ML20027A099
| ML20027A099 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 09/29/1978 |
| From: | Berson B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7810110023 | |
| Download: ML20027A099 (39) | |
Text
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NRC PUBLIC DOCUENT M
'9/29/78 0
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY C0FlilSSION
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'N.-o BEFORE THE ATOMIC SAFETY AND LICEN qiSII Y C C
M In the Matter of
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Docket Nos. 50-26 (3
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WISCONSIN ELECTRIC POWER 50-301 COMPANY g
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Amendment to License Nos. LF.s-4 (Point Beach Nuclear Plant, and DPR-27 (Increase Spent Fuel Units 1 and 2)
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Storage Capacity)
NRC STAFF FIRST SET OF INTERROGATORIES 70, AND REQUEST FOR THE PRO-(
DUCTION OF DOCUMENTS FROM, INTERVENOR LAKESHORE CITIZENS FOR SAFE ENERGY The Nuclear Regulatory Commission (NRC) Staff h'ereby requests that the Intervencr, pursuant to 10 CFR 92.740b, answer separately and. fully, in writing under oath or affirmation, the following interrogatories within 30 days from the date of mailing of this document.
For each response to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of the response.
.r If additional information becomes available with rescect to one or more of the answers af ter the Intervenor has answered these interrogatories, the Staff requests that the answers be amended in a, timely manner to provide such additional information.
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The NRC Staff further requests that the Intervenor, pursuant to 10 CFR 52.741, provide. copies of, or make available for Staff inspection and copying, the documents designated by the Intervenor in response to certain of the accompanying interrogatories within 30 days after service of this request.
i, GeneralInterrogatoriesE G-1.
State whether or not you intend to present any witnesses in this proceeding on the subject of a) Contention 1 j) Contention 3h (s) Contention 16b~
4 b) Contention 2 k) Contention 5 (t) Contention 16c c) Contention 3a
- 1) Contention 6 (u) Contention 16d d) Contention 3b m) Contention 7 (v
Contention 16e e) Contention 3c (n) Contention 8 (w
Contention 16f f) Contention 3d (o) Contention 9 (x
Contention 169 i
) Contention'3e (p) Contention lla (y) Contention 16h l
l Contention 3f (q) Contention lib (z) Contention 161 Contention 3g (r) Contention 16a i
and _ provide the names, addresses, educational background, and professional qualifications of'those witnesses you intend to.;present.U Interrogatories in this section should be answered with respect to 6
' each contention.
U Contentions 1-16i' refer to those contentions set forth in Attachment A which the Staff believes states those contentions.of Lakeshore Citiz' ens for Safe Energy which were admitted as matters in controversy.in this proceeding by order of the Atomic Safety and Licensing Board,. dated September 1,1978, following the August 17, 197.8 special prehearing_
conference.
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L A
G-2.
Provide summaries of the views, position, or proposed testimony on a) Contention 1 j) Contention 3h Contention 16b b) Contention 2 k)
Contention 5 Contention 16c c) Contention 3a
- 1) Contention 6 Contention 16d (d) Contention 3b (m) Contention 7 v) Contention 16e (e) Contention 3c (n)
Contention 8 w)
Contention 16f (f) Contention 3d
() Contention 9 (x) Contention 169 (g) Contention 3e
() Contention lla (y) Contention 16h (h) Contention 3f
() Contention lib (z) Contention 16i (i) Contention 3g (r) Contention 16a
(
of all persons named in response to' Interrogatory No. G-1 that you intend to present during this proceeding.
G-3.
Identify by author, title, date of pus 1tcation and publisher, all books, documents, and papers that you intend to employ.or rely upon in presenting your direct case on (a) Contention 1 (j) Contention 3h s
Contention 16b b) Contention 2 (k) Contention 5 t
Contentica 16c c) Contention 3a (1) Contention 6 u
Contention 16d d) Contention 3b (m) Contention 7 (v
Contention 16e (e) Contention 3c (n
Contention 8 (w
Contention 16f (f) Contention 3d (o
Contention 9 (x
Contention 16g.
g) Contention 3e (p
Contention lla (y
Contention 16h-h) Contention 3f (q) Contention 11b (z) Contention 161 i) Contention 3g (r) Contention 16a :
and provide copies of, or make available for Staff inspection and copyin.g, these items.-
G-4.
If the representations made in (a) tontention 1 (j) Contention 3h (s) Contention 16b (b) Contention 2 (k) Contention 5
'(t) Contention 16c (c) ' Contention 3a (1) Contention 6 (u) Contention 16d (d) Contentien-3b-(m) Contention 7 (v) -Contention 16e
' (f))
.(e Contention 3c (n) Centention 8 (w) Contentien Mf Contentica 3d (o) Ccatention 9 (x) Contention 16; (g) Contention 3e (p) Contention. lla
'(y) Contention-lCh
-(h) ' contention 3f (q) Contention lib (z) Contention 16i
.(i) Contention 3 '
(r) Contention 163 9
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o are based in whole or in part on any documents prepared by the Applicant or NRC Staff which you contend are deficient, specify which documents, and the particular portions thereof, you regard as deficient and explain why they are deficient.
G-5.
Identify by author', title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in k
conducting your cross-examination of witnesses for other parties who may testify in connection with a
Contention 1 (j
. Contention 3h (s
Contention 16b b
Contention 2 k
Contention 5 Contention 16c c
Contention 3a 1
Contention 6 Contention 16d d
Contention 3b m
Contention 7 Contention 16e e
Contention 3c (n) Contention 8 (w
Contention 16f (f
Contention 3d (o) Contention 9 (x
Contention 169 (g)- Contention 3e (p) Contention lla (y
Contention 16h (h) Contention 3f (q) Contention lib (z
Contention 161 (f) Contention 3g (r) Contention 16a Specific Interrocatories
-Contention 1
.f 1-1.
Define with particularity the terms " sign'ificance" and "significant",
as used in the context of Contention 1 and quantify the level at
. which an incremental. increase in emissions is significant.
1-2.
Indicate specifically each and every type of analysis of incremental airborne radioactive emissions you contend must be performed and state why such analysis is necessary.
.Is.
1-3.
Do you contend that incremental airborne radioactive emissions as a result of the proposed spent fuel expansion wil1 be found signi-ficant?
1-4.
If your answer to Interrogatory No.1-3 is other than an unqualified no, explain fully why and under what circumstances incremental radioactive emissions will be significant.
(
1-5.
If your answer to Interrogatory No.1-3 is other than an unqualified no, explain fully why the applicant's airborne monitoring program must be considered. Specify what you mean by " considered."
1-6.
Explain fully why monitoring results sh'ould be published in the local newspaper.
Contention 2 I
2-1.
Define specifically the term "effect" as used in the context of this contention.
',s 2-2.
S'pecify each and every combined or accumulated effect (including the biota affected, if any) which you contend will result from increased spent fuel storage at Kewaunee and. Point Beach.
2-3.
provide the complete scientific basis for each and every combined or ac-cumulated effect identified in your res;Icnse to Interrogatory No. 2-2.
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. y Contention 3a 3a-1.
Quantify the phrase "within a short period" as used in this contention in terms of appropriate units of time.
3a -2.
Describe fully each and every mechanism or event which would I
require both cores to be off-loaded into the spent fuel pool within a short periad.
3a-3.
Describe and explain fully the factual basis for the contention that coolant circulation-flow has been reduced by the increased numbers of fuel assemblies and storage racks.
1 Quantify the reducti,on in coolant circulation-flow you expect due 3a-4.
I to increased storage of spent fuel and provide all calculations and analyses which support this reduction.
.f 3a-5.
Describe and explain fully the factual basis for your contention that the water temperature of the spent fuel pool wil' be increased 1
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by, increased storage of spcat fuel.
3a-6.
Quantify the increase in pool water temperature you expect due to increased spent fuel storage and provide all calculations and -
analyses which support this increase...
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F Contention 3b Specifically identify and describe what increased worker activity 3b-1.
is necessitated by compaction referred to in this contention.
3b-2.
Describe separately and fu'ly each and every mechanism by which
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increased worker activity nesessitated by compaction could block (1) the coolant water discharge pipe and (2) the coolant water entrance pipe and state your basis.
3b-3.
Define " blockage" as used in this contention.
3b-4.
Describe separately and fully the "results" and consequent effects of a blockage of (1) the coolant water discharge pipe and (2) the
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coolant water entrance pipe.and state your basis.
Contention 3c
.i 3c-1.
Defin,e the term " emergency core unload situations" as used in the context of this contention.
3c-2.
Define " normal" core unload situation as used in the context of this contention.
.
- 3c-3.
Describe fully and separately each and every mechanism or event which could cause the loss of both storage pool coolant pumps under (a) normal core unload situations and (b) emergency core unload situations.
3c-4.
Describe fully and separately the factual basis for each mechanism
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or event identified in your response to Interrogatory No. 3c-3.
3c-5.
Describe fully and separately each and every mechanism or event by which the increased heat load caused by compaction may cause boiling in the spent fuel under (a) normal core unload situations and (b) emergency core unload situations.
3c-6.
Describe fully and separately the factual basis for each and every r
mechanism identified in your response to Interrogatory No. 3c-5.
3c-7.
Specify each and every emission possibihity you contend could result '"in the event the fuel pcol should boil due to _-the increased heat load caused by compaction."
3c-8.
State the factual basis for each emission possibility identified in your response to Interroga' tory No. 3-7.
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G Contention 3d 3d-1.
Describe fully and separately each and every mechanism by which loss of volume of coolant water in the spent fuel pool may occur and explain fully 'the factual basis for each such mechanism identi-fied.
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3d-2. Quantify the loss of volume you expect for each mechanism identi-fied in your response to Interrogatory 3d-l and explain fully your factual basis.
3d-3.
Describe fully and separately each and every mechanism by which loss of volume or flow of service water through the heat exchanger may occur and explain fully the factual basis for each such mechanism identified.
3d-4. Quantify the loss of volume or flow you expect for each mechanism
. identified in your response to Interrogatory No. 3d-3 and explain
.r fully your factual basis.
3d-5.
Describe fully and separately each and every mechanism by which-loss of the service water pumps may occur and explain fully the factual basis for each such mechanism identified.
i
. 3d-6.
Quantify the loss of volume you expect for each mechanism identified in your response to Interrogatory No. 3d-5 and explain fully your factual basis.
3d-7.
Define fully the term " degree of hazard" as used in the context of this contention.
(
3d-8.
Explain fully and separately for each mechanism identified in Interrogatories No. 3d-1, 3d-3, and 3d-5 how and why the degree of hazard increases with the addition of each additional stored spent fuel assembly.
3d-9. Quantify the probability of occurence of each and every mechanism identified in your response to Interrogatories No. 3d-1, 3d-3 and 3d-5 and specify your factual basis.
i 3d-10. Specifically describe 'each worker activity at the pool which will be increased due to the proposed compaction and quantify in man hours ths amount of the increase f'or'each activity identified.
Discuss fully and separately for each worker activity identified in Interrogatory 3d 10 how and wh'y the possibility of an accident caused by each mechanism identified in Interrogatories No. 3d-1, 3d-3 and 3d-5 is increased.
11 -
Contention 3e 3e-1.
Describe fully and separately each and every mechanism by which the pool liner may be damaged when the spent fuel pool is filled l
t to capacity and explain fully the factual basis for each sucti I
mechanism identified.
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3e-2.
Describe fully and separately the nature and extent of liner damage j
you expect from each mechanism identified in Interrogatory No. 3e-1 and specify your factual basis.
3e-3.
For each mechanism identified in your response to Interrogatory No. 3e-1 above, separately indicate whether any spent fuel assemblies would have to be, relocated or removed from the spent
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fuel pool to effectuate repairs.
3e-4.
For each and every mechanism identified in your response to s
Interrogatory No. 3e-3 which would require the relocation or removal of spent fuel from 'the spent fuel pool, specify your factual basis.,
3e-5.
Define " pool liner breach" as used in the context of this contention.
4
3e-6.
Discuss fully the factual basis for your contention that the degree of hazard resulting~ from a pool liner breach increases with each additional stored fuel assembly.
3e-7.
Discuss fully and separately for each worker activity identified in your response, to Interrogatory 3d-10 how and why the possibility of a pool liner breach is increased.
(
3e-8.
Discuss fully the basis for your contention that the increased weight burden to the pool and liner due to additionally stored assemblies increases the possibility of a pool liner breach.
3e-9. Quantify separately the increase in probability of a pool liner breach due to:
a.
increased worker activity, and b.
increased weight burden to the pool and liner and specify your basis.
.i Contention 3f 3f-l Quantify the incremental load to the pool base of the additional spent fuel assemblies proposbd for this modification and necessary 2
racking in lbs/i'n and specify your basis. -
3f-2.
Do you contend that the existing pool base is not adequate to support the incremental load specified in your response to Interrogatory No. 3f-l?
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3f-3.
Explain fully the factual basis for your response to Interrogatory No. 3f-2 if the response to Interrogai:ory No. 3f-2 is other than an unqualified no.
3f-4.
Define the term " seismic event" as used in the context of contention 3f.
3f-5.
Do you contend the spent fuel pool as modified by this proposed amendment will not adequately withstand a seismic event?
i 3f-6.
Explain fully the factual basis for your response to Interrogatory
.No. 3f-5 if your response to Interrogatory No. 3f-5 is other than an unqualified no.
/
Contention 3g i
- [
- 3g-1.
Identify with specificity the " associated material" which you l
refer to in contention 3g.
Contention 3h 3h-1, Identify each and every problem associated with defective or deteriorating neutran absorber plates.which you refer to in contention 3h,
. 3h-2.
Specify the factual basis for each problem identified in your response to Interrogatory 3h-l.
3h-3.
Do you contend that monitoring for a loss of neutron absorber material, bulging and swelling is desirable or necessary at Point Beach?
(
3h-4.
If your response to Interrogatory 3h-3 is other than an unqualified no, suggest any and all monitoring programs you consider reasonable and provide the basis for your suggestions.
Contention 5 5-1.
Define fully the term " actual pool failure" as used in the context
(
of this contention.
5-2.
Define fully the term " threatened pool fqilure" as used in the context of this contention.
5-3.
Define and describe the " procedures, hazards, or logistics of transportation"you refer to in contention 5.
5-4.
Quantify the term "in a short time period" in the context of this con ten tion.
o 5-5.
Describe fully and separately each and every mechanism by which an " actual pool failure" may occur due to the proposed modification and explain fully the factual basis for each such mechanism identi-fled.
5-6.
Describe fully and separately each and every mechanism by which a
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" threatened pool failure" may occur due to the proposed modification and explain fully the factual basis for each such mechanism identi-fied.
5-7.
Spect.fy separately for each mechanism 1dentified in your response to
' Interrogatories No. 5-5 and _5-6 above whether you contend the removal of spent fuel assemblies from the spent fuel pool would be. required and state your factual basis.
Contention 6
.t 6-1.
Define fully the term " activity" in the context of this contention.
6-2.
Do you contend that the proposed modification will result in waterborne radioactive.emissio.ns which will enter the ground water?
6-3.
'If your answer to Interrogatory No. 6-2 is other' than an unqualified no, discuss fully the factual basis for the contention.
6-4.
Specify how ana why increased activity and stress loads due to increased spent fuel storage capacity is related to groundwater movement.
(s 6-5.
Specify the location of all aquifers and wells near the Point Beach facility which you contend should be monitored.
6-6.
Estimate the transit time of any leakage from the spent fuel pool due to the increase in spent fuel storage capacity to each and every aquifer and well identified in your response to Inter-rogatory No. 6-5 and provide the basis for your estimate.
Contention 7
_f 7-1.
Specifically identify all "other low-level radioactive waste" which you contend requires disposal as a result of the proposed
- modification or as a result. of additional. storage of spent fuel at Point Beach.
O
17 _
7-2.
Do you contend that the existing spent fuel storage racks or other low-level waste should be buried or stored at Point Beach rather than shipped offsite?
7-3.
If your response.to Interrogatory No. 7-2 is otner than an unqualified no, explain fully the factual basis for that contention.
Indicate the time period for which the low-level wastes should be stored or buried at Point Beach and specifically identify which wastes you contend should be stored or buried at Point Beach.
I Contention 8 8-1.
Do you contend that the Point Beach fuel assemblies presently stored at NFS cannot be safely stored at Point Beach when the NFS fuel'is returned to Point Beach?
i 8-2.
If your response to Interrogatory No. 8-i is other than an un-qualified no, explain fully the specific factual basis for the
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contention.
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Contention 9 Contention 9 was admitted by the Atomic Safety and Licensing Board based on Intervenor's explication that emergency situations might result from seismic activity, sabotage, or the additional number of workers involved in the fuel storage operation itself. 2/
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9-1.
Explain fully why the more dense storage of spent fuel at Point Beach would require revision and updating of the plant's emergency plans.
9-2.
Identify and describe each and every evacuation or emergency situation which you contend would be created due to more dense and increased storage of spent fuel at Point Beach.
9-3.
Specify your factual basis for each and every evacuation or emergency 4
situation which would be created due to mgre-dense and increased storage of spent fuel at Point Beach.
9-4.
Describe how each and every evacuation or emergency situation identified in your response to Interrogatory No. 9-2 would occur and state your factual ' basis. '
-I See Board Order, dated September 1,1978 at pp. 9-10.
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.t 9-5.
For each and every evacuation or emergency situation identified in your response to Interrogatory No. 9-2, state whether you believe applicant's existing emergency plans are adequate to cope with the consequences.
9-6.
If your response to Interrogatory No. 9-5 is other than an un-(
qualified yes, identify each and every deficiency in the emergency plans and provide your basis.
9-7.
Specify and describe how and in what respects (a) seismic activity may effect the spent fuel pool in its present configuration.
(b) seismic activity may effect the spent fuel pool as modified by the proposed amendment. -
f 9-8.
Quantify the additional number of workers uhich you contend will be ' involved in the Point Beach spent fuel storage operation as a result of the proposed modification and provide the basis for your response.
9-9.
Specify how any increase in the number of workers who would be involved in the Point Beach f' el handling operation as a result u
of the proposed modification is relatedeto.yvacuation or emergency situations.
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i.
9. Contention 11 11-1.
Define the term " effects" as used in the context of Contention 11.
11-2. Quantify the incremental radioactive exposure you contend that Point Beach occupational personnel will receive as a result of
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the proposed modification in man / rem and provide the factual basis for this exposure.
11-3. Quantify the incremental radioactive exposure you contend the general public who live in the vicinity of the facility will
.rece ve as a result of the proposed modification in man / rem and i
provide the factual basis for this exposure.
W Contention 16a 16a-1.
Identify each and every "other component'l in contact with the storage pool borated water not otherwise specifically identified in Contention 16(a) for which you alle'ge the corrosive effects must be evaluated.
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16a-2. State specifically for spent fuel, spent fuel cladding, support -
i-frames, storage racks, neutron absorber plates ~and each and a
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every component identified'in your respons' to Int.rrogatory e
No. 16a-1:
(a) the types and amounts of corrosion formation'due to e
contact with borated water expected with the present SFP configuration, I
(b) the types and amounts of corrosion formation due to
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contact with borated water expected if the SFP is
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modified as proposed, sandbdentify any document, study or analysis which estimates these types and levels.
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Do you contend that problems with spent fuel storage rack swelling similar to those experienced at the Connecticut Yankee facility could occur at Point Beach as a result of the proposed modification?
If your response-to Interrogatory No.16a-3 is other thar. an un-qualified no, explain fully your factual pasis for the contention.
ContIntion 16b
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State separately' for accelgrated corrosion, microstructural e
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r.g ch'inges, alterations in mechanical properties, stress corrosion,
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4 cracking, intergranular corrosion, and hydrogen absorption and precipitation by zirconium alloys:
(a) each and every SFP component in the present SFP configuration you expect to be affected by that particular type of corrosion or process and how 1
safety.would be affected, (b) the amount of corro'sion fonnation for each component identified in your response to (a) above (with the present SFP configuration) due to that particular
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type of corrosion or process, (c) each and every SFP component in the proposed modi-fication (including existing components and proposed additions, if appropriate) you expect to be affected by that particular type of corrosion 6r process and how
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l safety would be affected, (d) the amount of corrosion fornation for each component identified in (c) above due to sthat particular type of corrosion or process in the proposed modification, ald identify any document, study or analysis which estimates these levels.
Contention 16c 16c-1. Specifically identify each and every pipe _ referred to in Contention 16(c).
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16c-2. State specifically for the pool liner, storage racks, storage rack bases and each pipe identified in your response to Interrogatory No.16c-1:
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(a) the level of electrolytic corrosion expected with the present SFP configuration, (b) the level of electrolytic corrosion expected if the I
SFP is modified as proposed, and identify any document, study or analysis which estimates these levels.
Contention 16d 16d-1. Specify and describe each and every monitoring method to identify defective fuel elements referred to in Contention 16d.which you
(
contend should be. addressed and identify any document, study or analysis which discusses or describes each monitoring method
- speci fi ed.
16d-2. For each and every monitoring method identified in your response to Interrogatory 16d-1, stato the results and significance of the results you expect from the monitoring and specify the factual basis for your response.
_]
16d-3. Specify the factual basis for your assertion in uontention 16d that applicant should consider the desirability of monitoring each individual spent fuel assembly.
16d-4. Specify the factual basis for your assertion that leakage and disintegration of spent fuel and its cladding is possible over
(
the period of licensed plant operation.
(Contentions 16a-16i have been limited to the period of licensed plant operation by Board order dated September 1,1978 at p.12).
Contention 16e 16e-l. State specifically the factual basis for your assertion in Contention 16e that spent fuel will be stored in the SFP for 1
(
longer periods of time as a result of the proposed SFP modi-fication.
3 16e-2.
Specify each and every method of encapsulation which should be discussed.
If you contend that encapsulation of defective spent fuel would be desirable at Point' Beach, specify why and under what circum-stances encapsulation would be appropriate and state your basis.
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I Contention 16f 16f-1. St' ate specifically for spent fuel and spent fuel cladding the i
anticipated thickness of crud layers--
(a) expected for the present SFp configuration, (b) expected if the SFp is modified as proposed,
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and identify any document, study or analysis which estimates this thickness.
16f-2. State specifically whether you believe crud will influence the corrosion of spent fuel and spent fuel cladding.
If the response to Interrogatory No.16f-2 is other than an un-qualified no, explain fully why and under what circumstances
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crud will influence.the corrosion of spent fuel and its cladding
-as ja result of the proposed modification and state your basis.
.t Contention 16g i
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169-1. Specify and explain fully each and every " uncertainty" pertaining to borated water stress on spent fuel pool materials you refer to in Contention 16g and provide your factual ' basis.
9
169-2.
Identify each spent fuel pool material subject to borated water stress you refer to in Contention 169 169-3. Specify and explain fully each and every " uncertainty" pertaining to the corrosive resistance of zircaloy you refer to in Contention 16g and provide your factual basis.
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169-4. Specify all "other conditions prevalent with wet storage of more densely packed spent fuel at Point Beach" you refer to in Contention 16g.
16g-5. For each "other condition" identified in your response to Interrogatory No.169-4, specify and explain fully each and every uncertainty associated with the condition and provide your factual basis.
16g-6. Specify separately each and every alternative to on-site under-
.f water storage of spent fuel at point Beach you refer to in Contention 16g.
169-7. For each alternative identified in your response to Interrogatory No.169-6, state whether you contend it is preferable to the spent fuel pool expansion proposed by the Ap'plicant and provide the factual basis for your position on each alternative.
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Contention 16h s
16h-l. Sp.ecifically identify and describe separately for each activity listed below each and every problem in handling spent fuel re-sulting from:
(a) transfer of spent fuel from one pool to another during reracking,
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(b) repositioning of spent fuel in the expanded storage pool upon removal of additional spent fuel from the Corte (c) encapsulation of defective spent fuel elements, (d) placement of spent fuel in or removal'from shipping
- casks, that you refer to in Contention 16h and provide the factual basis for each problem so identified.
(
16h '
- ecify the factual basis for your assertion that the spent fuel i
und spent fuel cladding will lose integr ty due to more dense and
'ncreased spent fuel storage at Point Beach.
16h..
. ecify the "other components" of and in the spent fuel pool which would lose integrity due to more dense and increased spent fuel c+orage.and provide the factual basis for the loss of integrity
. each component identified.
I
16h-4.1Specify how the placement of spent fuel in or its removal from shipping casks is affected by the proposed modification and pro-vide the factual basis for your response.
16h-5. Specify how handl'ing associated with the encapsulation of defective spent fuel elements is affected by the proposed modification and provide the factual basis for your response.
16h-6. Explain what you mean by " repositioning of spent fuel in the ex-panded storage pool upon removal of additional spent fuel from the Core."
If you contend that the proposed modification will result in the removal of additional spent fuel from the core, quantify the I
number of additional assemblies and provide-the basis for your response.
.f Contention 16i 161-1. Specify the existing chemical composition of the Point Beach SFp water and provide the basis for your response.
. 161-2. Specify the existing chemical composition of the' Nuclear Fuel Services SFP water and provide the basis for your response.
161-3.
Do you expect the chemical composition of the. Point Beach SFP water-to change as a result of the proposed modification?
If your response to Interrogatory No.161-3 is other than an unqualified no, specify each and every change in composition you expect and provide your basis.
Indicate the change in concentration of each chemical component or measure which will change and its resultant concentration in mg/l or other appropriate units.
I 161-5. Specify each and every chemical difference between the Point Beach and NFS spent fuel pool water which you believe will produce corrosion effects at the Point Beach SFP resulting from the return of the NFS fuel to Point Beach. Provide the basis for your response.
3 Respectfully submitted, 0N/LU YJ.
PHJ Bruce A. Berson.
Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of September,1978 -
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Y ATTACHMENT A September 29, 1978 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 80!dD In the Matter of
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Docket Nos.
WISCONSIN ELECTRIC POWER COMPANY Amendment to License Nos. DPR-24 (PointBeachNuclearPlant, and DPR-27 (Increase Spent Fuel Units 1 and 2)
StorageCapacity)
ADMITTED CONTENTIONS
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l.
Intervenor contends that incremental airborne radioactive emissions as a result of the proposed spent fuel pool expansion, must be analyzed for their significance.
If found significant, the adequacy of Applicant's airborne monitoring program must,be considered, and the monitoring results should be published in the lo' cal newspaper.
2.
The Applicant fails to address the combined or accumulated effect of radioactive emissions generated from increased spent fual storage at the
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Kewaunee Nuclear Plant and the Point Beach Nuclear Plant.
3.
5plicant's discussion and analysis of the possibility or consequences of-the following situations is inadequate:
a.
The spent fuel pool's water ' temperature maximums in the event that both cores must of off-loaded within a short period into the pool whose temperature has already been increased by a. greater number of stored 1
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s rods, and whose coolant circulation-flow has been reduced by the in-creased numbers of fuel assemblies and storage racks.
b.
The. spent fuel pools have only one entrance and one discharge coolant water pipe. Applicant fails to discuss the results of a blockage or either of these which might occur due to increased worker activity necessitated by compaction, No analysis has been made of the loss of both storage pool coolant c.
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pumps under normal or emergency core unload situations. Applicant does not discuss emissions possibilities in the event the fuel pool should boil due to the increased heat load caused by compaction.
d.
The Applicant has not.made any analysis of the thermal effects on the stored fuel of the loss of volume of coolant water in the spent fuel
' pool, or of the loss of volume or flow of service water through the heat exchanger, or the loss of the service water pumps. The degree of hazard
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.c# any of these accidents increases with the. addition of each additionally stored assembly and the possibility of such an accident increases with the increased worker activity at the pool.
In the event of damages to the pool liner while the spent fuel e.
pool is filled to capacity', the Applicant failed to discuss where the fuel assemblies would be kept during repairs and how the repairs would be made.
The degree of hazard resulting from a pool liner breach increases _ with
3-each additionally stored fuel assembly, and the possibility of such a breach is increased by increased worker activity at the pool and the in-l creased weight burden to the pool and liner of the additionally stored assemblies.
f.
Applicant fails to discuss the effects of the increase of weight to me pool base of 1502 fu'el assemblies and necessary racking, nor do they discuss the additional risk this increased burden may impart during
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a seismic event.
g.
Applicant should state the methods for safely removing and shipping i
off-site the present fuel storage racks and associated materials.
h.
Applicant fails to dis 6uss problems associated with defective or i
deteriorating neutron absorber plates and how the specimens will be monitored for a loss of neutron absorber material, bulging and swelling.
5 5.
Applicant does not discuss procedures, hazards, or logistics of trans-portation during the forced removal of the increased number of fuel assemblies in a short time period due to an actual or threatened pool failure.
i 6.
Applicant should study ground water movement around the plant. These aquifiers shou,ld be regularly monitored to assure that no leakage has occurred from the spent fuel storage pool due to increased activity and stress loads.
,. 7.
In the application and amendment thereto, Applicant did not quantify the increases of filters, cartridges, resins and other lcw-level radio-active wastes that would have to be disposed of due to the proposed compaction and additional storage of spent nuclear fuel at Point Beach.
Applicant should indicate where these increased quantities of low-level radioactive solid wastes wjll be placed. Applicant should also discuss the p)ssibility of land burial or storage of these increased quantities of low-level wastes, particularly the existing racks, at Point Beach.
8.
Applicant's request'for compaction is based partially on anticipated return of spent fuel assemblies presently stored at NFS in West Valley, New York. Applicant gives no ass.urance that these fuel assemblies are intact and safe for storage.' Applicant did not state in the original license
. application, nor in the amendment thereto, but did state in " Additional Information Spent Fuel Storage Expansion," submitted to Harold P. Denton of the NRC and dated July 19, 1978, that this fuel must be removed from
-West Valley by 1980.
t 9.
Applicant has not presented a revised and updated version of its medical and health car ~ plan for those injured in evacuation or emergency e
situations due to more dense and increased storage of spent fuel to assure the public safety.
(Contention admitted based on Intervenor's explication that' emergency situations might result from seismic activity, sabotage, or the additional number of workers involved in the fuel storage operation itself.1 /)
_j/ See Board Order, dated September 1,1978 at pp. 9,10.
11.
The Applicant's Environmental Report fails to quantify the effects of radioactive emissions from the co'mpaction and inc'reased storage of spent-5 fuel on the health of:
a.
the occupational personnel of the facility;
- b..thergencral public who live in the vicinity of the facility. No consideration has been made.of the changing population levels which will occur chring the life of the facility.
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- 16. Applicant has not discussed the long-term integrity of the various components of and in the spent fuel storage pool in light of the proposed i
compaction and increased amount of spent fuel at Point Beach. The health,-
i safety, environmental and economic impact of the loss of integrity of these 7
components due to more dense'and increased storage of spent fuel for the-i r
. period of licensing must be evaluated.
a.
Applicant should evaluate the corrosive affects of borated water
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.on spent fuel and its cladding, support frames, storage racks, fuel basin liner, neutron absorber plates and any other components in contact with the storage pool borated water. According to A. B. Johnson in Behavior of Spent Nuclear Fuel in Water Pool Storage, Battelle North West Laboratories -
2266, September 1977.at page 36:
...(P)ool and fuel bundle materials j
have appeared to function-satisfactorily in' boric acid fuel pool chemistry, but very few detailed analyses of the materials are available." These i
analyses are necessary to process the application to amend Point Beach's' operating license to compact spent fuel and to store an unprecedented number i:
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t of spent fuel assemblies as proposed by Applicant. These analyses are L
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also important because problems of spent fuel storage racks swelling i
associated with borated water have been experienced at the Connecticut l
L Yankee facility, and, consequently, the possibility of this situa' tion
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being duplicated at Point Beach must be examined and studies documented.
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b.
Applicant should examine the effects of accelerated corrosion,
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i microstructural changes, alterations in mechanical properties, stress corrosion,-
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cracking, intergranular corrosion, and hydrogen abt.orption and precipitation 4
by the zirconium alloys due to the proposed compaction and long-term storage l
of spent fuel at Point Beach. The Nuclear Regulatory Commission Draft
- Generic Environmental Impact Statement on Handling and Storage of Spent i
Light Water Power Reactor Fuel, NUREG-0404, Volume 2, March 1978, at page f
f i
H-23 states that these corrosion effects in underwater spnt fuel storage i
' requires examination.
i c.
Applicant must analyze the long-term electolytic corrosion effects 1
i of using dissimilar alloys for the pools liners, pipes, storage racks, and t
l-storage rack' bases.
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- d. -Because of the possibility of leakage and disintegration of; spent i;
fuel and fi:s cladding over the long'-term, Applicant must discuss the i
, desirability of and methods for sensitive monitoring.to identify defective' fuel elements.
In Behavior of Spent Nuclear Fuel in Water pool Storage ij at page 76, there is definite need for selected, focused, exploratory-i i
surveillance at present to confirm wet storage as an acceptable option for F
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1 storing spent fuel and to define the condition of pool-stored spent fuel when renoved to any alternative storage or to a reprocessing plant.
Applicant must also analyze the desirability of monitoring each individual spent fuel assembly.
e.
Applicant should discuss the desirability of and various methods and effectiveness of encapsQlating defective spent fuel elements upon dis-L covering leakage or disintegration due tb loss of cladding integrity. This I
discussion is essential when considering longer-term storage and increased density of spent fuel at Point Beach than had originally been anticipated in tre original license.
f.
Applicant should delin,eate anticipated thickness of crud layers and crud tendency to influence corrosion of spent fuel and its cladding due
. to increased and more dense spent fuel storage as proposed for Point Beach.
A. B.
Johnson, in Behavior of Spent Nuclear Fuel in Water Pool Storage at
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p, age 65, indicates that study of existing crud analyses and selected other analyses "...may determine whether the corrosion environments in crud layers are as inert as they currently are regarded to be."
g.
Because of the uncertainties pertaining to borated water stress on mateials in spent fuel pools, corrosive resistance of zircaloy, and other conditions prevalent with wet storage of more densely pa d ed spent fuel at Point Beach, applicant should discuss and evaluate the health, safety, environmental and economic impact of alternatives to on-site underwater storage of spent fuel at Point Beach, including dry storage in
sealed storage casks, air-cooled vaults, and near surface heat sinks --
both on-site and off-site. According to Alternatives for Managing Wastes from Reactors and Post-Fission Operations in the LWR Cycle, ERDA.76-43 May 1976, at pages 17.17-17.44, the advantages of these dry and/or surface storage methods of spent fuel storage is that containment and cooling can be provided with passive, low maintenance systems, h.
Applicant should analyze problems in handling spent fuel (e.g.,
including but not limited to transfer from one pool to another during re-racking, repositioning of spent fuel in the expanded storage pool upon s_
removal of additional spent fuel from the core, encapsulation of defective spent fuel elements, placement in, or removal from shipping casks, etc,)
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resulting from loss of integri y of spent fuel and its cladding as well as
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, other components of and in the spent fuel storage pool due to more dense and increased storage of spent fuel as proposed by Applicant.
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- i. Applicant has indicated that Point Beach spent fuel now stored at tbclear Fuel Services in West Valley, New York, may be returned to its place of creation. Applicant must evaluate the corrosion effects on the. Point Beach spent fuel now stored at West Valley and the existing and anticipated spent fuel to be more densely _ stored at Point Beach due to chemical differences in the Nuclear Fuel Services and Point Beach spent fuel storage pools.
(Contention 16(1) is limited to corrosion effects at the Point Beach spent fuel pool resulting from the return of the NFS fuel
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due to chemical differences in the NFS and Point Beach storage pool.
August.17,1978 Special Prenearing Conference, Tr. 251, 252 (6193,_ 6194).)
j Contentions'16(a)-(i) are limited to the period of licensed plant operation.
Board Order, supra at p.12.
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,y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket Nos. 50-266 1
50-301 WISCONSIN ELECTRIC POWER COMPANY Amendment to License Nos.
DPR-24 and DPR-27 (Point Beach Nuclear Plant,
)
(Increase Spent Fuel Units 1 and 2)
)
Storage Capacity)
CERTIFICATE OF SERVICE
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I hereby certify that copies of "NRC STAFF FIRST SET OF INTERROGATORIES T0, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, INTERVENOR LAKESHORE CITIZENS FOR SAFE ENERGY" and " ATTACHMENT A - ADMITTED CONTENTIONS" in the above-captioned proceeding, have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 29th day of September,1978:
' Marshall E. Miller, Esq., Ch' airman
- Mary Lou Jacobi f
Atomic Safety and Licensing Board Vice Chairperson U.S. Nuclear Regulatory Commission Lakeshore Citizens for Washington, D.C.
20555 Safe Energy 923 N. 5th Street Or..Emmeth A. Luebke*
Manitowoc, Wisconsin 54220 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Atomic Safety and Licensing
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Washington, D.C.
20555 Board Panel
- U.S. Nuclear Regulatory Commission Dr. Paul W. Purdom Washington, D.C.
20555 245 Gulph Hills Road Radnor, Pennsylvania 19087 Atomic Safety and Licensing Appeal Board
- Patrick W. Walsh, Esq.
U.S. Nuclear Regulatory Commission Assistant Attorney General-Washington, D.C.
20555 The State of Wisconsin Department of Justice Docketing and Service Section*
114 East, State Capitol Office of the Secretary
' Madison, Wisconsin 53702 U.S. Nuclear Regulatory Comnission Washington, D.C.
20555
- George F. Trowbridge, Esq.
- Bruce W. Churchill, Esq.
Shaw, Pittman, Potts &
Trowbridge ni n
1800 M Street, N.W.
Or W S bb. U<%4@e/
Washing ton, D.C.
20036 Bruce A. Berson Counsel for NRC Staff
.