ML20062F764

Intervenors Responses to Licensees' First Set of Interrogs a Thermo-Inversion Around the Plant Sites May Cause a Higher Level of Radiat to Be present.Thermo-Inversion Prevents Emissions Escaping to Higher Atmosphere.Cert of Svc Encl

ML20062F764
Person / Time
Site:	Kewaunee
Issue date:	11/28/1978
From:	Cordaro W External Citizen/Individual/Media (Affiliation Not Assigned)
To:
References
NUDOCS 7812210006
Download: ML20062F764 (7)

Text

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NDzjg Noven'oer 28, 1978

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& g f(* g f UNITED STATES OF AM3RICA NUCLEAR REGULATORY CO G4ISSION l%g40 0fg 9]

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1. M EFORE THE ATOMIC SAFETY AND LICEI! SING BOARD

/ tq tter of Wisconsin Public 9/ , , 4x Corporation. Docket Ho. 50-305

_c se Ho. DPR-43 INT 2RVENORS RESPONSES TO LICENSEES' FIRST SET OF INTERROGATORIES Interrogatory 1 .)

Contentions 2, 8, 13a, 13b, 13c and 13f: We have not en-gaged any witnesses for these contentions and do not anti-cipate presenting expert testimony in this proceeding for financial reasonc. We have asked the State of Wisconsin to investigate the availability of witnesses. ,

Interrogatory 2 See response to Interrogatory 1.

Interrogatory 3 Contentions 13 a and f: A. 3. Johnson, 3ehavior of Scent Nuclear Fuel in Water Pool Storage, Battelle Northwest Laboratory 2256, September 1977.

Contention 13 b: NRC Draft Generic Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel, HUREG 0404, Volume 2, March 1978, 1

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1 A!EllERS TU INTERROGATORIES SUB'JITTt:D BY THE APPLICA!.T IN REGARD TO THE KENAUNEE NUCLEAR PUWER PLANT.

II.TERRUGATORY #4 Unable to determine.

11Tr1RROGATORY #5 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 I, from escaping higher into tha atmosphere. Also, refer to " Radiological b Environmental Monitoring--bemi-Annual Monitoring Report," Foint Beach Nuclear Power Plant, sec. 5, Fage 8, July--December,1977. g-lP l-1 HAVE ST/CED THE ABOVE TO BE ORUE TO THE B!bT OF MY KNowlE1DE.

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Interrogatory 6 -

4 No, we do not contend that the neutron absorber material proposed for use in the Kewaunee Spent Fuel Pool are similar to those used at the Connecticut Yankee facility.

i i However, to our knowledge,you have not specifically stated nn .

what you propose to us,#.< You have indicated that you'

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are considering or investigating the use of the'Eleck~

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torschmelzwerk Kempten GMBH plates and we're presently awaiting your evaluation of these plates as well as the studies which support their reliability.

Interrogatory 7 .

'I cannot. address specific problems related or associated with the neutron absorber plates proposed for use in t

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the Eewaunee Spent Fuel pool as I am avalting your docu-

mentation.

l j Interrogatory 8 1

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Monitoring of neutron absorber plates appears to be both desirable and necessary.

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! i Interro5atory 9 e Monitoring is necessary because of problems previously 1

incurred with the use of the neutron absorber plates.

such as bulging and cuelling and off-gasing and gamma i

radiation damage.

.I cannct adar ons monitoring until you inform ne what you propose to use and how it will be employed in the spent fuel pool. i ,

I, Sandra Bast, swear that I have responded to portions of Interrogatories 1 and 2 and Interrogatorias 6, 7, 3, 9. to the I'.. ./. k./x .

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Interrogatory 10 Contention 12 -- To the best of our knowledge, the present racks, filters, cartridges and resins are the low-level radioactive wastes that will be pro'duced and have to be carefully stored or disposed of by Licensee as a result of the spent fuel pool modification. We would appreciate knowing if there are any other low level radioactive wastes resulting from the spent fuel pool modification as proposed.

Interrogatories 11, 12 and 13 Contention 12: Ve do not know whether or not there will be an increase in the level of radioactive wastes--other s than the present racks which will have to be removed and disposed of--due to the proposed modification of the spent fuel pool. We vould appreciate a delineation of low level wastes anticipated and where they will be stored.

Interrogatories 14 and 15 Contention 13 a: We do not know whether or not borated water will have corrosive effects on materials of and in the spent fuel pool, We have asked you, the licensees, to provide this data which we believe you should have before going ahead with the nodifications as proposed.

Interrogatory 16 ~

Contention 13 a: Detailed analyses of the long-tera effects of borated water on the spent fuel, cladding and other components of and in the spent fuel pool (at least for the l period of license) should be provided in this proceeding.

Interrogatory 17

! Contention 13 b: We do not know whrt corrosive effects are likely to occur in the spent fuel pool during the period

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(5) of licenso and have asked you to provide this data.

As indicated in our contention, the NRC has asserted that these corrosion effects require examination'and we are simply asking Licensee to study this matter thoroughly and report findings in this proceeding.

Interrogatory 18 Contention 13 c: We do not know whether or not the materials in the spent fuel pool will be subject to electrolytic cor-rosion and have asked ~ Licensee to provide this data.

Interrogatory 19 Contention 13 c: We do not know what alloys yo:_ use and have asked you to delineate them via_your response to our Certainly you should have this information.

interrogatory.

Interrogatory 20 Contention'13 f: We do not know what corrosive effects will result from any buildup of crud and have asked you to provide this data during this proceeding.

Interrogatory 21 Contention 13 f: We.have asked vou to provide this data l which you certainly would want to have in the event your i

modification proposal is granted!

Interrogatory 22 Contention 13 f: To the best of our knowledge, there is no detailed analysis specifying the mechanists which will result in the formation of. aeration cells, but you certainly

would want to obtain such an analysis.

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f 3, Jane Schaefer, hereby sweat that 3 responded ta po.ttions of 2nter.tagalories # 1 and 3 and aLL of OntestagaAories 10 .tkroagh 22 prapaunded by [icensee to .the beat of my knowledge and .in good faLth.

Dated this 20th Da; af novenbe.,t, 1978

'/ (kk' ts. Send Sch$efer

!)3741 Xoehle.t Drive Shehoggan, U2 53081 I

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UflITED STATES OF AlL:RICA HUCLEAR REGULATORY COMMISSI0ff BEFORE THE ATOMIC SAFETY AND LICENSIfiG BOARD In the Matter of

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WISCONSIN PUBLIC SERVICE CORPORATI0ft WISC0NSIll POWER AND LIGHT COMPANY , Docket tio. 50-305 AND /mendment to License MADISON GAS AND ELECTRIC COMPANY No DPR-43 -

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

CERTIFICATE OF SERVICE d

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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 fir. Glenn 0. Bright Steven E. Keane, Esq.

Atomic Safety and Licensing Board Panel Foley & Lardner U.S. Nuclear Regulatory Corrmission 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 Conmission Appeal Board Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 i2 1t Street / ~ c^- Y!$bM.I:Ng U' '

Manitowoc Wisconsiji 54220 Bermcl Boa @

U.S. Nuclear Regulatory Commission Mrs. Wend Schaefer Washington, D. C. 20555 3741 Koehler Dr.

Sheboygan, Wisconsin 53081 William J. Olmstad Counsel for URC Staff Ms. Mary Lou Jacobi U. S. Huclear Rcculttory Con.

Lakeshore Citizens for Safe Energy Vashington, D. C. 20555 932 N. 5th Street Manitowoc, Wisconsin 54220 V **