ML20027A446
| ML20027A446 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/08/1978 |
| From: | Newton R WISCONSIN ELECTRIC POWER CO. |
| To: | |
| References | |
| NUDOCS 7812050049 | |
| Download: ML20027A446 (23) | |
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NRC PUBLIC DOCCBIENT ROOM st 1 November 8, 1978 ,
UNITED STATES OF AMERICA $
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NUCLEAR REGULATORY COMMISSI0tl
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g@d X . l' I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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'IIn the Matter of ) Docket Nos. 50-266 *
) 50-301 NISCONSIll ELECTRIC POWER '
COMPANY Amendment to License Nos.
- (Point Beach Nuclear Plant, (Increase Spent Fuel.
' Units 1 and 2)- ) Storage Capacity) ;.
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l r l APPLICANT'S ANSWERS TO INTERR0GATORIES - '
PROPOUNDED BY THE NRC STAFF (~ -
ON SEPTEMBER 29, 1978 -
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Interrogatory 1 State subject of whether or not you intend to present any witnesses in this proceeding on the a) Contention 1 (j) Contention 3h (s) Contention 16b b) Contention 2 k) Contention 5 (t) Contention 16c c Contention 3a 1) Contention 6 (u) Contantion 16d
( _.d Contention 3b m Contention 7 (v) Contention 16e e Contention 3c n Contention 8 (w) Contention 16.*
(f) Contention 3d (o Contention 9 (x) Contention 169 g) Contention 3e p) Contention lla (y) Contention 1Ch h) Contention 3f c) Contention llb (z) Contention 161
- 1) Contention 3g (r) Contention 16a ,
and provide the names, addresses, educational background, and professiona quali-fications of those witnesses you intend to present.
RESPONSE
Plans for the presentation of Applicant's case ha':e not yet been fully developed or finalized, hcwever, it is Applicant's present intention to present witnesses to address the subjects of the specified contentions. The tentative witness list is as follows: l 1
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Identifier Name Affiliation RAN Roger A. Newton Wisconsin Electric Power Company EJL Edward J. Lipke Wisconsin Electric Power Company
. . Bechtel Arthur Ranald Bailey Bechtel Power Corporation Wachter Warren T. Witzig Pennsylvania State University Westinghouse Not yet identified Westinghouse Electric Corporation Details of the witnesses' addresses, educational background and professional quali-fications are attached. Tentatively, the specific contentions to be addressed by each witness are as follows:
(a) Contention 1, EJL (n) Contention 8. RAN (b) Contention 2 EJL (0) Contention 9, RAN, EJL (c) Contention 3a, RAN (p) Contention lla, EJL
, (d) Contention 3b, RAN (q) Contention lib, EJL (e) Contention 3c, RAN, EJL (r) Contention 16a, Westinghouse (f) Contention 3d, RAN (s) Contention 16b, Westinghouse
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_. (g) Contention 3e, RAN (t) Contention 16c, Westinghouse (h) Contention 3f, Bechtel (u) Contention 16d, RAN
'(t) Contention 3g, EJL (v) Contention 16e, RAN (j) Contention 3h, RAN, Wachter (w) Contention 16f, Westinghouse (k) Contention 5 RAN (x) Contention 16g, RAN (1) Contention 6, RAN, EJL (y) Contention 16h, Westinghouse (m) Contention 7, EJL (z) Contention 161, RAN l i
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RESUME Roger A. Newton Senior Nuclear Engineer Wisconsin Electric Power Company 231 West Michigan Street Milwaukee, Wisconsin Education:
1964 University of Wiscon::in, B.S. in Mechanical Engineering 1966 Bettis Atomic Power Laboratory Nuclear Engineering School Experience:
1973 - Present: Senior Nuclear Engineer for Wisconsin Electric Pcwer Company.
Engineering project management in the areas of nuclear core design, accident analysis, primary system design, fuel handling and storage, plant instrumentation and control, electrical systems, and turbine generator design for new and operating plants.
1968 - 1973: Reactor Engineer at Point Beach Nuclear Plant. Responsible for initial plant staff training of operators in nuclear reactor behavior and plant transient response, plant startup testing from initial core loading to full power operation, fuel receipt and inspection and plant nuclear core perfonnance.
Obtained senior reactor operators license for Point Beach in
( 1971.
1966 - 1968: Technical assistant for Wisconsin Electric Power Company, training assignment at Westinghouse Electric Corporation, PWR Division. Assisted Westinghouse engineers in preparation of procedures and actual core loading of the San Onofre Nuclear Plant and startup testing of the Connecticut Yankee Nuclear Plant. Assisted in the control system setpoint study for the Robert Emit Ginna Nuclear Plant.
1964 - 1966: Westinghouse Electric Corporation, Bettis Atomic Power Laboratory. Test equipment design and data analysis of nuclear submarine steam generator behavior. Attended the six month full-time Nuclear Engineering School covering advanced courses in mathematics, heat transfer, shielding, control theory, nuclear physics, and nuclear design.
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RESUME '
Edward J. Lipke f
ProjectEngineer(NuclearPlant) :
Wisconsin Electric Power Company 231 West Michigan- !
Milwaukee, Wisconsin Education:
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Educational background of the Radiation Protection Officer (Edward J. Lipke) l 1s as follows: '
i B.S.,1964, Biology, University of Detroit !
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' M.S.,1965, Radiological Health, Wayne State University ;
M.S.,1967, Environmental Health Sciences (Radiological Health), .
- University of Michigan Ph.D.,1971, Environmental Health Sciences (Radiological Health),
University of Michigan i This totals approximately seven years of formal training in a) principles L
' and practices of radiation protection, b) radioactivity measurement standard-ization and monitoring techniques and instruments, c) mathematics and calcu- t lations basic to the use and measurement of radioactivity, d) biological effects of radiation, and 3) other related science and engineering areas.
r Experience:
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$2 weeks as summer student at Fermi I, s2 months as summer student at Battelle - Northwest (Hanford)
" s2 years as Radiological Engineer at Vallecitos Nuclear Center (General Electric) .
- l-1/2 years as Senior Scientist at Bettis Atomic Power Laboratory (Westinghouse) '
$4 years to present as Project Engineer (Nuclear Plant) at Wisconsin Electric Power Company, Nuclear Projects Office i I !
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. .. L PCWER. CORPORATION - PERSCML RESUME NAE _ _
__ ARTHUR RANALD BAILEY ,.___. ... DATE January 1978 7
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CLASSIFICATION __ Engineering Grcup Suoervisor D.'q.',6';. ;. ~' , ~. ., , ,.Q::wj CRGANIZATION & LOCATION
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CITIZENSHIP _ U._S . A . _ _
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CHILDREN'S BIRTH DATE5 8/56. 12/58
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PROFESSIONAL l.ICENSES AND SOCIETIES Registered Professional Civil / structural Engineer, California and Massachusetts 1
l EDUCATION AND' PERSONNEL DEVELOPMENT PROGRAMS DEGREE, CERTIFICATE,ETC. SCHOOL MAJOR (OR SUBJECT) DATE A8 Dartmouth College Engineering 1956 i
( ,MS Thayer School
'" l Civil Engineer 1957 of Engineering i
i OTliER SIGNIFIdANT INFORMATION 4
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L AftTHUR'PMAL5 8AILEY (Cont'd)-
WORK HISTORY l COMPANY, DIVISION, OR POSITION liELD, SIMiARY OF DATES ; DLPARTHENT: RESPONSIBILITIES, AND FROM TO' LOCATION _AND__ SUPERIOR SIGNIFICANT ACCOMPL1SHMENTS 1957 1966 BC Engineer on various projects.
1966 1969 BC, P&I Division Civil group supervisor: assigned to San Francisco, CA Point Beach project. Registered pro-fessional engineer in Wisconsin.
i J.K. Leslie 1969 1971 BC, P&I Division Project engineer and civil super-San Francisco, CA visor: perfortaed miscellaneous t
D.W. Halligan studies, i
1971 1972 BC, P&I Division Civil group supervisor: assigned to San francisco, CA Mendocino project.
J.K. Leslie 1972 Present BPC, SFPD Civil group supervisor: assigned to
- San Francisco, CA Pilgrin 2 project.
8.N. Pusheck i
Attended ACRS Sub-ccmittee meeting
! in Plymouth, Mass. , November,1975.
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T10000SS-01 Page 2 of 2 1-6
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WARREN P. WITZIG i Residence: Office: l 1330 Park, Hills Avenue 231 Sackett Building l State College, Pennsylvania The Pennsylvania State University ;
16801 University Park, Pennsylvania 16302 ;
Telephone: 814-23E-6885 - Telephone: 814-865-4911 i
' Education: i 1942 Rensselaer Polytechnic Institute, B.S. in Electrical Engineering l' 1944 University of Pittsburgh, M.S. in Electrical Engineering 1952 University of Pittsburgh, Ph.D. in Physics l t
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s Experience: I 1967 - Present Pennsylvania State University. Professor and Department l Head of Nuclear Engineering. Here he is responsible to one of .
the largest student programs in Nuclear Engineering. Nuclear ;
Engineering Research is conducted in areas of Reactor Design and
, Safety, Fuel Cycle and Nuclear Economics. He is responsible for the administration of the following facilities: The TRIGA Mark III Reactor, the Cobalt-60 Facility and nuclear laboratories. i 1960 - 1967 NUS Corporation. Senior Vice-President and Board of Directors member. Under his technical direction, the Corpora- ,
tion grew from a two-man organization to the largest independent nuclear consultants of over two hundred engineers and scientists.
Overn11 responsibility for technical direction of work related to the application of nuclear energy for the production of electricity, mall military reactors, test reactors, the use of l nuclear reacte and isot' opec in aerospace. Supervision of physics, environmental sciences, mechanical engineering, thermal and safeguards engineering is involved. Management responsibili- ,
ties for professi nal standards, salaries and marketing.
1942 - 1960 WestinghouAe Research and Bettis Plant. During the war worked on the Mar.nattan District program on high vacuum systems, heat transfer, mass spectroscopy and ionic centrifuge as a scientist. After the war, he served as the first experimenter in ,
the Materials Testing Reactor and later as engineering manager of in-pile tests for the naval reactor program in Hanford, Chalk River and the MTR-ETR complex. He was responsible for the SSW reactor design and engineering used in the SKI? JACK and CEORGF. , ;
' WASHINCTCN series of nuclear submarines which are still being built today.
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i Publications:
" Induction Heating," AIEE Transactions, 1944. ;
" Heat Transfer to Boiling Freon," ASRE,1945. -
t KAPL Reports on thermal cycling and upble gas solubility in sodium-potassium alloy, 1949.
... " Irradiation Effects Cu Au,"
3 Phys. Rev., 1952 and 1953.
"In-Pile Tests at MIR," WAPD Reports, 1954 and 1960.
" Analytical and Experimental Techniques in Nuclear Design," AIEE Transactions, 1960.
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" Nuclear Power Today and Tomorrow," IEEE Spectrum, July 1964.
, " Predicting Criticality and Nuclear Characteristics," Nucleonics,-
Vol. 23, No. 3, March 1965. *
" Safety Analysis of Nuclear Power Plants," presented at the 12th Nuclear Science Synposium, IEEE, published February 1966. .
Nuclear Power Plants in Maryland, Governor's Task Force on Nuclear Power Plants, December 1969, Co-author.
" University Activity and Fast Reactor Development," Fast Reactors and the University, proceedings of an ASEE-AEC short copical conference conducted at Rensselaer Polytechnic Institute, August 28-30, 1968.
" Curriculum Development," Education for Peaceful Uses of Nuclear Explo-sives, University of Arizona Press,1970.
Numerous Classified Topical Reports on reactor physics, thermal and hydraulics and mechanical design of nuclear reactors, Bettis Plant.
Numerous NUS Reports for clients covering diverse fields of nuclear energy application. ,
l . . " Creep of Copper under Deuteron Bombardment," Ph.D. Thesis, JAP, 1952.
Book Review, " Poisoned Power," AIF, Inc., INFO, June 1971.
"An Evaluation of the Concept of Storing Radioactive Wastes in Bedrock Below the Savannah River Plant Site." National Academy of Sciences, Report by the Committee on Radioactive Waste Management, National * #
' Research Council, Washington, D.C., 1972.
" Economic Analysis of the Nuclear Fuel Cycle," Nuclear Technology, Vol. 13, January 1972, W.F. Witzig and I..M. Cirvin. -
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/ Publications (Cont.):
AIF Report on Access to Enrichment Technology, Committee Chairman, AIF i Meeting on Nuclear Fuel Cycle, Dallas, Texas, January 1972. ;
- " Nuclear Controversy in the U.S.A., Power Reactor Safety," International Workshop, Lucerne, Switzerland, May 1972, W.F. Witzig and W.H. D'Ardenne.
" Container Ships:
Vol. 22, May 1974, Thomas B. Dade and W.F. Witzig. Oil Fueled Versus i
'. "An Agro-Power-Weste Water Complex for Land Disposal of Waste Heat and
. Waste Water."
Interdisciplinary Research Team, Institute for Land and t
. Water June 1974.Resources, The Pennsylvania State University, NSF Grant GI-35100,
~' "TRICA Core Management hbdel," Nuclear Technology, Vol. 23, September 1974, W.F. Naughton, M.J. Cenko, S.H. Levine, and W.F. Witzig.
"The Agro-Power-Wasta Complex," European Nuclear Conference, Paris.
France, April 21-25, 1975, M. A. Schultz and W.F. Witzig. *
- " Reactor Operator Screening Test Experiences," Coauthored by William O'Brien, Consultant. Duquesne Light Company, J.L. Penkala, Consultant, W.F. Witzig, June 1975, Palo Alto, California. Presented to EPRI workshop on Operstor Selection
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"American Nuclear Society Public Information Activities," Nuclear Technology, Vol. 27, September 1975, W.F. Witzig. e l' Energy Parks and the Commonwealth of Pennsylvania-Issues and Recom manda-tions." Volumes Energy Council. 1 and 2. (1975) Report to the Pennsylvania Government
- Witzig (Contributor). Center for the Study of Environmental Policy. W.F.
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" Interim Storage of Solidified High-Level Radioactive Wastes." National Academy of Sciences, Panel on Engineered Storage, Coc=1ttee on Radioactive Waste Management, National Research Council, Washington, 1975. *
" Nuclear Science Education and Technology Transfer Programs at Thennsyl- Pe vania State University,"
McKee, W.F. Witzig. ANS Transactions, June 1976. W.A. Jester, J.R. .
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" Statement to the Mines and Energy Management Committee." Pennsylvania HouseState vania of Representatives, Pittsburgh, Pennsylvania, U.F. Witzig, Pennsyl-University, September 16, 1976.
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"A Summary Witzig, of DeWalle.
and D.R. U.S. A. Activities in Low Temperature Soclear Heat," W.F. - 4 Temperature Nuclear Heat on AugustPresented at the Topical 22, 1977 in Helminki, Finland. 3keting on Low o
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" Nuclear Wastes as a Heat Source " W.F. Witzig and hLZ. Foster.
Presented at 24,the Topical 1977 MeetingFinland.
in Helsinki, on Low Tamparature Nuclear -Nuclear Beat on August .
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/ Publications (Cont.):
?. "A Regression Model for the Prediction of Shutdown Margin for Boiling Water Reactors," ANS Transactions, ANS Winter Meeting, 1977 in San Francisco, Ross T. Thomas and W. F. Witzig.
" Teaching Fuel Management at Penn State - Successes and Failures,"
Transactions of the International. Nuclear Society Meeting in Iran, April 1977, W. F. Witzig and S. H. Levine.
'" Statement to the Mines and Energy Management Committee." Pennsylvania *
' House of Representatives, Harrisburg, Pennsylvania, W. F. Witzig, Pennsylvania State University, October 21, 1977.
"A High-Speed In-Core Management System for PWR's," ANS Trans.
Vol. 26, November 1977, M. Cenko, S. H. Levine, and,W. F. Witzig.
" Ice Pond Cooling of a Power Plant," submitted to Nuclear Technology,
, J. Urbanski, G. C. Geisler, and W. F. Witzig.
"A Model for the Prediction of Shutdown Margin for Boiling Water
- Reactors," submitted to Nuclear Science and Engineering, March 1978, R. T. Thomas and W. F. Witzig.
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Memberships: '
Institute of Electrical and Electronics Engineers - Past Chairman i of the Administrative Committee for Professional Group-on I Nuclear Science. ,
Argonne Universities Association - Past Chairman, EBR II Review
, , _ . Committee. . t American Nuclear Society - Past Chairman, National Committee on i Public Information;.Past Chairman, Sub-committee on Associate l Degree Curriculum; member of Executive Committee, Education ,
Division.
k Named a " Fellow of the American Nuclear Society," June 1974. o American Physical Society. -
Washington Academy of Sciences - Joint Board of Science Education. *
- Sigma Xi, Sigma Pi Sigma, Eta Kappa Nu (Honorary Societies).
i Nuclear Standards Board Past Member, USASI, N45 Committee, N18 Committee.
Registered Professional Engineer, Commonwealth of Pennsylvania
- 8633 and District of Columbia #4821E. , .
. t Sierra Club member. ,
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University Club of Washington, D.C. ; Centre Hills Country Club, -
State College, Pennsylvania.
- Pennsylvania Society of Professional Engineers, Environmental Task Force member. ,
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Pennsylvania Governor's Advisory Committee on " Regulation and Devel- I
, opment" - Sub-committee Chairman on " Power"; Sub-committee member on Power Plant Siting. l
' Pennsylvania Governor's Advisory Committee on " Atomic Energy Devel- !
opment and Radiation Control."
, i National Academy of Science - Rad-Wasta Committee member.
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American Society of Engineering Education - Past Chairman, Nuclear . .c '
Engineering Division. ,
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Memberships (Cont.):
Atomic Industrial Forum - Pennsylvania State University Representative Chairmin, Access to Enrichment Technology. -
.i Who's Who in America - 1972-1973. .
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P'rsonal: I Born March Buffalo, New York26, 1921, suburbs. Detroit, Michigan. Attended public schools in to Recruit Married, fourandchildrun. Train W.CA leaders." Elder Presbyterian ChitrchBoard M
. Height 6 ft. 2 in. Weight: 200 lbs. .
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Warren F. Witzig .
ADDENDUM !'
i During World War II Dr. Witzig, as a Westinghouse Engineer, worked on the Manhattan District Project in the field of isotope separation. Work i in similar areas was continued in the R'escarch Laboratories and led to his selection as one of the early employees in the Bettis Laboratories for !
research and development on submarine nuclear propulsion. He worked on the
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submarine Sea Wolf and performed fundamental studies on radiation effects.
He supervised radiation behavior of nuclear fuels in Ranford, Washington;
- Idaho; and Chalk River, Canada for submarine application. He supervised the first criticality approach of the submarine Nautilus and wrote the safety analysis for'that ship's triumphant entry into New York City Earbe,r
, after its submerged cruise around the North Pole. ,
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Dr. Witzig was responsible for the reactor design and operation known as SSW for the ships SKIPJACK and George Washington, of which = ore than 200 reactor cores have been built.
cial plant, Shippingport. He also assisted work on the first co=mer .
He then =oved to civilian application as one of the cofounders of the NUS corporation, the world. the largest independent nuclear and energy consultant in
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This activity grew from a two-man organization to over 200 '
professionals at the time he moved to academic endeavors.
At The Pennsylvania State University he has helped expand the graduata student ate'levals. body and initiated two new degree programs at the B.S. and Associ-s His principal areas of study and research are nuclear engi-neering education, reactor design and operation, training programs, fuel ,
management and economics, and nuclear safety and plant siting.
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During hiIs professional career Dr. Witzig has beca a consultant on the fo11 ewing reactors and organizations: ;
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Reactors
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Three Mile Island, Pathfinder. Big Rock Point, San Onofre, Peach ,
Bottom, Nuclear Submarines, Army plants (PM3A, PM1A, Camp Century, MH1A), Yankee Rowe, Hallam, Bres:eale; Calvert Cliffs, NTS repro-
- cessing, MTR, ETR, EBR II, Saxton, KWO (West Ger=any), Selni (Italy), KR3 (West Germany), OKH (Sweden) .
_ Organizations National Academy of Sciences; Pennsylvania Depart =ent of Environ-mental Protection; Brown Boveri Krupp (West Ger=any); Electrovatt - C (Switserland); West Ger=an Taiwan, Japanese, Phillippine, and Finnish governments; Air Products; NUS; SAI-JRD; Franklin Institute;-
Cincinnati Cas & Electric; Boston Edison; Duquesna Light; Chem 71=; .
Argonna Universitiss Association; and others.
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Interrogatory 2 Provide summaries of the views, positions, or proposed testimony on a) Contention 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 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 Contention 3e (p) Contention lla (y) Contention 16h Contention 3f (q) Contention lib (z) Contention 161 Contention 3g (r) Contention 16a of all persons named in response to Interrogatory No.1 that you intend to present during this proceeding. ,
RESPONSE
The following responses summarize our views, positions, and/or proposed testimony on each of the contentions that Applicant currently intends to present during the hearing by the witnesses listed in the response to Interrogatory 1. The responses provided herein are preliminary in nature and are not intended to represent the final content of testimony that will be filed at a future date in accordance with the established hearing schedule. i
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(a) Co,ntention 1 - The testimony will show that the potential incremental airborne releases and doses to the public, if any, are insignificant. Therefore, the ,
publishing of monitoring results need not be considered.
(b) Contention 2 - The testimony will present a conservative analysis showing that any incremental releases are insignificant, both individually and combined.
Infonnation presented in the response to Contention 1 will provide the basis for the response to Contention 2. '
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(c) Contention 3a - The testimony will describe the design features and the arrange-ment of components to the spent fuel pool cooling system. The performance of the cooling system with increased spent fuel storage will be presented, as well as its capability to handle the heat load from two core unloads. The testimony will conclude that the cooling system is capable of removing heat from spent fuel under all likely conditions.
(d) Contention 3b - The testimony will describe the design of the inlet and outlet cooling system piping and show that blockage is extremely unlikely. If one
(.' were to assume that blockage did occur, just for the sake of discussion, Applicant will describe what would happen and refer to the next contention response for pool water heatup behavior.
(e) Contention 3c - The testimony will review the design features of the cooling system and explain that the loss of both cooling trains is extremely unlikely.
The loss of all cooling will nevertheless arbitrarily be assumed and the resulting effect on pool water temperature, and the associated assumptions in calculating the pool temperature response, will be presented. The testimony will explain that the incremental. increase in spent fuel storage and the resulting effect on heat addition to pool water will not cause boiling because the cooling system has sufficient heat removal capability to handle it.
(f) Contention 3d - The results of a loss of pool cooling, which would include loss of service water flow or pumps, will have been discussed in the response to Contention 3c. The loss of pool water is not considered possible and the various methods of adding water to the pool will be described. The worker activity associated with the spent fuel pool and storage of fuel before and after the rerack will be described and result in the conclusion that there is no significant increase in worker activity.
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(g) Contention 3e - The testimony will show that repairs to the liner can be made while the fuel is stored in the pool. A typical liner repair process will be described to show that the pool does not have to be dewatered. Worker activity will have been discussed in the response to Contention 3d and the design considerations of the pool to withstand the increased burden will be discussed in the response to Contention 3f.
(h) Contention 3f - The Applicant's witnesses will describe the pool structural analysis that has been performed, which includes seismic forces, to evaluate
' the effects of the increased weight due to increased spent fuel storage. The analysis will show that the pool structure will withstand the forces from the postulated events.
(i) Contention 3g - The testimony will describe the planned method for rack removal and shipping.
(j) Contention 3h - The Applicant's witness will describe the neutron cbsorber material and the results of testing that has been performed to qualify the material. The material will be phewn to be acceptable for the planned spent fuel storage.
(k) Contention 5 - The design considerations of the pool and associated plant features will be described. It will be shown that the pool is designed to not fail under all credible events and, therefore, forced removal will not be necessary.
(1) Contention 6 - The testimony will describe the pool structure, liner and leak detection system. If the liner were to leak, the leak detection system would indicate that leakage was occurring and the liner would be repaired by the 2-3
methods that will be described in the response to Contention 3e. The testi-l many will also describe the direction of ground water flow and the present sampling program.
(m) Contention 7 - The testimony will describe the types of solid low-level radio-active wastes associated with the spent fuel pool and the expected increases in these wastes due to the increased spent fuel storage. The plan for disposal of these wastes will be described, including a statement that no plans for on-site land burial exist.
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(n) Contention 8 - The testimony will review Applicant's history with NFS, identify the number of assemblies in storage, explain the possibie need for return of 4
assemblies and the timing for their return. The storage environment at NFS will be described as well as the basic structural integrity inspection at the time of shipment from NFS. Successful shipping experience of the nuclear industry will also be referenced. The testimony will show that the assemblies will be received at Point Beach intact and safe for storage.
i( (o) Contention 9 - The testimony will show that the emergency plan in its present form encompasses postulated emergencies far more severe than could arise from the storage of spent fuel, both before and after reracking.
(p) Contention lla
- The testimony will show that the incremental effect of the increased storage of spent fuel on the health of the occupational personnel at point Beach is essentially zero. l (q) Contention 11b - The testimony will show that the incremental effect of the increased storage of spent fuel on the health of the general public who live in the vicinity of the plant is essentially zero. -
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l (r Contention 16a (s)) Contention 16b (t) Contention 16c ;
(w) Contention 16f - The testimony will discuss the long term integrity of fuel !
and pool components. The experience of fuel that has been stored for long l periods of time will be referenced and the corrosion rate of these materials !
will be presented. The testimony will show that the fuel will remain intact !
and can be safely stored and handled while at Point Beach. !
l (u) Contention 16d - The testimany will describe the spent fuel pool monitoring s and will explhin why there is no need for additional monitoring of individual fuel assemblies. <
i (v) Contention 16e - The testimony will show that there is no need for encapsula- ,
tion of fuel assen:blies.
t (x) Contention 160 - The testimony will show that water pool storage has been demonstrated to be a safe and effective method of storing spent fuel.
Alternatives to the proposed method were surveyed for their feasibility.
and pool storage at Point Beach was found to be the best and least expensive means for storage. .
t (y) Contention 16h - The testimony will show that there will be no problems in '
handling spent fuel.
(z) Contention 161 - The testimony will explain that the discussion on fuel assembly corrosion properties in the response to Contentions 16a,16b,16c, and 16f is applicable to fuel stored at NFS as well as at Point Beach. The testimony will show that no detrimental corrosive effect will occur as a result of chemical differences between the NFS and Point Beach storage pools.
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Interrogatory 3 Identify by author, title, date of publication 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) 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 16g Contention 3e Contention lla y) Contention 16h Contention 3f Contention lib z) Contention 161 Contention 3g ) Contention 16a
'(_,, and provide copies of, or make available for Staff inspection and copying, these items. '
Resp 0NSE:
Following is a tentative list of books, documents, papers and submittals which may be used in presenting Applicant's direct case on the above listed contentions.
- 1. Wisconsin Electric power Company's application for Spent Fuel Storage Expansion dated March 21, 1978, and the references cited therein.
- 2. Modificatien to the application dated June 14, 1978, and the references cited
( therein.
- 3. Modification to tne application dated September 29, 1978, and the references cited therein.
I
- 4. Additional information to the application dated July 19, 1978.
- 5. Additional information to tha application dated October 10, 1978.
- 6. " Applicant's Answers to Interrogatories Propounded by Intervenor on September 27, 1978", dated October 27, 1978.
- 7. " Applicant's Answers to Interrogatories propounded by The State of Wisconsin on October 2,1978", dated flovember 1,1978.
- 8. Band Industrial Services, Inc. , Report No.1047-1, "Boraflex I Suitability Report", Revision 1, dated May 5,1978.
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- 9. A. B. Johnson, " Behavior of Spent Nuclear Fuel in Water Pool Storage",
Battelle Northwest Laboratory 2256, September 1977.
10.
4 DOE, " Draft Environmental Impact Statement Storage of U. S. Spent Power Reactor Fuel". DOE /EIS-0015-D, August 1978. '
- 11. NRC, " Draft Generic Environmental Impact Statement Handling and Storage of Spent Fuel From Light Water Nuclear Power Reactors", NUREG-0404, March 1978.
- 12. ERDA, " Alternatives for Managing Wastes from Reactors and Post Fission Operations in the LWR Fuel Cycle", ERDA 76-40, May 1976.
k The above references represent a preliminary list which may be modified or expanded as testimony preparation proceeds. Applicant assumes that copies of the above !
listed documents are in the possession of the Staff.
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e 9
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Interrogatory 4 Identify by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in conducting your cross-examination of witnesses for other parties who may testify in con.7ection with (a) Contention 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 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 g) Contention 3e (p) Contention lla (y Contention 16h h) Contention 3f (q) Contention 11b (z) Contention 161 i) Contention 3g (r) Contention 16a
( RESP 0tiSE:
The books, documents, papers and submittals identified in the response to Inter-rogatory 3 may be employed in conducting Applicant's cross-examination of witnesses.
The references cited therein represent a preliminary list which may be modified or expended as preparation for the hearing proceeds.
The responses to interrogatories contained herein were prepared by Roger A. Newton.
(
gr'y.A. G Roger 'A. Newton Senior Nuclear Engineer Subscribed and sworn to before me this 8th day of November 1978.
W% WA& A+ w .
Notary Publick 3 tate of Wisconsin My Comission expires 4S 6, /13 0 -
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November 8, 1978 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!411SSI0tl BEFORE THE ATOMIC SAFETY AfID LICEflSING BOARD 3 In the Matter of Docket Nos. 50-266 50-301 WISC0llSIN ELECTRIC POWER C0ftPAtlY Amendment to License Nos.
DPR-24 and DPR-27 (Point Beach fluclear Plant, (Increase Spent Fuel Units 1 and 2) ) Storage Capacity) !
L. I AFFIDAVIT OF SERVICE I hereby affirm that copies of " Applicant's Answers to Interrogatories Propounded by the NRC Staff on September 29, 1978", were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 8th day of November,1978.
(f N. Y Roger A. Newton Senior Nuclear Engineer Subscribed and sworn to before me this 8th day of flovember 1978 .
N Wm J' Notary PubUic, State of Wisconsin My Commission expires LR (,, /170.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE hTOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-266 50-301 WISCONSIN ELECTRIC POWER COMPANY Amendmant to License Nos. <
(Point Beach Nuclear Plant, (Increase Spent Fuel Units 1 and 2) ) Storage Capacity) 7
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SERVICE LIST Marshall E. Miller, Esq. Bruce A. Berson, Esq.
Chairman Office of the Executive Legal Director Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Ms. Mary Lou Jacobi Dr. Emmeth A. Luebke Vice Chairperson Atomic Safety and Licensing Board Lakeshore Citizens for Safe Energy U. S. Nuclear Regulatory Commission 932 N. 5th Street Washington, D. C. 20555 Manitowoc, Wisconsin 54220 <
Dr. Paul W. Purdom Patrick W. Walsh, Esq.
(l- 245 Gulph Hills Road Assistant Attorney General Radnor, Pennsylvania 19087 The State of Wisconsin '
Department of Justice Docketing and Service Section 114 East, State Capitol Office of the Secretary Madison, Wisconsd n 53702 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Ms. Sandra Bast 1112 N. lith Street Atomic Safety and Licensing Appeal Board Manitowoc, Wisconsin 54220 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Ms. Jame Schaefer 3741 Koehler Drive Sheboygan, Wisconsin 51081 I