ML20028E160
| ML20028E160 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/17/1983 |
| From: | Coleman J BEVERIDGE, FAIRBANKS & DIAMOND, LOUISA COUNTY, VA |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20028E158 | List: |
| References | |
| ISSUANCES-OLA-2, NUDOCS 8301210038 | |
| Download: ML20028E160 (53) | |
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gotKE.TE1/17/83 ysNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION m ;jg
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In the Matter of )
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VIRGINIA ELECTRIC AND ) Docket Nos. 50-338/339-OLA-2 POWER COMPANY )
)
(North Anna Power Station, )
Units 1 and 2) )
(Proposed Amendment to Operating License to Permit Expansion of Spent Fuel Pool Stornge Capacity)
CONTENTIONS OF INTERVENORS COUNTY OF LOUISA, VIRGINIA AND THE BOARD OF SUPERVISORS OF THE COUNTY OF LOUISA Intervenors County of Louisa, Virginia and the Board of Supervisors of the County of Louisa ("Louisa County' or "the County") make the following specific contentions with regard to a license amendment proposed by Virginia Electric and Power Company
("Vepco" or "the applicant") to permit the expansion of fuel storage capacity for North Anna Nuclear Power Station Units No. 1 and 2 from 966 to 1,737 fuel assemblies and identify a new nominal center-to-center spacing between fuel assemblies of 10-9/16 inches.
I. Need for Proposed Action The applicant has not established a need for the proposed action.
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The Council on Environmental Quality regulations require the Nuclear Regulatory Commission ("NRC" or "the Commission"), in considering a proposed action, to determine whether there is a "need for the proposal," and these regulations are binding on all federal agencies, including NRC. In response to this requirement, Vepco asserts that it needs to expand the North Anna pool in order to provide storage capacity for the 500 Surry fuel assemblies it plans to ship to North Anna. As discussed at length in the County's contentions filed in the companion proceeding concerning Vepco's application to receive and store Surry spent fuel at North Anna, ! the County contends that Vepco has not established a need to ship Surry spent fuel to North
. Anna. The North Anna pool's present capacity, according to Vepco's figures, allows North Anna to continue operating
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without loss of full core reserve until 1989 and to maintain refueling capability until 1990 (North Anna 1) and 1991
- 1/ 40 C.F.R. $ 1508.9(b) (1982).
l j2 Andrus v. Sierra Club, 442 U.S. 347, 358 (1979); 40 C.F.R.
1500.3 (1982).
3/ Contentions of Intervenors County of Louisa, Virginia and the Board of Supervisors of the County of Louisa, Relating to Vepco's Proposed Amendment to Operating License to Allow Receipt and Storage of 500 Spent Fuel Assemblies from Surry Power Sta-tion, Units 1 and 2 at 2-4. The County argues principally that (1) threatened loss of full core reserve does nat establish a
~' need to ship Surry fuel, (2) Vepco has provided no data to support its assertions that Surry will lose full core reserve in 1984 and refueling capability in 1987, and (3) other documents cast doubt on Vepco's assertions.
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(North Anna 2); and Vepco does not assert that No'rth Anna's own storage needs establish a need for the proposed action.
Indeed, there is evidence that supports the conclusion that Vepco's nuclear plants need not be operated at maximum capacity. Vepco is currently in the process of selling to the Old Dominion Electrical Cooperative ("ODEC") 25 percent of North Anna 2 and 12.5 percent of the North Anna Power Station's common facilities, a move which suggests that Vepco may have overbuilt its baseload capacity and may not need to continue to operate its nuclear plants at the same capacity level as has been the case in the past.
Given the Commission's statutory obligations under the National Environmental Policy Act of 1969 ("NEPA") and the .
Atomic Energy Act of 1954 ("AEA") to minimize adverse 5/
environmental effects- and to safeguard the public against radiation hazards to health and safety, the NRC should not embark on a proceeding that could result in substantially increased handling of spent fuel, and thus increased environmental and health and safety risks, unless the need for such a proceeding has been clearly shown. Vepco has not shown such a need here.
! 4/ 1981 Annual Report of Virginia Electric and Power Company at 2-3, 12-14.
F 5/ Public Service Company v. U.S. NRC, 582 F.2d 77, 81, 85-86 Tlst Cir.) cert. denied, 439 U.S. 1046 (1978); Calvert Cliffs i
Coordinating Committee, Inc., v. U.S. AEC, 449 F.2d 1109, 1128 D.C. Cir. 1971).
II. Consolidation The proposed action is integrally related to the appli-cant's other proposed actions now before the Commission.6/
Therefore, the three elements of the applicant's plan --
namely, receipt and storage of Surry spent fuel at North Anna, expansion of the North Anna spent fuel pool and trans-shipment of Surry fuel to North Anna -- should be considered in consolidated proceedings to ensure that the cumulative environmental, health and safety, and common defense and secur'.ty impacts are properly addressed.
As support for this contention, Louisa County notes that the courts have consistently held that, even apart from any agency responsibility to prepare an environmental impact statement, "NEPA mandates comprehensive consideration of the effects of all federal actions. 42 U.S.C. { 4332(2)(A). To l
permit noncomprehensive consideration of a project divisible into smaller parts . . . would provide a clear loophole in NEPA." City of Rochester v. United States Postal Service, 541 F.2d 967, 972 (2d Cir. 1976). Indeed, without the other 1
6/ Vepco concedes the interdependence of the plans to receive and store Surry fuel at North Anna and to expand the North Anna pool. " Storage of Surry spent fuel assemblies at North Anna
, would, of course, hasten the day when the North Anna pool would I be filled. Thus, Vepco has also applied to NRC for a license j
amendment authorizing the installation of neutron-absorbing racks I at North Anna Units 1 and 2." Applicant's Answer to Motion of Intervenor Louisa County to Stay Proceedings. Affidavit of Marvin L. Smith at 1 5 [ hereinafter Smith Affidavit].
~5-elements of Vepco's plan there is no cognizable need for expansion of the spent fuel pool at this time.
III. Scope of Environmental Inquiry Required ,
A. The proposed action, viewed either alone, or in con-I junction with the other integral elements of Vepco's plan (i.e., transshipment and receipt and storage of Surry fuel at North Anna), is "a major Federal action significantly affecting the quality of the human I
environment," and therefore the Commission must prepare an environmental impact statement in accordance with the provisions of 42 U.S.C. $ 4332(C).
As the Council on Environmental Quality (CEQ) regulations make clear, "[s]ignificance cannot be avoided by terming an action temporary or by breaking it down into small component parts." 40 C.F.R.
l
$ 1508.27(b)(7) (1982). Rather the question of significance turns on, inter alia, "whether the action is related to other actions with individually insig-nificant but cumulatively significant impacts.
Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment."
i Id. See also City of Rochester v. United States Postal Service, 541 F.2d 967 (2d Cir. 1976). The CEO regula-R tory requirements are binding on the NRC. Andrus v.
l Sierra Club, 442 U.S. 347, 358 (1979).
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B. Vepco's environmental analysis is insufficient to form the basis for Commission compliance with NEPA (42 U.S.C. $ 4332(A)) or with 10 C.F.R. 51.7(b) (1982) which requires consideration of the " probable impacts of the proposed action on the environment because Vepco has failed to consider the environmental :onse-i quences for Louisa County (1) if no other storage facility is available when North Anna loses full core reserve or when the North Anna pool is filled to 8/
capacity- or (2) if no permanent solution is on-line for handling the spent fuel stored at North Anna at the end of North Anna's operating life.
The dates at which North Anna will lose full core reserve and refueling ability depend on whether the proposed action is viewed in isolation or in conjunc-l tion with the proposed transshipments from Surry. The l
l applicant's submittals assert, without supplying any l data, that if the pool is evuanded and Surry fuel is l
stored at North Anna, North Anna will lose full core 2/ See also 40 C.F.R. 1508.9(b) (1982) which states that an l
environmental assessment "[s]hal( include brief diseassions of the need for the proposal, of alternatives as required by Sec. 102(2)(E) [42 U.S.C. 4332(2)(E)], of the environmental impacts
! of the proposed action and alternatives, and a listing of l agencies and persons consulted."
P 8/ Possible consequences include premature shutd?dn nf the North Anna station and a consequent loss of jobs for County residents and tax revenues to the County.
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reserve in 1990 and refueling ability in 1993. If the pool is expanded but no Surry fuel is shipped, Vepco asserts that North Anna would have adequate storage until 1998. Presumably, if the fuel is shipped but the pool is not expanded these dates would be advanced significantly, but Vepco makes no assertion based on this scenario.
Given the uncertainties that have characterized past Federal action on the spent fuel permanent storage question and the current commission uncertainty whether permanent storage facilities will be in existence at the end of North Anna's operating life, NEPA also requires the Commission to consider the environmental impact that will obtain if no permanent facility is operational when North Anna reaches the end of its
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life. Potomac Alliance v. U.S. Nuclear Regulatory Commission, 682 F.2d 1030 (D.C. Cir. 1982).
9/ Smith Affidavit at 5 5.
M/ Summary of Information In Surport of the Storage of Surry Spent Fuel At North Anna Power Station Unit Nos. 1 and 2 at 2 (July 1982) [ hereinafter Storage of Surry Fuel Summary].
11/ A Summary of Information In Support of Increasing the Spent F31el Storage Capacity At North Anna Power Station, Units 1 and 2 at 6 (August 1982) [ hereinafter Increased Storage Capacity Summary].
IV. Occupational Exposure Concerns Vepco has failed to provide sufficient information regarding the control of occupational radiation exposure to workers who will be handling the existing stored spent fuel at the Nor'h c Anna plant, removing old spent fucl racks, installing new racks, and l
disposing of the obsolete equipment. Therefore, Vepco has not demonstrated that occupational exposure levels will be "as low as is reasonably achievable" as required by 10 C.F.R. { 20 (1982).
In performing the spent fuel storage pool expansion project, Vepco plans that the existing high density spent fuel racks will be removed from the pool, decontaminated, and cut up for disposal 12/ Vepco states further that measures will be taken to of f site .--
ensure that personnel exposure will be kept as low as is reason-ably achievable but no details are given as to how this task is to be accomplished. The existing spent fuel racks will be contaminated, existing spent fuel will have to be mcved in the l
pool, and the procedures of how this will be accomplished have l
l not been identified. Overexposure of workers has occurred at i
l other facilities where similar expansion projects have been attempted and Vepco's failure to identify how overexposure is to I be avoided at North Anna represents a concern and a potential danger to plant workers, many of whom are residents of Louisa County.
s 12/ Increased Storage Capacity Summary at 86.
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l V. Alternatives I
Vepco's analysis of the available alternatives is insuf-ficient to serve as the basis for NRC compliance with its NEPA obligation "to study, develop, and describe appropriate alter-natives to recommended courses of action in any proposal which l
involves unresolved conflicts concerning alternative uses of
! available resources.' 42 U.S.C. $ 4332(2)(E).
The obligation to consider alternatives arises regardless of wheher a proposed action is significant enough to warrant a full-scale environmental impact statement. Rather, it is an independ-i ent NEPA requirement that comes into play whenever "the objective l
! of a major federal [ action] can be achieved in one of two or more ways that will have differing impacts on the environment." Trinity Episcopal School Corp. v. Romney, 523 F.2d 88, 93 (2d Cir. 1975).
Moreover, even if Vepco's analysis of alternatives were exhaustive, the obligation imposed by 4332(2)(E) is the agency's, not the applicant's; the courts therefore have held that it is improper for an agency to rely solely on the evidence submitted by an applicant as to the feasibility.of other alternatives. City of New yaven v.
Chandler, 446 F. Supp. 925, 934 (D. Conn. 1978).
As support for its alternatives contention, Louisa County I
notes the following:
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13/ Accord, Township of Lower Alloways Creek v. Public Service Electric & Gas Co., 687 F.2d 732, 739 n. 14 (3d Cir. 1982);
Aertsen v. Landrieu, 637 F.2d 12, 20 (1st Cir. 1980).
mr w --- - - -
A. In the materials submitted in support of the instant application, Vepco does not even consider the option of increasing Surry's pool storage capacity, despite the fact that it is Surry's shortage that prompts the current proposal to expand the North Anna pool. The companion application, however, asserts, without support, that the Surry pool cannot be expanded because "no additional weight can be allowed in the Surry spent fuel pool.
Vepco, however, fails to address the possibility of installing aluminum racks at Surry, and thereby increasing the total storage capacity at Surry by about 10 percent without exceeding the pool's claimed load capacity.
B. Vepco rejects the option of constructing a new pool at Surry, even though such a pool would meet Surry's storage needs until a federal repository is available, because, it asserts, a new pool would cost $100-125 million and take eight years to design, license and 14/ Summary of Information In Support Of The Storage of Surry Spent Fuel at North Anna Power Station, Unit Nos. 1 and'2 at 16 (July 1982) [ hereinafter Storage of Surry Spent Fuel].
15/ For the convenience of the Board, a copy of a letter to Vepco discussing the possibility of using aluminum racks at Surry is appended at Attachment A.
16/
c on s t ru ct .--- No data are supplied to support these assertions. The Johnson Report, however, estimates that a new pool could be operating at Surry within seven years, and other internal Vepco documents estinate that a new pool could be available at Surry within six years of a oroject start-up at a cost of
$70-98 million in 1982 dollars.
C. Vepco rejects the dry cask option because, it asserts, "it is . . . less certain that this alternative would be available in a timely manner to meet the spent fuel 19 storage needa at North Anna Units 1 and 2. '"- / By Vepco's own' reckoning, however, North Anna has sufficient capacity now to store its own fuel through 1990, and dry-cask could surely be on-line before that date. The Johnson Report estimates that design, l licensing, construction and preoperational procedures associated with dry-cask could be completed within 42 months. Since Vepco has already filed for the neces-l t 16/ Increased Storage Capacity Summary at 17.
17/ A Preliminary Assessment of Alternative Dry Storage Methods l' For _the Storage of Commercial Spent Nuclear Fuel, JAI-180 (DOE /ET l 47979-1 (UC-85)), Nov. 1981, at 7-3.
l 18/ Current Cost Estimates, Independent Fuel Storage Installa-tTon, Surry Power Station - Units 1 and 2 (Vepco Memorandum, Oct.
l 6, 1982), Attachment 2 [ hereinafter Current Cost Estimates]. For the convenience of the Board, this document is reproduced as Attac'r. ment C herein.
19/ Increased Storage Capacity Summary at 18.
I
sary Commission approvals for dry-cask (October 8, 1982), this means dry-cask storage could be avail-able at Surry beginning in 1986. If by " fuel storage needs at North Anna," Vepco means storage of Surry fuel, dry-cask would still be available well before the Surry pool is full in 1987. Alternatively, if Vepco means storage of spent fuel generated at North Anna, Vepco has not produced a scintilla of evidence suggest-ing that that plant may be threatened with a storage problem.
D. Vepco rejects the alternative of reprocessing because, it asserts -- again, without foundation -- that "under current administration policies" shipment to a foreign reprocessing center "would almost definitely be con-sidered inimical to [the common defense and security]
of the United States.- Yet, at least one admini-stration spokesperson, John Marcum of the White House Office of Science and Technology Policy, has indicated that there are "no impediments to U.S. utilities
(, 20/ Vepco filed its initial NRC application for dry-cask on l
October 8, 1982. (NRC Docket No. 72-2).
21/ Vepco's internal documents also project a 1986 startup date for a dry-cask facility at Surry. Current Cost Estimates, Attachment 1.
22/ Increased Storage Capacity Summary at 19.
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contracting to have spent fuel reprocessed in foreign 23/
plants.'
E. Vepco presents no data to support its assertion that an
" extended burnup" program would have no more than a negligible impact on Vepco's near-term fuel storage requirements. Even if it is true, as Vepco asserts, that Surry will lose full core discharge capability in 1984, only a small increment of additional capacity, if any, is required to meet Surry's storage needs until dry-cask could be available. During the first year that Surry discharges more assemblies than it can store while maintaining full core reserve, the excess number of assemblies will be only 61-65. It is possible that extended burnup, used alone or in conjunction with
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one of the other rejected alternatives (e.g.,
contingent transshipment, operating Surry or North Anna at a reduced power level, temporary installation of spent fuel racks in Surry's cask handling area), could provide the needed increment.
l 23/ " Bring Back Buy-Back," Nuclear News at 61-62 (Oct. 1982).
l 24/ Increased Storage Capacity Summary at 21, 25/ Johnson Renort at 3-4, Spent Fuel Disposition lternatives Study for Vepco (Ebasco, Mar. 1980) at A4-3 Lhereinafter Ebasco Report].
F. Vepco's assertion that it cannot operate North Anna at a reduced power level (and thereby extend the life of the fuel) because to do so would involve "significant economic penalties" is again totally unsupported and disingenuous. There is no present need to operate North Anna at a reduced capacity -- the solution lies in the creation of the problem. Vepco has manufactured a spurious storage problem at North Anna by shipping Surry fuel there. Rather, as mentioned earlier, there is no current storage problem at North Anna for which a cure is necessary. This fact is highlighted by Vepco's divesture of substantial portions of the North Anna plant.
G. Vepco's assertion that it cannot close North Anna when the pool is full because the cost of replacement power would be prohibitive is also unsupported by any data beyond a vague reference to " economic studies," and disingenuous for the reasons given in paragraph F above.
H. " Buy-Time Alternatives": Although Vepco appears to be committed to a dry-cask installation at Surry, and, as 26/ See pages 1-3, supra.
27/
discussed above,-- current projections indicate that such a facility could be available in 1986, Vepco has not considered any combination of alternatives to " buy time" for Surry until dry-cask would be on line and thus obviate the need to expand the North Anna pool, such as:
- 1. Give up full core discharge capability for a limited time, as have other utilities;
- 2. If Vepco's primary goal is to preserve full core reserve at Surry, install, temporarily, fuel racks in the cask handling area to be used only in the event full core discharge is required. Once the Surry dry-cask facility were operational, the racks could be removed. This option is addressed in a May 1982 Vepco memorandum, which reports that such a temporary installation would provide space for 108 fuel assemblies and extend the time to loss of full core discharge by at least two years; additionally, the memo reports that once before, when Surry's existing high density racks were 22/ See pages 11-12, supra.
being installed, one rack was installed tempo-rarily in the cask handling area;
- 3. Install aluminum racks at Surry, and provide space for approximately 100 more fuel assemblies without exceeding Surry's claimed weight limits, thus also extending the time until loss of full core dis-charge capability by at least two years. As suming for the moment that Vepco's 1984 date for loss of full core reserve is correct, aluminum racks would extend the Surry pool's capacity to 1986, and by then dry-cask would be operational , and
- 4. Operate Surry at a reduced capacity for a limited period of time.
l I. Long-term Alternatives: Vepco has failed adequately to consider alternatives that would permanently resolve its interim storage problems.
! " National environmental policy requires a detailed I
analysis of the long-range environmental costs of proposed action and a thorough study of the available 28/ Alternatives For Loss of Full Core Discharge, Surry Power SEation Unit Nos. 1 and 2 (Vepco Memorandum, May 5, 1982). For 2
the convenience of the Board, a copy of this memorandum is appended at Attachment B herein.
2_9/ See Attachment A.
alternatives before any action is taken. Planning and building . . . in a piecemeal fashion threatens to i
f rustrate this policy by allowing a gradual, day-to-day growth without providing an adequate opportunity to assess the overall, long-term environmental ef fects of that growth." Patterson v. Exon, 415 F. Supp. 1276, 1282 (D. Neb. 1976). Thus, proposed actions must be viewed comprehensively and, further, consideration of environmental factors must begin "at the earliest possible point." Sierra Club v. Bergland, 451 F. Supp.
- 120 (N.D.Miss. 1978).
l Even under the proposed scheme, Vepco will run out of storage space for both Surry and North Anna in 1993, and it is highly unlikely that any permanent federal repository developed under the recently enacted Nuclear Waste Policy Act of 1982 will be on line at that time. In fact, it appears that using the most opti-mistic assumptions, the repository could not be ready until the mid to late 1990's. Thus, it is clear l
even now that Vepco's plan to store Surry fuel at North i
Anna is only a sto 3ap measure postponing the inevi-table, and that, even if Vepco's current scheme is approved, Vepco must still develop additional interim storage capacity to bridge the gap between exhaustion 1
30/ Vepco agrees with this projected timetable. See Storage of Surry Fuel Summary at 21.
of the North Anna pool's capacity and the availability of a federal repository to receive spent fuel. Yet, Vepco attempts to focus only on near-term problems, ignoring or rejecting out of hand alternatives that would provide a comprehensive solution to its interim storage needs.
J. Comprehensive Alternatives: Vepco, by treating the discussed alternatives as mutually exclusive dois not consider the advantr.ges of a comprehensive, multi-faceted approach. For example, Vepco could solve both its near- and long-term interim storage needs and continue to operate both Surry and North Anna by:
- 1. Temrorarily installing fuel racks in Surry's cask handling area to bridge the loss-of-full-core-f reserve gap (asserted by Vepco to begin in the l
I fall of 1984) until drr-cask could be available at Surry in 1986, or l
- 2. Temporarily abandoning full core reserve, or l
I l 3. Tee.porarily reducing Surry's capacity, and l~
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- 4. Vigorously pursuing the dry-cask optien at 3urry which, by Vepco's own reckoning, could be on line I . ._ _ _ _ _ _ __
in 1986 and meet all of Surry's storage needs for its entire operating life.
Faced with a proposal such as the instant one, where it is clear that the currently presented solution leaves a gaping hole in the applicant's long-term spent fuel storage needs (i.e., the time between 1993 when the Surry and North Anna pools are completely filled and the late 1990's when the planned federal repository may be operational), and inadequately addresses the short-term picture, it is incumbent upon the Commission to evaluate Vepco's interim storage needs comprehen-sively. This obligation springs not only from NEPA but also from the Atomic Energy Act, which requires the Commission to take steps to minimize the health and safety risks associated with the commercial use of nuclear power. Thus, the Commission should, at this early point, attempt to develop an overall plan that minimizes fuel handling (and the attendant environ-mental and health and safety risks for workers and the public at large) over the entire lifospan of Vepco's nuclear plants.
North Anna 3 was once thought, at least by Vepco, to be the answer to its post-1993 storage needs.
Vepco, however, recently decided to cancel the North Anna 3 project, a decision whica clouds the longer-term storage picture. Louisa County urges the Commission to take steps now -- for example, by using its authority to impose conditions on the licenses it grants, Public Service Company v. U.S. NRC, 582 F.2d 77, 81, 85-86 (1st Cir.) cert. denied, 439 U.S. 1046 (1978), -- to require Vepco now to develop a comprehensive solution to its interim storage needs. The aim would be to develop an en'rironmentally-acceptable overall plan to (1) reduce the need for fuel handling and thus minimize the risks of accidents or sabotage and reduce occupa-tional exposure, and (2) ensure that NRC licensing and supervision of commercial nuclear plants is consistent and rational -- in particular, to ensure that a Commission licensing action does not effectively bail out one plant at the expense of another.
VI. Corrosion Vepce's application is insufficient to determine that ada-quate attention has been and will be given to the corrosive ef fect that exposure to the fuel storage pool water will have on 31/ Interim Storage at 10-11.
the capability of the neutron absorber material, Boraflex, to perform as required for the life of the facility. The applica-tion states that the " compartments containing the Boraflex are not watertight. The application states that Boraflex is fully compatible with the pool environment but cites no test data to verify this claim. There is concern that this material, contained in a " crevice-like" configuration, exposed to oxygen-saturated water may suffer degradation that would jeopardize its structural or nuclear properties. Similarly, the applicant has made no commitment to monitor the condition of this material, either by means of periodic inspections or a surveillance sample
- program. Accordingly, Vepco has failed to satisfy the requirements of 10 C.F.n. 50.36, 10 C.F.R. 50, Appendix A, general design criteria 1461 and 62 and 10 C.F.R. $ 50, Appendix B.
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32/ Increased Storage Capacity Summary at 53.
f Respectfully submitted, January 17, 1983 'h w
/J. Marshall Coleman Christopher H. Buckley, Jr.
Cynthia A. Lewis Robert Brager Virginia S. Albrecht Beveridge & Diamond, P.C.
1333 New Hampshire Avenue, N.W.
Washington, D.C. 20036 (202) 828-0200 Attorneys for Intervenor Of Counsel:
Richard W. Arnold Jr.
County Attorney Courthouse Square Main Street Louisa, Virginia 23093 (703) 967-1650 m
CERTIFICATE OF SERVICE COLKETEP UCNOC I hereby certify that I have this day served the foregoing Contentio.as of Intervenors County of Louisa, Virginia 81nd$kdk NI Board of Supervisors of the County of Louisa upon each:of the,.ei,w c
i#Ja;2.' Ting & SEPViC ,
persons named below by depositing a copy in the United StEFdEH mail, properly stamped and addressed to him at the address set out with his name:
Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing and Service Section Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear leagulatory Commission Washington, D.C. 20555 Dr. Jerry Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George h. Ferguson
' School of Engineering Howard University Wa i g on D C. 2b59 Daniel T. Swansor., Esq.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555
?
James B. Dougherty, Esq.
3045 Porter Street, N.W.
Washington, D.C. 20008 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 2
Michael W. Maupin
- Hunton & Williams i P.O. Box 1535 Richmond, VA 23212 9
January 17, 19G3
. Marshall Coleman i
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Mr. Ronald H. Leasburg Vice President-Nuclear Operations Virginia Electric & Power Company
?.0. Box 26666 Richmond, VA 23261
SUBJECT:
Spent Fuel Storage at Surry
Dear Mr. Leasburg:
I am sending this letter in resconse to our telechone !
conversation of last week. As I see it, VEPCO has'three reasonable alternatives for spen: fuel storage: increase pool storage capacity, tranship to North Anna, and on-site non-pool storage.
I realize that Stone and Webster will not allow any 1 increase in fuel pool loads. However, it may be possible to increase the storage capacity without increasing the leads. I do not know the details of the Surry fuel rack l g design, but if the present racks are stainless steel
,d without nuetr_on absorber, it would be possible to replace
{ them with b r - racks with neutron absorber and sub-g scantially'21 C ihe fuel rack weight. This change alone should allow storage of about ten percent more fuel in the existing pool. A side benefit of this approach is that the new racks could be designed for a higher fuel enrichment, which may be advantageous when considering extended fuel cycles. I assume that the fuel pool strue: ural analysis has taken advantage of the concrete aging strength increase, used bouyant weights of fuel and fuel racks , ninimized hydrodynamic mass effec:s and similar means of maximi ing strength and minimizing loads. However, there may still be some other means of increasing storage capability.
Although the increase in pool storage capacity is somewhat limited, it deserves all possible consideration because of its benefits; reduced licensing problems, less fuel handlin no new structures or transportatien recuirements and so on.g, 32169
Mr. Rennld Lsamburg Page 1 In relation to this approach, Mollerus Engineering could provide i a detailed evaluation of the potential storage capacity increase, 9 work with S & W to ensure that the pool structural capacity is {
not exceeded and provide a report including recommended approaches, '
licensing concerns, cost and schedule estimates and recommended -
suppliers. This work would require about five weeks, and ME would perform the work on a time and materials basis for approx-imately $8,000.00, including one trip to Virginia. t' Transhipment of Surry fuel to North Anna for storage would provide temporary relief of the Surry storage problem. However, licensing cf this alternative could be a long and difficult process. Some of the areas in which NE could be of assistance to VEPCo are:
evaluation of alternatives for the license request, determination
" of the availability of licensed equipment (particularily shipping casks), review of the North Anna fuel handling equipment for compatibility with Surry fuel, and review of North Anna storage racks for mechanical, structural and nuclear compatibility with Surry fuel.
m If you are interested in NE providing services relafed to any or all of the above areas, I will provide cost and schedule esti=ates based on whatever scope of work you desire.
As we discussed on the telephone, the most reasonable ap on-site non-pool storage appears to be storage in casks.proach Thereto are several companies interested in supplying these casks. To my knowledge the most advanced is Brooks & Perkins. B&P received I a contract from DOE in January 1982 to supply one of these casks.
1 The cask to'be delivered to DOE will be for BWR fuel, but B&P will submit a topical report to the NRC to covar both BWR and PWR fuel storage. The proj ected schedule for this is :
Submit topical report to NRC July 1982 Complete cask manufacture December 1982 NRC review complete January 1983 The cask will be delivered either to Barnwell or TVA for testing.
Mollerus Engineering can provide assistance to VEPCo in relation to this type of storage as follows: preparation of bid specifications, technical and quality assurance qualification of vendors, evaluation of bids, determination of requirements for the cask storage facility, independent review of cask and/or facility design and analysis, licensing assistance and project management.
l As with the transhipment alternative, I will prepare a cost and schedule esti= ate for a specific scope. gladly
- ~.
@I_N t -. . -. . - _ - . - -
, l Mr.' Ronald Leasburg Page . Both Fred Mollerus and I are experienced with design, analysis, fabricacion and licensing of spent fuel storage modifications. e Both Fred and I have testified at NRC hearings on spent fuel storage modifications.
As stated in our brochure on fuel storage which Bob Allen gave to you, ME is associated with Arne P. Olson Corporation for nuclear and shielding analysis . Dr. Olson has extensive experience in fuel storage modifications and has also testified as an expert witness on this subj ect at NRC hearings.
In the area of structural analysis, Mr. Glenn Brockmeier has over 35 years of experience, including spent fuel pool structual analysis. Mr. Brockmeier would provide the structural analysis input to these proj ects.
I certainly believe that ME can be of assistance to VEPCo on this work. I will call you in about one week to discuss this further.
Sincerely, -
Mollerus Engineering
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/James D. Gilerest -
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's lL' lbk MEMORANDUM , /
4.<;fCrn to M. L. Smith Richmond, Virginia mou M. L. Bowling, Jr. May 5, 1982
. /
ALTERNATIVES FOR LOSS OF FULL CORE DISCHARGE
/
SURRY POWER STATION UNIT N05. 1 AND 2 j
Loss of Full Core Discharge Capability is presently estimated to occur in the fourth quarter of 1984 at Surry Power Station Unit Nos. I and 2. To postpone this loss of full core discharge there are options wnich may be available.
The one major option which could be utilized on a strictly " temporary basis" would be to utilize up to 3 spent fuel racks which are presently in the spent fuel pool at North Anna. The spent fuel racks could be placed in the Surry spent fuel pool in the cask laydown area. This wouTd provide additional storage for 108 spent fuel assemolies and extend the time to loss of full core discharge at Surry by at leest 2 years. In order te do this, a temporary stand for the fuel racks would have to be installed for the racks to be piaced on as there is a step in the floor of the spent fuel cask laydown area. The stand would simply consist of 2 or 3 I-beams and some stainless steel plate. The weight associated with the stand, the fuel racks, and fuel assemolies could be accommodated as the total weight would be less than a 125 ton spent fuel shipping cask and it would be spread out over a greater surface area of the floor (see attachment 1, calculation of
- weights).
From a licensing standpoint, Vepco would have to request the NRC to provide emergency permission to do this, however, from a technical stand-point there should be no problem. This was actually done with one spent fuel rack during the installation of the Surry High Density Spent Fuel Racks.
From a seismic / structural standpoint there would be no problem as the
' North Anna fuel racks were designed to North Anna siesmic criteria which envelopes the Surry criteria. From a thermal-hydraulic and criticality stancpoint tnere would be no problem as the North Anna spent fuel racks were designed to accommodate either North Anna or Surry spent fuel.
In erder to temporarily relocate the 3 spent fuel racks from North Anna to Surry, should tne need arise, the racks would be removed from the pool and decontaminated (hydrolased). They would then be wrapped in plastic and possibly be crated and then be shipped by truck to Surry. Once at Surry they could then be placed in the cask laydown.
= .
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- To: M. L. Smith May 5, 1982
.A.
Other alternatives include storage in dry casks (NPE is currently
-~
reviewing this alternative as part of the dry cask ISFSI project) and storage in transportation casks.
Please advise Mr. H. S. McKay if you require any further information on this matter.
N Y' M. L. Bowling, Jr.
HSM:cbs cc: W. C. Spencer
_J. M Davis E _ Malljggog R. W. Calder L. H. Girvin C. P. Sanger G. H. Flowers H. S. McKay
- PSE&C Records Management NM-01, NP-51.2 e
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- - - - - - . . - . . . - - . - - , - , - - - - - - ---......-w . - - . - - , -- - - -
~~~
ATTACHMENT X
,d 108 assemblies x 1700 = 186,300 lbs. or a.92 tons Weight of Fuel Racks = 15,000 lbs. each or 45,000 lbs. for 3 racks 22.5 tons Stand - < l5,000 lbs Total Weight to Pool 122 tons
< 125 ton shipping cask l
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MEMORANDUM l Mr. M. L. Smith M h..
gs to Richmond, Virginia race M. L. Bowling, Jr. ,
October 6, 1982
, . u .. , . .
CURRENT ~ COST ESTIMATES ~#
L. .'
I '
INDEP' INDENT SPENT FUEL STORAGE INSTALLATION SURRY POWER STATION-UNIT 5 1 AND 2 l Attached for ycur infonnation are best-estimate lifetime total co.it estimates for the Dry !ask and Wet Pool Storage facilities being considered for interim storage of the Surry spent fuel. The estimates provide projec-ted cash flows associated with each storage option ,as well as assumptions forming the basis of the estimates. ~
- : . '$0 The attached information is the same as that which was reviewed with ~.
l .
you in the August. 23, 1982, meeting as preliminary. TheS purpose oPthe -iirc.-
- l formation is to provide a' basis for estimates of total lifetime costs.
Accordingly, the estimated cash flows for each year may be subject to ad-justment without significantly affecting total estimated costs, as the - ,
actual timing or scope of specif.ic project activities changes from the estimate. .
I ~
Tables 1.2 and 2.2 summarize the estimated costs of the Dry Cask .
and Wet Pool facilities respectively. The estimated c.ost of the Dry Cask facility in 1982 unescalated dollars is between 58 and 75 million. The estimated cost of the Wet Pool facility in 1982 unescalated dollars is l between 70'and 98 million. These estimates are generally cons.istent with l our earlier estimates and those provided in Mr. R. H. Leasburg's memorandum of March 24, 1982 (60-90 million dollars for Dry Cask and 100-125 million dollars. for Wet Pool). The diffeience reflects our contracting exoerience, vendor discussions, and more detailed scope definition.. ,
We intend to update the estimate after approval of the 1983 budget. - '-
M.
7~ At that time, we will know authorized funding f.or 1.983.and can plan near-term ;
project activities accordingly. Please note that the attachment assumes '
commencement of Wet Pool final engineering in 1983. Your current authoriza ~ ,
tion to PSE&C, and our 1983 budget request, do not provide for final eng.ineer . .
ing. Other known changes, which will be included in the update, pertain t
(1,) to the timing and amounts of license fees and (2) to engineering services. '
to be provided by cask vendors. Neither of these items will have a signia .
ficant effect on the estimated lifetime costs.
. De S th 8 8.
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- O 166758 g .
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4 Mr. M. L. Smith October 6, 1982 Page Two We will advise you promptly of any significant deviations from these estimates.
- If you should have any questions concerning these estimates, please l feel free to contact me.
hW d kW '
M. L. Bowling, Jr.
GHF/JRA/nh Attachment cc: Mr. S. C. Brown, Jr., w/ attachment Mr. W. C. Spencer , w/ attachment Mr. A. L. Parrish, III , w/ attachment Mr.. J. M. Davis , w/ attachment Mr. G. H. Flowers w/ attachment Mr. J. R. Adams w/ attachment PSELC Records Management NP-50 w/ attachment
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166759
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'I 4
ATTACHMENT 1 j
SUMMARY
OF COSTS DRY CASK INDEPENDENT SPENT FUEL STORAGE INSTALLATION SURRY POWER STATION I
L l4 l
i PSE&CS AUGUST, 1982 4
166760
'-_- brh/2942/1 . - . - - - . _ - _
4 TABLE 1.1 SlMMARY OF A55UlfTIONS FOR COST ESTIMATE DRY CASK INDEPENDENT SPENT FUEL STORAGE INSTALLATION SURRY POWER STATION - UNIT 5 1 AND 2 Tetal storage capacity provided - up to 2000 assemblies 1.
- 2. All costs projected in 1982 dollars without escalation
- 3. Project Start Date - April,1982
- 4. Projected Startup Date - 1986
- 5. Facility Life - through 2008
- 6. Other assumptions are included with the individual tables e
166761 i 08/82 brh/2942/2 I i
j
TABLE 1.2 COST
SUMMARY
DRY CASK STORAGE FACILITY 1982 5 X 1000 t
License Application Preparation $ 328 Design Engineering (A/E) 265 Licensing Support (A/E) 429 Vepco Costs Excluding Construction 1645 Construction ,
2350 Storage Cask Purchases 51000 - 68000 l
.I Operation & Maintenance 1454 Decomissioning 153 TOTAL LIFE OF FACILITY COSTS 57624 (Less Contin p ty)
Contingency l Contingency at 15% for Licensing 882 support, Yepco Engineering, j Construction, O&M TOTAL RANGE $58506 - 75506 Notes:
- 1. Life of facility is through the year 2008.
- 2. If consolidated fuel is stored in the casks the total costs would be at least 25% lower than those shown above.
166762 08/82 En/2942/3
TABLE 1.3 CASH FLOW (000)
DRY CASK LICENSE APPLICATION PREPARATION BECHTEL POWER CORPORATION 1982 April $ 12 May 32 June 72 July 100 J
August 75 September 37 TOTAL $328 The above costs are for the preparation of all documents to be submitted for the application for dry cask storage. Expenditures through June are actual amounts. Expenditures for July through September are estimates based on inputs from Bechtel. '
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166763 08/82
%*CnI40)))]
TABLE 1.4 CASH FLOW (000)
DRY CASK FACILITY ENGINEERING BECHTEL 1982 April $ 23 May 50 June 66 July . 50 August 30 September 25 1983 21 TOTAL $265 The above costs are based on a fim price contract with Bechtel (Task Item f4) for all work required for the "No Building Option".
1 166764 08/82
~
- TABLE 1.5 CASH FLOW (000)
DRY CRIE LICEN5ING 5UPPORT BECHTEL 1982 $ 33 1983 132 1984 132 i
1985 132 .
. TOTAL $429 The above costs are based on Bechtel providing licensing support throughout the licensing process depicted on the project schedule.
Licensing process is assumed to be in accordance with the P. L. Grey Report. Bechtei assistance is estimated to be 200 MH/ month for l 1983-1985.
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e 166765 08/82 I ~
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TABLE 1.6 CASH FLOW (000)
YEPCO EXCLUDING CONSTRUCTION COSTS PSE&C OTHER (Veoco) LEGAL TOTAL DB2 $ 141 $370* $ 50 $ 561 1983 144 72 50 266 1984 144 72 50 266 1985 144 72 50 266 i 1986 72 .36 50 158 1993 36 18 10 64 2001 36 18 10 64 TOTAL $ 717, $658 $270 $1645 1
The above costs are estimated based on mcderate Vepco involvement in predominately Mode II operation. 1982 costs are 605 of the current ISFSI estimate which also includes engineering for the Wet Pool option, based on
[ pursuing dry storage as the prime alternative. Costs for 1983 through 1986 assume only dry storage will be pursued. The costs are based on PSE&C expenditures of $12 k/mo ($6k NPE, $3k ES, $3k Overhead), other Vepco department expenditures of $6k/mo (1/2 of PSE&C) and $50k/yr paid to Hunton & Williams for legal support during licensing and construction.
Costs for 1993 and 2001 are for engineering support of modular expansions.
i I
- 1982 costs include $300,000 for license application fee.
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TABLE 1.7 CASH FLOW (000)
FACILITY CONSTRUCTION COSTS il 1985 $ 425 1986 425 1993 ,
750 2001 750 l
TOTAL $2350 l
The above costs are based on constructing storage slabs as required. 1 Initial construction (1985 & 1986) will consist of clearing the '
l entire site, installing any security systems and constructing the ;
first storage facility. Initial construction is scheduled '
(optimistically) to beg 1n before the license is issued. Costs are ;
based on estimate cade by Bechtel dated March 2, 1982. 1985 costs l
include purchase of cask transport equipment.
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08/82 106767
_ _ _ br.h/29_42/8_. _ _ _ _ _ _ _ _ _ ,.
TABLE 1.8 ORY STORAGE CA5K PURCHASES Number of Casks Cost /$600k/ea Cost / Cash Flow (000)/$800k/ea 1985 4 $ 2400 $ 3200 86 3 1800 2400 87 5 3000 4000 88 2 1200 1600 89 3 1800 2400 1990 5 3000 4000 91 2 1200 1600 92 3 1800 2400 93 5 3000 4000 94 2 1200 1600 1995 3 1800 2400 96 5 3000 4000 97 2 1200 1600 98 3 1200 2400 99 5 3000 4000 2000 2 1200 1600 01 3 1800 2400 02 5 3000 4000 03 2 1200 1600 04 3 1800 2400 2005 5 3000 4000 06 2 1200 1600 07 5 3000 4000 08 6_ 3600 4800 TOTAL 85 $51000 $68000 The above costs are for 24-element storage casks. The current cost estimates for casks range from $600k to $800k each. The required quantities are based on the fuel buildup schedule (attached). Casks purchased on 1985 and 1986 would be used for early -
storage of spent fuel prior to construction of the facility, subject to NRC approval, and are considered initial capital costs.
08/82 brh/2942/9 - _- . _- .
TABLE 1.9 CASH FLOW (000)
DRY CASK FACILITY OPERATING & MAINTENANCE COSTS 1986 $ 57 87 64
,; 88 57
- i 89 60 1990 64 ll: 91 57 (i 92 60 L 93 64
! 94 57 t
1995 60 96 64 97 57
. 98 60 99 64 2000 57 01 60 02 64 03 57 .
04 60 2005 64 06 57 07 60 08 64 i
~
09 66 L
l TOTAL $1454 These operating and maintenance costs are based on the Bechtel preifminary engineering study dated March 1982. The costs include rental of cask unloading crane and routine maintenance of monitoring and lighting systems.
4 l
s 08/82 100700
. _ brh/2942/10_ __ __ _ ___ ____ _. ___ ___ . _ _ _ _ _ _ _ .
i TABLE 1.10 CASH FLOW (000)
DRY CASK FACILITY DECOMMISSIONING 2008 $ 51 2009 51 2010 51 TOTAL $153 The above costs include dismantling the monitoring and electrical systems and checking the slab and surrounding area for contamination.
Costs do not include disposal of fuel assemblies and casks.
I 08/82 beh/29_43/11_ __ _._____ _ . _ . _ _ _ _ _ __
i I
ATTACHMENT 2
SUMMARY
OF COSTS WET POG. INDEPENDENT SPENT Fou. .,TORAGE INSTALLATION SURRY POWER STATION i
l PSE&CS AUGUST, 1982
=
166771
s TABLE 2.1 SIMMARY OF A55UMPTIONS FOR COST ESTIMATE WET POOL INDEPENDENT SPENT FUEL diuRAGE INSTALLAT70N SURRY POWER STATION - UNIT 5 1 AND 2
- 1. Total storage capacity provided - 2100 assemblies
- 2. All costs projected in 1982 dollars without escalation
- 3. Project Start Date - April, 1982
- 4. Projected Startup Date - 1988
- 5. Facility Lif.2 - through 2008
- 6. Otherassudptionsareincludedwiththeindividualtables e
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08/82 100II2 brh/2942/13
i
. TABLE 2.2
SUMMMARY OF COSTS WET POOL INDEPENDENT SPENT FUEL STORAGE INSTALLATION a
SURRY POWER STATION - UNIT 5 1 AND Z 1982 5 X 1000 I
License Application and
, Conceptual Engineering $ 465 P Final Engineering 934 j Construction Costs 27000 - 54000 l
Vepco Costs Excluding Constructio'n 3075 Modular Expansion Costs 3388 o
Operating and Maintenance Costs 16262 Decommissioning 11250 TOTAL LIFE OF FACILITY COSTS 63134 (Less Contingency)
) Contingency l,
Based on 15% of Final Engineering 7713
[. Field Engineering, Vepco EngineeM ng, j Construction Modular Expansion Costs and 0 & M Costs I
l TOTAL RANGE $70847 - 97847 lt Note:
[
Life of facility is through the year 2008.
e I
I s
(
08/82 Ph/204UT4
TABLE 2.9 CASH FLOW (000)
WET POOL OPERATING A!JD 1%Il4TENANCE COSTS 1988 $ 680
, 89 . 742 1
1990 742 91 742 92 742 -
93 742 These operating and maintenance o
costs are based on Table B of the Stone 94 742 & Webster cost estimate dated f4 arch 1982. Costs for 1988 are for 11 months 1995 742 of operation per schedule.
96 742 97 742 98 742 99 742 2000 742
?1 742
[ 02 742
- 03 . 742 l
- l 04 742 l 2005 742 06 742 l-07 742 08 742 l 09 742 i
s TOTAL $16262 l
08/82 i p1 166780
. u 7
TABLE 2.10 CASH FLOW (000)
DECOMMISSIONING COSTS 2009 $ 3750 2010 3750 2011 3750 TOTAL $11250 Decomissioning costs are estimated to be approximately 40% of the total construction costs including modular expansions.
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8 08/82 166781 i brh/2942/22
TABLE 2.9
_ CASH FLOW (000)
WET POOL OPERATING AND MAINTENANCE COSTS 1988 $ 680 89 742 l i
~
l 1990 742 1
! 91 742 !
i, 92 742 -
l 93 742 These operating and maintenance t
costs are based on Table B of the Stone 94 742 & Webster cost estimate dated March 1982. Costs for 1988 are for 11 months 1995 742 of operation per schedule.
96 742 t
97 742 98 742
! 99 742 2000 742 L 01 742 02 742 i
j ,
03 742 i
l 04 742 i
L 2005 742
't 06 742 07 742 08 742 e
09 742 9 TOTAL S16262 08/82 l - 166780
(- .
TABLE 2.10 '
CASH FLOW (000)
DECOMMI55]ONING COSTS 2009 $ 3750 2010 3750 2011 3750 TOTAL $11250 Decommissioning costs are estimated to be approximately 40% of the total construction costs including modular expansions.
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08/s2 166781 brh/2942/22 , _ _ - . - _-
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