ML20062F419

Response by Intervenors Bast & W Schaefer to NRC Staff'S First Set of Interrogs.Cert of Svc Encl

ML20062F419
Person / Time
Site:	Kewaunee
Issue date:	11/28/1978
From:	Bast S, Schaefer W AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7812180267
Download: ML20062F419 (9)

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EUCL2AR R2GULATORY CCEIISSION 3E7CR2 THE A20MIC SAF_;TY .-tND LICE!.' SING 3 CARD

' In the matter of Wisconsin Public -

Service Corporation. Docket No. 50-300 License No. DPR-43 INTERYENORS RESPONSES TO NRC's S?A??S FIRST SET OF INTERROGATORIES November 28, 1978

~fnterrogatories of General Applicability

1. Contentions 2, 8, 13 a, b, c, and f: We are unable at this time to identify any witnesses we can present to provide data on the ability of spent fuel and components of and in the spent pool to maintain their integrity during the period of license.

We have not been able to locate witnesses on this issue and are' financially unable to sponsor testimony.. We have asked the State of Wisconsin to investigate the availability of witnbases who could be funded by our State. However, we believe that the Licensees must bear the burden of proof that spent fuel cladding and components of and in the spent fuel storage pool will remain intact and not pose any hazard for the people and their environment during the period of license and beyond.

(We understand, hcwever, that the NRC hearing board will not permit us to discuss the maintenance of spent fuel pool com-ponents beyond the pericd of license -- a catter which greatly disturbs and concerns us.

7812180267

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2. For our views and positions on these contentions, please re or to them as worded in our August 16, 1975 Amended Con-tentions and in the October 11, 1978 0rder of the Atomic Safety and Licensing Socrd.

3. None at this time.

4. We have already noted deficiencies in the Licensee's Snent Puel Pool Modification Descrintion and Safety Analysis and Environmental Imnact Statement as indicated in our Petition to Intervene and Arended Contentions. We have nothing further to add at this time.

5. Contention 13 a: In pursuing these contentions, we will refer to A. B. Johnson's 3ehavior of Suent Nuclear Fuel in Vater Pool Storage, Battelle Northwest Laboratory 2256, September 1977.

We have requested true copies of this report but have not as yet received them.

If t'.e URC Staff has a copy of this report, please so inform us; otherwise, we will forward a copy.

Contention 13 f: We will use the Draft Generic IIS on Handling and Storage of Spent Light Water Power Reactor Fuel, NURIG 0404, Volumes 1 & 2, F. arch, 1973.

6. None at this time.

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A&;wi33 TO ILTERROGATCRIES SU3.d1TTED BY THE NUCLEAR REOUI.ATORY COWISSION STAFF IN REFERENCE TO THE Km,v/AUNEZ NUCLEAR ruler FIld.T FRCCEEDIES COIEE:CION 12 A. " Allowable Levels" refer to any amount that adds to the already existing natural background radiation levels that can be harmful to the Public and environment.

B. As our contention states, we do not contend that atnospheric conditions may or may not cause emissiens to exceed allowable levels. We feel that the topic was not addressed in the application and no credible reason for not addressing the issue has been provided as.'of yet. I cannot say if an atmospheric condition may or may not cause emissions to exceed allowable levels.

C. We feel that a Thermo-inversion around the Plant sites may cause a higher level of radiation to be present. A Thermo-inversion prevents the emissions from escaping higher into the atmosphere. Also, refer to " Radiological Environmental Monitoring--semi-Annual Monitoring Report" Point Beach Nuclear Power Plant, Sec. 5 Page e, Aly--December,1977.

D. Applicant conte"ds that there will be insignificant release of radioactive materials according to present standards and monitoring equipment'..

However, there will be emissions in any case. A separate monitoring sys-tem should be set up to determine emissions from spent fuel to give more accuracy to applicant's reports. No rzarantee is given that insignificant levels today are going to be insignifIqant tomarrow.

E.. Refer to Kewaunee Application.

1 hah STATED THE ABori. TU BE TRUS To THE BEbT uF MY KNC"! LEDGE'.

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1. ILLIAM M. CORDARO l

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2. Contention 8

a. The general problems ascociated with defective or de-tericrating neutron absorber plates which are referenced in Contention (based on information that the Applicant at that time intended to use plates similar to those in use at the Connecticut Yankee plant) are bulging, swelling, off-gasing and samma radiation damage.

It is our understanding that Kewaunnee intends to use the Elecktroschnelsverk Kempten GM3H plates on which we have received no data.

b. See a.

c. I assume it is always desirable to monitor for a loss of neutron absorber material, but I am unable to evaluate until I receive information from the Applicant on the type of plate,1f any, to be employed at the Kewaunee facility.

d. I am unable to answer because I don't have the information.

However, there must be some type of visual inspection of l

the plates as artminimum precaution. I base the need for l

monitoring on the proble=sincurred at the Connecticut l

Yankee facility. It seems that unless the re2iability of the proposed plates to be employed at Kewaunnee can be guaranteed to be ICCE. safe and problem free, inspections and monitoring must occur.

e. I did not receive the letters from E. W. James, Senior Vice-President of Wisconsin Zublic Service Corpcration t

to Victor Stello of the NRC, dated July 10, 1978 and September 5, 1975. Please forward a copy.

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3. Contention 12

a. & b. As we have already stated orally and in writing, we have asked Licensee to identify the forms and quantities of low level radioactive wastes which will result from the increased storage and compaction of spent nuclear fuel at Kewaunee.

- Please refer to the Licensee's response when received by the HRC staff.

We anticipate that among the low level radioactive wastes Licensee will generate are the present racks, filters, and cartridges. We consider any amount of low level radioactive wastes to be significant because until disposed of in a safe manner, the radioactivity contained therein poses a threat to people's health.

4. Contention 13 a

a. We do not know of any other components in contact with the spent fuel storage pool borated water otner than those listed in this contention. However, if the NRC Staff and/or Licensee can delineate any other spent fuel pool components, we would appreciate this information.

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b. c We do not have any spe'ific information regarding corrosion effects cm the components listed in this contention and have asked Licensee to analyse these potential corrosion effects which may affect the integrity of the spent fuel, cladding and storage pool components.

c. We do not know whether or not Kewaunee will experience the problems with spent fuel storage racks swelling as those at the Connecticut Yankee plant. We hope that Licensee and the NRC staff will provide an anlysis to ascertain the possibilities

of swelling in light of the fact that Licensee proposes to use

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b the same type of racks presently in use at the Connecticut Yankee facility.

d. As indicated in our contention, the Johnson report states that these materials appear to have functioned satisfactorily in underwater pool storage over short periods of time, but that there have been very few detailed analyses of the materials in boric acid pools over long periods of time (refer to page 36 of the Johnson report as noted in our contention). We do not know whether or not the zirconium clad fuel elements stored in boric acid in the Kewaunee pools will retain their integrity for the period of license, and Licensee and/or NRC Staff should provide this information,

e. We do not believe the Johnson report offers direct support for the belief that there will be significant deterioration in the spent fuel pool and components thereof. However, Johnson states that there are few detailed analyses of these materials (refer to page 36) and identifies factors which require further definition to assure the safety of long-term underwater storage os spent fuel (page 76).

5. Contention 13 b

! a. (1) through (4) -- The NRC in NURIG 0404, Draft Generic 2nvironmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel, March 1978, states that thes.c corrosion effects referred to in this contention might occur and should be examined in greater detail. We are asking that these analyses are made and provided in this proceeding to assure that corrosion will not be a problem at the Kewaunee pool during the period of license.

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6. Contention 13 e

a. The " pipes" we refer to in this contention are those connected with the spent fuel storage pool.

Ve are unable to specifically identify the pipes which do not appear to be de-lineated,in the Kewaunee scent Fuel 2001 Modification Desien and Safety Analvsis and the Environmental Intact Statement.

b. We do not knew the level of electrolytic corrosion expected with the present spent fuel pool configuration. Ve have asked this question of the Licensee and hope that Licensee and/or NRC Staff can provide this information.

7. Contention 13 f

a. We do not know what thickness of crud laye,rs are anticipated.

We hope that Licensee and/or NRC Staff can provide this data and analyze crud formation impact on corrosion of spent fuel in light of the Kewaunee spent full pool modification proposal.

b. We do not know whether crud will influence the corrosion of spent fuel and its cladding. As already indicated in our contention, Johnson states that study of crud may determine the corrosion environment in the spent fuel pool (refer to page 65). Certainly the NRC Staff and the Licensee will want

! to study this matter!

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c. We have asked Licensee to provide an analysis of the tendency of crud to influence corrosion of spent fuel and cladding due to the increased and core densely stored spent fuel as proposed for the Kewaunee facility.

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• 3, >e Schae)e t, he<tehy. oweast that 2 have auweted ca.ttioM of 2ntestaga-to,ttes of Qcne.taL App.LLcchiLLt.y. # 1, 2, 4, cad 5 and aLL of 2nte,t. toga.to.tisa Relating to Rdaltted Contentiou # 3, 4, 5, 6, cad 7 which wete ptopounded by. the Ruclecn. Regulato.ty Cowsisun Staff by docanented dated Ravenbe,t 9, 1978 and acceived by as on Ravenbe<t 16, 1978 by ikited States aall. Ru wers to the iM et toga,to.ti.es we<te p,tepa<ted to the best of ay. knowledge and in good faith.

Dated d.is 20th Day. of Ravenben., 1978 hbfMb l Qts. Gend. Schas'se,t.

VJ741 XoehLot Dtive Sheboyr,ca, 23 53081 I, Sandra Bast, sweir that I have answered portions of Interrogatories of General Applicability # 1, 3, 6. and all of Interrogatories relating to Contention 88 to the best of ray knowledge.

v/M/ 4A)Bast ' ' '

//.W Y Sandra A.

1112 N. 12th St.

Manitowoc, WI 54220 l

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U!!ITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI0tl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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WISCONSIN PUBLIC SERVICE CORPORATION j WISCONSIN POWER AND LIGHT COMPANY, Docket No. 50-305 AND /mendment to License MADISON GAS AND ELECTRIC COMPANY No DPR-43 -

) (IncreaseSpentFuel (Kewaunee Nuclear Power Plant) ) Storage Capacity) ,

CERTIFICATE OF SERVICE o

d Robert M. Lazo, Esq. Patrick Walsh, Esq. ,

Atomic Safety and Licensing Board Department of Justice U.S. Nuclear Regulatory Commission 114 East, State Capitol Washington, D. C. 20555 Madison, Wisconsin 53702 Mr. Glenn 0. Bright Steven E. Keane, Esq.

Atomic Safety and Licensing Board Panel Foley & Lardner U.S. Nuclear Regulatory Comission First Wisconsin Center Washington, D. C. 20555 777 East Wisconsin Avenue Milwaukee, Wisconsin 53202 Dr. Oscar H. Paris, Member Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Comission Appeal Board Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Ms. Sandra A. Bast ^aoea.j,.,,, ,

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1112 N. lith Street c m-- -

c e ~ ~..... uig Manitowoc, Wisconsiji 54220 B C '..el 8ca nD U.S. Nuclear Regulatory Ccmission Mrs. Wend Schaefer Washington, D. C. 20555 t 3741 Koehler Dr.

Sheboygan, Wisconsin 53081 William J. 01astad Counsel for :!RC Staff Ms. Mary Lou Jacobi U. S. :iuoleer Ecgull cry Cen.

Lakeshore Citizens for Safe Energy Washington, D. C. 20:55 932 N. 5th Street Manitowoc, Wisconsin 54220 WW