats can cause the release of significant quantities of gaseous and volatile fission products and in the more populated areas can cause serious health consequences and land contamin-ation.
The probability that these threats, considered credible, will be realized is highly uncertain and the NRC and the intelligence community can provide no assurance of detection of these threats prior to an attempted malevolent act.
6.C.
Hijackings ad blackmail threats.
6.D.
See answer to 6.B.
above.
Hijackings and black-mail events are serious because of the social unrest the*f cause.
6.E.
SAme as those cited in response to 3.I.
above.
6.F.
Arthur R. Tamplin and Thomas B. Cochran.
6.G.
None at this time.
6.H.
None have been identified as yet.
6.I.
Same as 5.G. above.
2231 253
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7 UNITED STATES OF AMERICA b
PUCLEAR REGULATORY COPMISSION pK0* #
E Cy 8
In The Matter Of
)
)
DUKE POER CO.WM
)
Docket No. 70-2623
)
(Amendment to Materials License SNM-1773
)
for Oconee Nuclear Station Spent Fuel
)
Transportation ar.d Storage at McGuire
)
Nuclear Station)
)
AFFIDAVIT OF ANTHONY Z.
ROISMAN, ESO.
City of Washington
)) ss:
District of Columbia )
I, Anthony Z.
Roisman, Esq., hereby depose and say:
1.
I am employed by the Natural Resources Defense Council, Inc., 917 15th Street, N.W.,
Washington, D.C. 20005.
2.
I am primarily responsible for answers to the NRC Staff's interrogatories relating to NRDC's Contentions 1,
2, and 3a&b.
All information contained in those answers is true and correct to the best of my knowledge.
fr~ //T%,
m Anthony Z. _Roisman 7731 254 Subscribed and sworn to before me this ll N day of April 1979.
V20 (GdT pot.'.ry Putilfc
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN In The Matter Of
)
)
DUKE POWER COMPANY
)
Docket No. 70-2623
)
(Amendment to Materials License SNM-1773 )
for Oconee Nuclear Station Spent Fuel
)
Transportation and Storage at McGuire
)
Nuclear Station)
)
AFFIDAVIT OF THOMAS B. COCHRAN. PH.D.
City of Washington
)) ss:
District of Columbia )
I, Thomas B.
Cochran, Ph.D., hereby depose and say:
1.
I am employed by the Natural Resources Defense Council, Inc., 917 15th Street, N.W.,
Washington, D.C.
20005 2.
I am primarily responsible for answers to the NRC Staff's interrogatories relating to NRDC's Contentions 3c&d, 5 and 6.
All information contained in those answers is true and correct to the best of my knowledge.
Thomas B. Cochran, Ph.D.
Subscribed and sworn to before me this day of April 1979.
2231 255 Notary Public
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of
)
)
s DUE POER COMANY
)
Docket No. 70-2623
)
(Amendment to Materials License SNM-1773 )
for Oconee Nuclear Station Spent Fuel
)
Transportation and Storage at McGuire
)
Nuclear Station)
)
AFFIDAVIT OF ARTHUR R.
TAMPLIN, PH.D.
City of Washington
)
)
ss:
District of Columbia )
I, Arthur R. Tamplin, Ph.D., hereby depose and say:
1.
I am employed by the Natural Resources Defense Council, Inc., 917 15th Street, N.W.,
Washington, D.C.
20005.
2.
I am prime;ily responsible for answers to the NRC Staff's interrogatories relating to NRDC's Contention #4.
All information contained in those answers is true and correct to the best of my knowledge.
Arthur R. Tamplin, PhYD.
2231 256 Subscribed and sworn to before me thin il d day of April, 1979.
(
yotary Public l