ML20073B485

Forwards Util to DOE Commenting on Draft DOE Contract for Disposal of High Level Radwaste & Spent Nuclear Fuel,Per Amends 45 & 28 to Licenses NPF-4 & NPF-7.Agreement Completion Expected by 830601

ML20073B485
Person / Time
Site:	North Anna
Issue date:	04/08/1983
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Eisenhut D Office of Nuclear Reactor Regulation
References
212, NUDOCS 8304120433
Download: ML20073B485 (6)

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VIRGINIA ELECTRIC AND Powna COMPANY RIciImoNo, VIRGINIA 202 61 W.L.Srawur Vies PEssipuur Nucz. EAR oPERATzON.

Apri1 8,

1983 Mr. Harold R. Denton, Director Serial No. 212 Office of Nuclear Reactor Regulation N0/JHL:acm Attn:

Mr. Darrell G. Eisenhut, Director Docket Nos. 50-338 Division of Licensing 50-339 U. S. Nuclear Regulatory Commission License Nos. NPF-4 Washington, D. C. 20555 NPF-7 Gentlemen:

In Amendment Nos. 45 and 28 to the North Anna 1 and 2 Operating Licenses, dated January 27, 1983, you specified that Vepco should be pursuing with the Secretary of Energy an agreement for the disposal of high-level radioactive waste and spent nuclear fuel.

In accordance with the requirements of P.

L.97-425, Vepco is currently pursuing such an agreement, and in fact is working with the Department of Energy to finalize this agreement.

We have attached our correspondence to date with the Department of Energy on this subject. We are working diligently to complete this agreement by June 1,

1983, but no later than June 30, 1983, as is required by P. L.97-425.

Very truly yoursj j

W W. L. Stewart Attachments cc:

Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing

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8304120433 830408 PDR ADOCK 05000338 P

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I March 7, 1983 e

t Mr. Robert Morgan j

Froject Director l

Nuclear Vaste Policy Act Project Cffice J

U. S. Department of Energy 1

j 1000 Independence Avenue. 5.W.

1 Room 7B-084 I

Washington, D.C.

20585 i

Dear Mr. Morgan:

CONMENTS OR TBE__ DRAFT DCE C05 TRACT FOR DISPOSAL OF SPENT WUCLEAR FUEL ANDf0_R BICE-LETEL_R_ADI_OACTITR_, WASTE i

I In accordar.ee with the Federal Register notice of February 4, j

1983. Virginia Electric and Power Company (Yepen) is pleased to offer the

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fellovian ecuments en the draft Department of Energy (DOE) Cortract For Disposal cf Spent Neelear Fuel ar.d/or Righ-level tedioactive Waata.

Vepco endorses the cemments also being esbeitted on Marc'n7 19f:3 l

by the Edfson Electric Institute (EEI). In perticular, Vepco strongly i

concurs with the following EEI comments:

1. The scope of pervices to be previded by D~t r.eeds to be more s

j clearly defined to include delivery, acceptance et citJa.

transportation and disposal of spent BBClear fuel dLd/CT' high level radioactive waste. (Articles 11 and 7.B.1) i i

2. The specific classifications for spent nuclear fuel should not be established at this time since the types and condition of fuel at the time of disposal cannot now be accurately predicted. Aleo, detailed icopection requireeents. for spent nuclear fuel should not be specified at this time, and lonk i

testing of spent nuclear fuel is not required to determine its condition. Only two classifications of spcet nucloor fun' are necessary: fuel that has to be canned and fumi that deca cot.

(Article VI.A.4 and Appendicea E and F)

3. Previetone need to be added to the coutract which would allow l

Purchasers to exchange allocated disposal' services.

(Article IV.5)

4. DOE sust provide nuclear hazards indemnity to Purchasers if it does not usc contractors for transportacion of apent nuclear

. fuel or operation of the disposal facility. (Articia XIV)

Mr. Robert Morgan 2

5. DOE must provide protection for Purchasers Arsinat non-nuclear riska and should agree to indemnify Furchasers against any such liability. Aa appropriate contrace clause is being ausgested by EEI.

6. The contract needs to provide that neither DOE aor Purchasers are-liable for consequential damages. An appropriste contract cismae is befog suggested by ZEI.

Further. Yepco offers the additiersi comments in the Attachment horeto. These comments address specific Vepco c'encerns reisted tot

1. The extent of required DCE verification of spent nuclear fuel packaging. (Article 71.B.1)

2. The fee and payment mathed for Aa-ccre fuel as of April 7, 1983 and irradiated fuel in storage which will be reinserted into the core. (Articia V111.A.4)

3. Purchaser should receive credits from DOE to the extent that significant identifiable ennes saviers are accrued by DOE as the renuit of specific actions taken by Purchaser, at Purchmace's exper.se.

If you have any questions, please contact me at (E04) 771-6775.

Very truly yours.

!/

R. R. /L ;as rg Vice President Power Statino Cometruction Attachment ce: Mr. Jaff M111, Office at M.nagement ar.d Eudgat bc: Mr. J. H. Ferguson Mr.-H. M. Wilson, Jr.

Mr. J. I. Oatts Mr. W. R. Benthall Mr. S. C. Brown, Jr.

Mr. M. L. Smith Mr. B. D. Johnson Mr. B. H. Wakeman Mr. O. J. Peterson M. W. Maupin, Esq.

- Mr. W. N. Thomas NFS File: 20.5.A.1 Mr. W. L. Stewart Central File Dr. J. T. Rhodes Chronological File Mr. W. C. Spencer Mr. D. R. Hostetler 108p20.5albhw7

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• '. gy ATTACMG"NT

1. The requirement for DOE verification of spent nuclear fuel packaging l

prior to acceptance by DOE should allow for packaging well in advance

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of DOE acceptance. For instance, Purchaser may be using dry storage

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4 casks for interim storage of spent nuclear fuel and may be able to

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l deliver these casks to DOE for transportation and disposal of the spent nuclear fuel. DOE and Purchaser shculd not be required to open f

storage casks to physically verify the cendition of the spent nuclear j

fuel if they can sufficiently document that its condition

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i acceptable. (Article VI.B.1).

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2. The fee for in-core fuel (and irradiated fuel in storage that will be

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reinserted into the core) should be equivalent to 1 Mill / Kwhr as calculated against the actual burnup of individual assemblies as of 1

April 7, 1983. (See the formula provided as Alternative 2 on pages j

5459 and 5460 of the Federal Register dated February 4, 1983.) The total liability for this fee should then be fixed, and the provisions

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governing escalation and payment for this fee should be the same as those established for permanently discharged fuel.

(See also EEI f

comments on fee escalation and payment reched for fuel discharged as of April 7, 1983.) (Article VIII.A.4) i 2

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3. DOE should be permitted, at their discretion, to award credits to a 1

Purchaser to the extent that Purchaser, at its expense, takes specific actions that provide significant identifiable cost savings to be accrued to DOE. The contract should contain a provision that permits-I DOE to award such credits should they elect to do so..

For instance, DOE-may~ be able.to. transport Purchaser's spent nuclear fuel in Purchaser's dry storage casks, thereby saving the. cost of~ using a transportation cask. Also, Purchaser may provide DOE with consolidated spent nuclear fuel, thereby reducing the volume of Purchaser's spent nuclear fuel that DOE has to transport and dispose.

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i March 7, 1983 1

l U. S. Department of Energy i

Procurement and Assistance Management Directorata

}

Office of Procurement Operations ATTN Ms. Jan Atkinson l

Washington D.C.

20585 i

1 Dear Ms. Atkinsont j-ADMINISTEATIVE INFORMATION FOR DOE SPENT j

EUrtRAE FUEL DISPOSAL _ SERVICES CONTRACT l

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4 In accordance with Mr. H. J. Rauch's letter of February 14. 1983, the following administrative information is provided by Virginia Electric and Power Company (Vepco) to facilitate signing of a spent nuclear fuel i

disposal services cortract by June 30, 1983, as stipulated in the Nuclear I

Waste Policy Act of 1983.

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1. Mr.

J.

H.

Ferguson, Executive Vice President and Chief 4

Operating Officer is the individual currently authorized to j

sign this contract for Vepco.

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2. I as the designated contact for discussions related to the contract. All correspondence to Yepco on the contract should i

be eddressed to me.

Also please send a copy to Mr. H. M.

l Wilson, Jr., Manager, Fuel Resources. My telephone rumber is j

(804) 771-6773. Yepco's mailing address is:

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Virginia Electric and Power Company Post Office Box 26666 i

Eichmond, Virginia 23261 1

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3. Assuming the DOE contract will become final by April 1,1983, j

the earliest date upon which we believe the signed contract can be returned to DOE is June 1, 1983.

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Ma. Jart Atkinson 2

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4. Vepeo is prepared to continue its contract negotiations with DOE at the earliest opportunity and we look forward to working with DOE.

4 If you have any guestions, please contact me.

Yary truly yours, i

i 4

1 l

R. R.

e rg 1

Vice Prosident j

Power Station Construction b

bc: Mr. J. H. Ferguson Mr. S. C. Brown, Jr.

i Mr. J. I. Oatts i

Mr. W. C. Spencer Mr. W. L. Stewart Mr. W. N. Thomas Mr. H. M. Wilson, Jr.

i Mr. W. R. Benthall Mr. M. L. Smith E. B. Brasfield, Esq.

{

M. W. Maupin, Esq.

j NFS File: 20.5.A.1 l

Central File j

Chronological File i

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