ML19291A640
| ML19291A640 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 04/02/1979 |
| From: | Roisman A National Resources Defense Council |
| To: | |
| References | |
| NUDOCS 7905240482 | |
| Download: ML19291A640 (7) | |
Text
i 3 pgffELATED CORRESPONDENCE g ".
/;. Q,,u,7 7 7,C Y h ",' g u
,-Q ~y aj,N s~
gnC gg7
,\\'/a s p
Q, 0'[;a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION q
- 3). r.
f[/g'Y
[
d
$6
~,
"lh.N
' MD "D In The Matter Of
)
)
DUKE POWER COMPANY
)
)
Docket No. 70-2623 (License Amendment for Transportation )
and Storage of Oconee Spent Fuel at
)
McGuire Nuclear Station)
)
NATURAL RESOURCES DEFENSE COUNCIL REQUEST TO APPLICANT AND STAFF FOR ADMISSIONS 1.
Approval of the pending application for re-racking at Oconee (dated February 2, 1979), if approved before would provide, with existing storage capacity at the site, sufficient spent fuel storage space to discharge the spent fuel generated by the Oconee reactors through 19
, assuming one full core discharge. capability for all three reactors is not retained.
2.
If Staff keeps its present schedule for completion of its review of the re-racking proposal, the Staff review would be completed prior to 3.
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 adverse environmental impact.
4.
Re-racking the spent fuel pool at Oconee as proposed by the Applicant does not endanger the health and safety of the public or workers and does not cause substantial adverse f
l 2
environmental impacts, even if no spent fuel is transshipped to McGuire prior to or during the re-racking.
5.
If the Applicant is unable to ship spent fuel from Oconee to an away-from-reactor storage facility prior to 1995, it would cost less money to Applicant's ratepayers to now expand existing spent fuel capacity at Oconee or to build new capacity at Oconee than to ship spent fuel from Oconee to McGuire.
6.
Storage of spent fuel from Oconee in the McGuire spent fuel pool during 1979 would make any subsequent modifi-cation in the McGuire spent fuel pool more expensive.
7.
Total exposure of all workers to radiation associated with re-racking the Oconee spent fuel pool will be reduced more if the spent fuel is transferred to spent fuel casks until the re-racking is completed than if it is transferred to McGuire where it would be unloaded from the casks and placed in the McGuire spent fuel pool and later it had to be removed from the McGuire spent fuel pool for storage in an interim spent fuel storage facility.
8.
Total exposure of all workers from spent fuel haadling would be lower with respect to the McGuire and Oconee facilities if at-reactor storage capabilities (including building a new pool at Oconee with maximum technologically feasible re-racking and exoanding the existing pool at McGuire with maximum technologically feasible re-racking to hold the lifetime requirements for spent fuel from each plant) were
3 utilized rather than transshipment to McGuire, further trans-shipment to an interim away-from-reactor storage facility and finally transshipment to a permanent waste repository.
(Assume all spent fuel handling is done with essentially the same equipment and techniques.)
9.
Shipment of spent fuel as proposed from Oconee to McGuire with the protective measures proposed increases the risk that the spent fuel would be released by the intentional act of someone other than the Applicant over the risk involved if it remained at the Oconee site with the protective measures involved there.
10.
Reliable expert analysis has concluded that a group of 12 outsiders and 3 insiders planning an attack against a nuclear facility is a credible threat.
U.S.
Atomic Energy Commission, Special Safeguards Study, by David M. Rosenbaum,
'J o h n N. Googin, Robert M. Jefferson, David J.
- Kleitman, William C.
Sullivan, 1974.
See also U.S. Nuclear Regulatory Commission, Report of Task Force on Allegations by James H.
Conran, April 29, 1977, p.
4-25; U.S.
Congress, Office of Technology Assessment, Nuclear Proliferation and Safeguards, July 1977, Chapter VIII " Control of Proliferation" p. 197.
11.
Reliable expert analysis has concluded that available methods for gathering information on possible sabotage against government or private property is such that a threat of the size described in the proceding paragraph can go undetected until an overt action is taken.
MITRE Corporation, The Threat to Licensed Nuclear Facilities, MTR-7022, by Brennan, et al.,
September 1975, p.
143.
4 12.
The Interim Repert SAND 77-1927 (pp. 190-200) presents a reliable estimate of the potential damage from an intentional release of radioactivity from a spent fuel cask of the general type proposed for the transshipment of Oconee spent fuel to McGuire.
Respectfully submitted, m
Y s
4 Anthony Z.,Rosman Natural Reso Ices Defense Council 917 15th St eet, NW j
Washington, D.C.
20005 (202)737-5000 Dated:
April 2, 1979
fl
\\gd f(p, RELATED CORRESPONT>ENCE k'
,6'1 A
Q +" %g 8 -
o
\\
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
b b
%'s 38
- e 6
/)3 N
In The Matter Of
)
'oDipT
)
DUKE POWER COMPANY
)
Docket No. 70-2623
)
(License Amendment for Transportation )
and Storage of Oconee Spent Fuel at
)
McGuire Nuclear Station)
)
CERTIFICATE OF SERVICE I hereby certify that copies of NRDC REQUEST TO APPLICANT AND STAFF FOR ADMISSIONS were mailed today, April 2, 1979, to all persons on the attached service list.
Wg Anthony Z. h h n
Marshall E. Miller, Chairman Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Cadet H.
Hand, Jr., Director Bodega Marine Laboratory Post Office Box 247 Bodega Bay, California 94923 Dr. Emmeth A.
Luebke Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 James Michael McGarry, III, Esq.
Joseph B.
Knotts, Jr., Esq.
Debevoise & Liberman 1200 17th Street, N.W, Washington, D.C.
20036 Richard K.
Hoefling, Esq.
Office of Executive Legal Director U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Docketing and Service Section Jeremy Block Safe Energy Alliance 1707 Lombardy Circle Charlotte, North Carolina 28203 Rich -rd P.
Wilson Assistant Attorney General 2600 Bull Street Columbia, South Carolina 29201 Shelley Blum, Esq.
418 Law Building 730 East Trade Street Charlotte, North Carolina 28202 Jesse L.
Riley Carolina Environmental Study Group 854 Henley Place Charlotte, N.C.
28207
r Brenda Best Carolina Action 305 East Chapel Hill Street Durham, North Carolina 27702 Chuck Gaddy NC PIRG Davidson College Davidson, North Carolina 28036 William Larry Porter Associate General Counsel Duke Power Company 422 S.
Church Street Charlotte, N.C.
28242 O
e