ML20027A352

Lakeshore Citizens for Safe Energy Responses to the NRC Staff'S First Set of Interrogs. Urges Evaluation of Airborne Emissions Which Add to Existing Background Radiat. Cert of Svc Encl

ML20027A352
Person / Time
Site:	Point Beach
Issue date:	10/25/1978
From:	Schaefer W LAKESHORE CITIZENS FOR SAFE ENERGY
To:
References
NUDOCS 7811200275
Download: ML20027A352 (22)

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.'f, A V A UNITEL STATES OF AMERICA NUCLSAR REGULAT0hY COMMISSION C'- r-etu.? ' .

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~TE~the Matter of Wisconsin Electric Power Company amendment to License Hon'. DPR-24 & Docket Hos. 50-266

27. 50-301 LAK3 SHORE CITIZENS FOR SAFE El:3RGY RESP 0HSES TO TH3 NRC STAFF'S FIRdT SET OF INTERROGnTORIES GENERAL INTERROGATORIES (G-1 through G-5 and all their s'ubparts).

We are unable to give you specifics as this time (also see page 16 ). We will inform you as soon as our case.

is clarified. Ve are anxiously awaiting your technical and safety evaluation as well as the final GEIS report.

CCMTENTIOUS:

1-1 An incremental increase in emissions is significant if it adds anything to the area which did not previously exist or adds to already existing radiation regardless of how minimal.

Significance--meaning, Significant--having meaning, existenc'e.

In otherwords, Intervenor contends that incremental airborne radio etive emissions (those emis:lons which add anythins to the area which did not previously exist or those emissions which add to already existing background radiation), must be analyred for their meaning (no matter how obscurg). If these emissions are found to hnve meaning (exist), Applicant's ,

airborne monitoring program must be considered (evaluated),

and the monitoring results should be published in the local pap'er.

1-2 Incremental airborne radiotetive emissions as re" erred to in the applicant's License amendment DPR 24 & 27. At this time, I cannot' state how or what type of analysis should be performed other than the monitoring of radioactive emissions and tioir effects on human beings (see transcript for specifics).

7 8113 0 0 J75i Analysis is necessary because radiation is dangerous.to one's health.

(a) .

1-3 .Yes, according to my definition.

1-4 See answer 1-1, 1-5 considered--must be able to measure any and all radioactive of emissions regardless4how small.

1-6 For public information. I understand that this is not a problem if someone is willing to gather the'information and give it to the media. This is not really an issue but more a convenience as the documents ums (radiation reports) are kelt in Steven Points.

l ( 2-1 The word "effect" deals with the emission's contact with the environment and health of humans in and around the plant

site. ,

2-2 See emissions as reported in the Applicent's original application. I'm unable to give further information at this time.

2-3 Because of the inconclusive inRuomation available to us at i

this time, we cannot address this question.

l 3a-1 The phrase "uithin a short period" is intended to mean i

within a period of ten days or less.

3a-2 Any event capable of causing the emergency core offload of ONE reactor may be duplicated to cause the emergency off-load of the second core. Since the NRC has deemed the emergency core-offload capability as " desirable" (but not f manditory)~for plant safety,Lthe NRC staff might best determine.

which - if any - occurance could require.the emergency off-loading of one, or both', cores.

Among uhe events which we envision'as possible are:

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the-breakdown of fuel an: emblies within the core;1the breakdown or threatened bronhdown of the core' containment walls; damage-

'to or mal-function of the ' emergency core cooling _ system;

'. I (3) damagep to or malfunction of the reactor core-coolant pumps and or piping; damage to or malfunction of the control rods and their activators; and the damage or threat of damage to the facility by " terrorist groups."

i 3a-3 As coolant water moves from point a to point b in the cooling pool, any blockage will impede its free flow. While it is true that the coolant water enters the SFP above the stored assemblies,,and is drawn-off from above the assemblies, and the direct flow from entrance to exit may not be hindered by the increased assemblies, some of the entering coolant water must be drawn by convection to the pool bottom, beneath, and between the stored assemblies. It is these convection currents which may be impeded by the increased numbers of stored older and cooler fuel assemblies.

, The added residual heat of these additionally stored assemblies will either increase the SFP's coolant water temperature, ,

or the coolant water flow rate will have to increase to dissipate it.

3a-4 Intervenor has no calculations to suppo'rt this contention.

On the contrary, if common sense leads the NRC to agree that the increased racks and assemblies will reduce the free flow of water then it behooves the NRC staff to engage ,

engineers to quantify the flow restrictfons in the public

-interest.

3a-5 Spent fuel assemblies are kept submerged Jn the SFP for two reasons: they are ra'dioactively " hot" and they are thermally " hot". Intervenors understand that a great deal of the thermal energy is loct during the' months following removal from the core.

l (4)

Most 5f the heat is lost quickly; most;but not all.

We have three possible consequences of adding more assemblies to the SFP. First, that the temperatue of the SFP will go down; Second, that its temperature will stay the same; and

. third, that its temperature will rise. We believe it may rise.

3a-6 Intervenors have no estimate of the increase in SFP coolant water temn and have no calculntions or analysis,to support our contention.. On the Contrary, we feel it the duty of the NRC's technical staff to compute this increase and and compare findings with the Applicant.

3b-1 Intervenors have precented interrogatories to the Applictnt-regarding this, and, as yet have received no reply. Ve believe worker activity will increase in these ways: removal of the old racks and the re-fitting of new racks will re-quire increased "over the pool" and "in the pool" activity; we understand that some of the spent fuel assemblies may be moved about in the pool foam one storage location to another af ter recoil from the core to assure that the outer-most stcrage positions (those nearest the walls) will be the coolcat; we believe the increased number of stored assemblies will require more monitoring &ctivity by the worker. .

3b-2 Intervenors have submitted interrogatories to Applicant which may,when answered,rolieve our concerna. Our present position is this:

We believe the 5FP coolant water suction ppe has no pro-

'tective ccreening.

Any of the three activitics mentioned in 3b-1 requires _in- )

1 creased worker activity over the pool.

i (5)

Any item used by the worker which could drop into the

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-pool might be drawn into the suction pipe and cause.a .

4 blockage. 7 i We concede. that. worker activity probably would not endainger the "f1Iing pipe."

3b-3' Blockage--any restriction in the' flow of SFP coolant water.

3b-4 The results of a blockage of the suction pipe would be a i

t reduced flow (in CP/mine) of coolant water. 1 l ,

The effect of a reduced flow might be an increase in the ,

1 4 temperatus of the SFP coolant water.

J See answer 3b-2.

" Emergency Core Unload Situations" are defined as those in-3c-1 stances which may necessitate the offloading of a complete .

reactor core ( or both reactor cores) in the shortest

'feasable time period. These instances were listed in our i answer 3a-2.

3c-2 " normal core' unload situation" is-defined in-this contention .

as the offloading of approximately 1/3 of a reactor core's-fuel asscmblics as would be-done in a " normal" refueling

-operation.

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3c-3 Intervonors are concerned with two possible causes of .,

damage to the coolant water pumps:

l -1. The-pumps may be damaged or even made inoperable by individuals attcapting to damage the. plant and machinery. I

! This may include. workers dropping loads onto the pumps, fanatical-groups __using explosives, or-possibly even small' arms fire from uct. pons discharged near the pumps.

.2. The pumps may be damaged.by objects drawn.into the asum e

(6) suction pipe in the SFF. This may include items accidentally dropped into the pool or it may include items intentionally fed into the suction pipe to cause a breakdown.

These concerns.would apply to the SFP coolant pumps in both normal operations and in an emergency core unload situation but would be magnified under the increased heat load accompany-ing an emergency core offload.

3c-4 Intervenors do not understand uhat the NRC staff desires in its request for a " factual basis" for our response to interrogatory 3c-37Perhaps we have satified your question in our response to 3c- 3.

3c-5 Intervenors believe that the SFP might reach boiling in the following areas:

1. Simultaneous failure of both coolant pumps within a one week period following a normal 1/3 core' offload refuel-ing operation; -

2. Failure of one or both pumps within a one week period follwing an emergency offload of one entire core;

3. Failure of one or both pumps within a one week period following an emergency offload of both entire cores. .

In any of these cases, the time required to reach boiling in the SFP would be hastened by the additionally stored

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spent fuel assemblies.

3c-6 Any of the mechanisms mentioned in Intervenor's answer to question 3c-3 could cause pump failure. In the event of complete pump failure, the SFP would reach boilinc sooner as a result of the additionally stored spent fuel assemblies.

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(:7) 3c-7 Intervenors do not know what will be emitted as a result of the SFP's water boiling. The Applicant and NRC staff should be aware of the emissions possibilities.

3c-8 Any radioactive materials dissolved or suspended in the SFP coolant water may be carried away with the boiling water.

3d-l Intervenors believe that coolant water volume may be lost through any of the following cases:

1. Icaks in the pumps or piping in the SFP's coolant loop.

2. Leaks in the pool liner and pool walls of the SFP.

These cases could be caused by worker sabotage, worker accident, or a terrorist attack.

3d-2 A leak in the pumps or piping could cause a loss of coolant of the top 10 feet of water in the SFP. A leak in the liner and pool wall could result in a complete drain of the SFP.

3d-3 The flow of service water through the heat exchanger maybe reduced by; a breakdown of the service water pumps; or

. a break in the piping and/or heat exchanger in the service water coolant loop.

These cases could be caused by: worker aabotage or accident; terrorist attacks.

3d-4 Either of the events centioned in 3d-3 could cause a com-plete loss of service water.

3d-5 The service water pumps maybe damaged or destroyed by: materials drawn into the pump and jamming it from within; explosives or any other concussion capable of cracking the pumps 3d-6 Either of the instances mentioned in 3d-5 could cause complete loss of volume in the service water loop.

(8) 3d-7 In this contention, the " degree of hazard" refers to the

." seriousness of the consequences" of damage to the spent fuel assemblies. Since there will be more assemblies stored in the SFP, the seriousness of a loss of coo..ing capacity increases.

3d-8 Any loss of cooling capacity which might be caused by the cases mentioned in answers to interrogatories 3d-1, 3, & 5, becomes more " hazardous" with each additionally.st6ead heat-generating spent-fuel assembly.

3d-9 Intervenors cannot " quantify the probability of occurance" of any accident or sabbotage.

3d-10 Intervenors propose that compaction will necessitate more ~

worker activity in and above the pool to: remove the present racking, install the new racking, re-position the stored spent fuel assemblies, and monitor the stored assemblies for deterioration or leakage. We cannot estimate the man-hours involved.

3d-11 Intervenors concede that w'rker o activity necessitated by compaction will have little or no effect on the accident or sabotage possibilities to the service water pumps, piping and heat exchanger (on the service water loop). This concession ,

does not negate the seriousness of the consequences of a failure in this loop. Service water loop failures could cause an increase in the SFP's water temperature, which would be hastened by the additionally stored assemblies.

Intervenors do contend that any worker activity mentioned in answer to interrogatory 3d-10 leads to a greater risk of the occurances ment,ioned in answer to 3d-1.

l (9)  !

i 3e-1 Intervenors contend the pools liner and/cr base and walls

.nlaybe damaged by: worker sabbotage or accident (dropping materials into the pool or onto the walls; terrorist .

activity (use of explosives.)

P 3e-2 Intervenor cannot estimate the " extent of damage" of dropping fuel assemblies, or shipping casks, or any other heavy object into the pool or onto the wall. Explosives could p2ncture the SFP wall.

s 3E-3 If the pool liner were damaged by any event mentioned in answer 3e-1, intervenors believe that stored spent fuel assemblies may have to be moved to another under- '

water storage site, or removed from the pool entirely.

3e-4 Any event which would necessitate the repair of the pool's liner, base, or walls, would necessitate the moyihg of the stored assemblies nearby to allow the repairs.

3e-5 Pool liner" breach" in this contention means any crack, t

tear, split, puncture, dent which msy leak or threaten to leak.

3e-6 The stored fuel assemblies are not harmless, They are stored beneath borated' water because they, pose a hazard .

to workers and the environment. If one assembly hs hazardous, then 1502 assemblies are more hazardous, 3e-7 Men make mistakes; men can cause accidents. Men can intentionally cause damage. The more man hours spent  ;

in, aroand and above the pool, the greater the risk of accident or sabbot ige.

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(10) 3e-8 The SFP was designed to hold, at most, several hundred spent f,uel assemblies. Now, we ask, how can the load

. be increased to 1502 assemblies and racking with no structural changes? The chance of a crack in the base increases as its weight burden increases.

3e-9 Intervenors cannot quantify such a probability; the NRO staff engineers may be nore qualified to do this.

3f-3 We rely on tha NRO staff to provide the stress ' calculations; we do contend that the pool was designed and built for a much lighter burden than this compac tion will produce.

3f-2 We specified no load in answer 3f-1, but we do contend -

until assured by the NRC technical staff to the contary -

that the pool base may not stand the increased burden.

3f-4 " Seismic Event" refers to ground vibration or shifting.-

3f-5 We contend that the' modified SFP "may" not be adequate <

to withstand a seimic event. We ask the NRO technical staff to analysis the structure with this in mind.

3r-6 If the pool's walls and base were designed for fewer assemblies," then we question their adaquacy while bearing ,

1arger stresses during a seismic event.

3g-1 " Associated materials" includes the rack bases and accompanying fasteners, and any materials contaminated by the removal exposure..

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, (11) 3h-1 Problems--off gasing and gamma radiation damage. Your Technical and safety evaluation should address this area '

and perhaps clear up any concern.,

3h-2 Documentation will be provided. (States problems that exist) 3h-3 Yes.

3h-4 Visual monitoring, monitoring of water, hand check (inspection).

5-1 A situation in which the pool no longer serves the purpose for ,

what it was constructed for. The pool can no longer serve _as a safe storage facility for spent fuel.

5-2 A situation that warrants the possible escape of dangerous i

elements as a result of an accident or sabotage.

5-3 Applicant needs to define and describe the " procedure, hazards or ;

logistics of transportation." Our contention is not that the Applicant has completed an inadequate job of describing the procedures, etc., but that the Applicant has failed to address the topic. This interrogatory should be directed to the Applicant.

5-4 When the pool experiences a failure, the pool must be relieved of its spent fuel rods in order to make the pool safe or to t implement repairs as soon as possible.

5-5 Refer to . transcripts from pre-hearing of August 17th, 1978.

5-6 Refer above.

5-7 Refer above

(12)

, 6-1 "Ac tivity' refers to '" worker ac tivity" at and around the SFP.

6-2 Intervenors contend that leakage from the pool may result from increased stress loads and/or worker activity at the pool site.

6-3 As mentioned earlier, worker activity and stre's s loads could cause a leakage of the pool.

6-4 Increased worker activity and stress loads will not likely modify the ground water movement. We contend the ground water should be monitored to detect possible leakage..

6-5 The Point Beach Facility should drill wells to the water table in order to monitor possible leakage. ^

The NRC staff may have recommendations as to how many wells should be monitored and their positioning.

6-6 Intervenor connot estimate the trasit time for leaked radioactive water to reach the water table; the applicant t and the NRO technical staff should be aware of this transit time s Responses to Interrogatories 3a - 1,2,3,4,5,&6 3b - 1,2,3,4 3c - 1,2,3,4,5,6,7,8 3d - 1,2,3,4,5,6,7,8,9,10, And 11 3e - 1,2,3,4,5,6,7,8,9 -

3f - 1,2,3,4,5,6 3g - 1 6 - 1,2,3,4,5,6, Were all prepared by David Estes,. Esq.

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! (13)

Specific Interrogatories:

7-1 -- Existing racks that would have to be removed, cladding, and particulates of and in the sper.t fuel storage pool which would be filtered and have to be disposed of as a result of additional storage of spent fuel at Point Beach are the "other low-level radioactive waste" referred to in this contention. There may be other low-level radioactive wastes of which we are unaware and which the Staff should ask to be enumerated by the Applicant.

I 7-2 and 7-3 -- We do not cont'end that the existing spent fuel storage racks or J 1

other low- level radioactive waste should be buried or stored at Point Beach, but circumstances at formerly and previously licensed low-level radioactive waste burial sites may force the utilities operating Point Beach to store low-level radioactive waste at the plant. We have asked the Applicant to assess availa-bility of storage of these waste off-site as well as on-site.

8-1 and 8-2 -- No, we do not contend that the Point Beach fuel assemblies presently stored at NFS cannot be safely stored at Point Beach when the spent fuel is returned to Point Beach. However, Applicant has given no indication that the Point Beach assemblies presently stored at NFS are in tact and capable of shipment to Point Beach.

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(14 J' 9-1 Because the Nuclear Regulatory Commission is revising thestatusofspentfueJkI'lassifyingitashavingagreater potential risk which will necessitate greater protection.

Since it holds greater p6tential as a hazard,other methods

, used to protect or aid the public in emergency situations created by this hazard must be re-evaluated 9-2 This was answered at the August 17, 1978 hearing. Please refer to transcript for scenarios.

9-3 This question is redundant. It has been answered on multiple occasions. (Example, sabotage, seismic eveht).

9-4 See 9-3.

9-5 Plans are outdated as they contain resources such as ,

physicians who are no longer present in the community. In a disaster situation, (see 9-3), Two River's Community Hosp.

would not be abic to handle mass emergencies in their one isolated room. Further, local law enforcement ' agencies '

and civil defense personal are unaware of the assistance that they will be require to give during such an occurence whether it be medical or an evacuation procedure.

9-6 See 9-5. Further the emergency plan has never been tested.

9-7 Waiting for this information from you. Should be contained in your safety analysis -

9-8 Ask the Applicant. I think you can safely assume that at least one worker will be required to implement increased storage of spent fuel. Applicant should have these statistics.

9-9 (additional worker activity refers to the construction and re-racking of the spent fuel.)

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J 11-1 The term " effects" as used in the context of contention 11 signifies negative'impa.ct or influence.

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11-2 & 3 vie are unable to answer these because of insufficient information available from the utilities.

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(16 .

, l Iritervenors Response to NRC Staff First Set of Interrogatories to and Reugest for j the Production of Documents from Intervenor Lakeshore Citizens for Safe Energy <

regarding Contentions 7, 8, and 16:

General Interrogatories:

G-1. (r) through (z), Contentions 16.a. through 16.i. -- We are investigating the i availability and cost of witnesses. We are also approaching the State of Wisconsin to sponsor witnesses on these contentions. ,

G-3. (r), Contention 16.a. -- A. B. Johnson,' Behavior of Spent Nuclear Fuel _ in Water i Pool Storage, Battelle Northwest Laboratory 2256, September 1977. We have requested true copies of this document through our U.S. Senator Gaylord Nelson's office and i

will forward same when received.

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G-3. (s), Contention 16.b. -- NRC Draft Generic Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel, NUREG-0404, Volume 2, March 1978, readily available to NRC Staff at the NRC. L G-3. (u), Contention 16.d. -- Same as (r), Contention 16.a.

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G-3. (w), Contention 16.f. -- Same as (r), Contention 16.a.

G-3, (x), Contention 16.g. -- Alternatives for Managing Wastes from Reactors and Post-Fission Operations in the Light Water Reactor Cycle, ERDA 76-43, May 1976, available from the Department of Energy.

G-4, (m), Contention.7, (n), Contention 8. (r) Contention 16.a. through (z) Contention <

16.i. -- Please refer to texts of these contentions as writ' ten in Admitted Contentions t

September 29, 1978. L G-5, (m), Contention 7, (n), Contention 8, (r) Contention 16a. through (z) Contention 4

16.i. -- Please refer to our response G-3 (r) through (x) above.

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' (17) 16.a.-1 -- We are unaware of "other co.T.ponents" and would appreciate Staff ,

enumerating any other components of and in the spent fuel. storage pool which ,

Applicant has not listed in the request to amend the operating license.

16.a.-2 -- Please refer to Contention 16.a. as .it appears in Admitted Contentions, September 29, 1978, at page 5. There are no studies estimating these enumerated types 'of corrosion. If the Staff knows of any studies or analyses, please inform g

us. We have asked Applicant to furnish same and perhaps Staff should do likewise.

L 16.a.-3 and 4 -- please refer to Contention 16.a. as worded in Admitted Contentions, September 29, 1978, at page 5.

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. 16.b.-1 -- To the best of our knowledge, there are no studies indicating the threat to the integrity of spent fuel, its cladding and other components of and in the spent fuel storage pool due to these corrosion factors. The absence of such a c

study and the fact that the,NRC Draf t Gsneric Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel stated that these  ;

corrosion effects require examination leads us to assert that they should be.

We would appreciate knowing if the NRC Staff disagrees with the Draft referred to, and why.

16.c.-1 -- All pipes subjected to the borated water in the spent fuel storage pool fall under this category. We are unable to identify each and every pipe as requested by the NRC Staff, and would appreciate Staff's requesting the Applicant to enumerate all; pipes in contact with the borated water in the spent fuel pool. i 4

16.c.-2 -- There are no studies, documents or analyses estimating those factors referred to in (a) and (b) of your interrogatory. We would appreciate your ,

identifying any documents which estimate the levels of corrosion referred to therein.

16.d.-1 -- We believe Applicant should discuss the desirability of all available monitoring methods to identify defective fuel elements, including monitoring of individual fuel assemblies. We are unfamiliar with methods of monitoring fuel assemblies and have, therefore, requested Applicant to enumerate those available' and discuss their desirability. This should have been done in the original application to compact spent fuel at Point Beach.

16.d.-2 -- Hopefully, Point Beach operators will be able tc, identify defective fuel elements and take steps to prevent further disintegration which should make future storage and handling possible and safe. Applicant has not yet ,

identified a method for monitoring to detect defective fuel elements.

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(19)- *

'16.d.-3 -- Applicant has not yet addressed the desirability of monitoring each spent fuel assembly. We have no factual basis for saying Applicant should --

just common sense. If Applicant plans to store spent fuel in the Point Beach pools for longer than anticipated, the . utility certainly would want to provide some mechanism for monitoring the spent fuel assemblies to detect leaking elements.

16.d.-4 -- There is no factual basis whatever that spent fuel will remain in tact for the period of licensed plant operation. Despite this lack of information, Staff

'- ', and Applicant, persists in assuming the spent fuel will retain its integrity for j

a h'owever long it is stored at Point Beach. We insist that you must have some

, factual basis for your assertions and that.the burden of proof as well as all the risks should not fall upon the citizens in the area.

s, 16.e.-1 -- Applicant is requesting permission to provide capacity to store 1502 spent fuel assemblies which would be adequate for spent fuel discharged throughout the duration of the operating license. If Applicant did not plan to store this anticipated spent fuel at Point Beach, the utility would not have wasted this time, effort and paper.

16.e.-2 -- Please refer to Admitted Contentions, September 29, 1978, Contention 16.e., at page 7. Applicant has not discussed methods of encapsulating defective spent fuel elements and should do so. One method of encapsulat'ing might be throuf1 an engineered pipe expressly designed for this purpose. We are unaware

'of methods of encapsulation that might be desired by Applicant and have asked .

the utility to discuss same.

16.e.-3 -- Encapsulation of defective spent fuel assemblies may be desirable at Point Beach to assure any necessary handling of the assemblies which does not involve hazards for workers at the Point Beach storage pool or during transfer to shipping casks for removal to another storage pool either on-site or off-site.

16.f.-1 -- To the best of our knowledge, there are no documents, studies or analyses estimating the thickness of crud layers. If Staff is aware of any such

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' (16.f.-1 c::ntinued) .

studies, please inform us -- and Applicant.

16.f.-2 -- We do' not know if crud will influence the corrosion of spent fuel and its cladding. No one seems to know! 'We are alerted by A.B. Johnson in Behavior of Spent Nuclear Fuel on Water Pool Storage at page 65 that this matter should be studied. Does the NRC disagree? If so, please indicate why and enumerate your sources.

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16.f.-3 -- No studies are available to explain why or under what circumstances crud will influence the corrosion of spent fuel and its cladding as a result of the proposed modification of the Point Beach spent fuel pool.

16.g.-1 -- All uncertainties regarding spent fuel pool components integrity as indicated in contentions 16.a. through f. are enumerated in Admitted Contentions, September 29, 1978.

16.g.-2 -- Pier.se see Admittad Contentions.16.a. and c.

16.g.-3 -- Please see Admitted Contentions 16. a., b., c., and f.

( 16.g.-4 -- Please refer _ to Admitted Contentions 16.a. , b. , c. , and f.

16.g.-5 -- Please refer to Admitted Contentions 16.a. , b., c. , and f.

16.g.-6 -- Please refer back to Admitted Contentions 16.g.

16.g.-7 -- Please refer back to Admitted Contentions 16.g. .

16.h.-1 -- We have already described this requested data to the best of our ability in Admitttd Contentions 16.h. at page 8.

-16.h.-2 -- We have'no factual basis, study, analysis or anything else to assert that spent fuel and its cladding will lose integrity due to more dense and increased spent fuel storage at Point Beach. There are admittedly many areas of study that O

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• (16.h.-2 Continu;d) have not yat b:en pursu d (please refer specifically to Admitted Contentions 16.a. , b., and f.) but should be to assure maintenance of spent fuel and'its cladding integrity. To assume that it will without any factual basis or experimentation or experience is irresponsible and further incites lac.k of faith in the NRC and the utility.

16.h.-3 -- Please refer to Admitted Contentions 16.a. and 16.c.

16.h.-4 and 5 -- If the spent fuel cladding disintegrates and loses its ability to contain the spent fuel, there may be difficulty in.. transferring the spent fuel assembly to and from a shipping cask and/or any encapsulating dev'cei utilized.

16.h. " Repositioning of spent fuel in th' expanded storage pool" refers to moving spent fuel assemblies immediately discharo'.d from the reactor to places that are not near the pool liner and transferring those assemblies in places farther away from the pool liner to closer to the liner.

16.h.-7 -- Please re-word for our understanding.

16.1- 1 -- Please refer to the application for Spent Fuel Storage Expansion submitted to the NRC by Wisconsin Electric Power Company for this requested' information.

We have requested similar information fro applicants who should enumerate the existing chemical composition of the Point Beach spent fuel pool water as well as provide this information on the NFS pool water.

16.i-2 -- Please refer to 16.i-1 above.

16.i-3 -- We do not know whether or not the chemical composition of the Point Beach spent fuel pool water will change as a result of the proposed modifications and have asked Applicant to supply- this information to us. We would appreciate the NRC Staff also requesting this information from the Applicant.

16.i-4 -- Please refer to 16.i-3 above.

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.+ ( 22) 16.8.-5 -- Please refer to 16.1.-3 a'bove.

I, Jame Schaefer, hereby swear that I have answered portions of Interrogatories G-1, G-3, G-4 and G-5 and all of Interrogatories 7-1 through 7-3, 8-1 and 8-2, and 16.a.-1 through 16.1.-5 and subparts thereof, which were propounded by the NRC Staff by document dated September 29, 1978, to the best of my knowledge and in all good faith. ,

Dated this 20th day of October, 1978, w/j' &

[Nrs.dendSchdfer 3741 Koehler Drive Sheboygan, WI 53081 414/458-9274 CERTIFICi,T2 0F SERVICE i

Marshall E. Hiller, Esq., Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. '20555 Dr. Paul V. Purdom 245 Gulph Hills Road Docketing and Service Section' (.3) -

Radnor, Pennsylvania 19057 Office of the Secretary U. S. Nuclear Regulatory Commission Patrick W. Walsh, Esq. Washington, D. C. 20555 Assistant Attorney General State of Wisconsin.

Department of Justice 114 East, State Capitol '7 g 7

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Madison, WI 53702 -

Ad/. ( 4%d J an Esteg'-

George F. Trowbridge, Esq. akeshorgCitizensforSafeEnergy 18000 M.. Street, U. W.

Vashington, D. C. 20036 Bruce.'A. Berson Counsel for NRC $taff U; S. Nuclear Regulatory Commission Washington D. C. 20555