ML20094L786
| ML20094L786 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/14/1984 |
| From: | Maupin M HUNTON & WILLIAMS, VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OLA-1, OLA-2, NUDOCS 8408150464 | |
| Download: ML20094L786 (31) | |
Text
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W August 14, 1984
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UNITED STATES OF AMERICA.'
NUCLEAR REGULATORY COMMISSION.
BEFORE THE ATOMIC TED SAFETY AND LICENSING BOARD l
'84 ASg gg SII.'12 In the Matter..of
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VIRGINIA. ELECTRIC AND POWER
' COMPANY
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Docket Nos. 5'0'4'3'5 8 / 3 3 9--OLA- 1 5/s - j-OLA-2 lg_l ,
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00"XET !'U." r3 (North Anna Power Station, ) PROD.& UT:L...........c. r?.0...ggg ]
Units 1 and 2) )
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APPLICANT'S RESPONSE TO C 30.".3.3. . I THE CONTENTIONS OF 4
CONCERNED CITIZENS OF LOUISA COUNTY bh1
! Concerned Citizens of Louisa County (CCLC) filed'its Third Draft of Contentions (Third Draft) on July 30, 1984. None of thuse contentions is admisrible, and all but-Conten' tion 4 in OLA-1 should be denied by the Board without more. Contention 4 in OLA-1 should be treated in accordance with paragraph'4 of
+ Section A of this Response.
A. Proceeding OLA-1 i
- l. Contention 1
}
The proposed license amendment constitutes a major federal
-action significantly affecting the human environment, and thus may not be granted prior to the preparation of an environmental impact statement.
- CCLC provides three Bases for this Contention. The first is 4 the risk that the transportation cask to be useu to ship Surry fuel to North Anna might rupture, the second is the risk of human error in cask handling and the third is the risk of sabotage 8409150464 840014 A2 Uw PDR ADOCK 05000338 g PDR
m-4.
during transportation. Each Basis addresses the environmental effects of' spent fuel transportation.
The Staff, in its-Environmental Assessment, specifically addressed the effects of transporting Surry spent fuel to North LAnna, including the-effects of potential accidents, and concluded-
'that. licensing Vepco's proposal would not significantly affect the human ~ environment. Environmental Assessment at 29. CCLC's !
I first two Bases for Contention 1 - cask rupture and human error -
i thus challenge the Staff's analysis. The Staff's analysis,
, however, is the correct-one; indeed , it is the analysis. required by law. In the Environmental Assessment, the Staff concluded:
3
- The environmental impact of the transporta-l tion activity associated with the proposed l transshipment of spent fuel from Surry to '.
l NAPS is within the scope of Table S-4 in 10
- CFR 51.52 and therefore need not be addressed on a site-specific basis. At 27.
- The Staff compared the parameters of Vepco's shipping. proposal
, with the parameters of Table S-4 and found -- correctly -- that each of the former falls well within the latter. In fact, the radiological impact of Vepco's proposal is less than the effects set out under Table S-4 by a factor of 30. Id.
Section 51.52 of NRC's regulations requires that an environ-
- f. mental report " prepared for the construction permit stage"1 of ,
1 1
These proceedings, of course, do not involve the i " construction permit stage" of a nuclear reactor. CCLC, however, has not argued that Table S-4 is inapplicable for that reason, 4
nor could it have rationally done so. The Surry Power Station, which is the point of origin for the proposed shipments, was licensed before. Table S-4 was promulgated. But had it been l (Footnote Continued)
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nuclear. reactor shall contain av statement concerning transpor-3 >.
tation of fuel and. radioactive wastes to and from the reactor. ,
The provision also requires that the statement shall indicate <
thatithe reactor.and the proposed transportation either meet all' of the conditions in S 51.52 (a) or all of the conditions in ,
, S 51.52 (b) . .On its' face the latter applies only if the former does not.- As the Staff points out in the Environmental
-Assessment, the Vepco proposal' falls within each of the' criteria of S 51.52 (a) , and so the Staff was required to use Table S-4.
Table S-4, of course, includes consideration of potential transportation accidents.
CCLC's challenge in Contention 1, then, is nothing more than a challenge to the adequacy of Table S-4. It is an attack on the accident assumptions underlying the Table.- nder 10 C.F.R.
S 2.758, however, CCLC may not challenge the adequacy of Table S-4 unless it successfully demonstrates that the application of i
i Table S-4 should be waived or an exception be made for this I particular proceeding. The sole permissible ground for such a i
petition is that there are special-circumstances with respect to the subject matter of this proceeding such that application of Table S-4 would not serve the purpose for which it was adopted. .
1 1
(Footnote Continued) licensed after. January 7, 1975, transportation of spent fuel from 4 Surry would have been assessed under Table S-4. Since the Board i has questioned the adequacy of the site-specific analysis
-actually undertaken when Surry was licensed, and since there is i- no rational reason why Table S-4 should not apply in the circumstances, the Staff's decision to use it was plainly correct.
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> CCLC'has not set out any reason why application of Table S-4 in this proceeding would not serve the purpose for which the Table l'
was adopted.- This is not surprising.. It is precisely for the
- s L purpose ' of evaluating a proposal such as Vepco's that Table S-4 f was adopted.
Nothing in CCLC's Contention 1 so much as. hints at why Table S-4 should be. deemed inapplicable. The only suggestion in this i
l regard is contained in'the Basis for Contention 5 in OLA-1.
1
, There CCLC states: ,
Nowhere, including the environmental
! impact statements prepared in connection with the licensing of Surry, has-the NRC Staff j considered the possible effects of spent fuel i
shipments on-Louisa County and its residents.
- Third Draft at 5.
{ In short, CCLC offers only the bald conclusion that a site-specific analysis is required. That, however, is just what Table j' S-4 was designed to avoid.-
i j This is not the first time an intervenor has attempted to i
j raise such an issue, and if this Board rejects Contention 1, as i
I it should, it would not be the first time that has happened 1
i either. In Duke Power Co. (Catawba Nuclear Station, Nnits 1 and i
- 2) , LBP-83-8B, 17 NRC 291 (1983), the applicant sought an
!. operating license and authority to store at Catawba spent fuel j from its Oconee and McGuire Stations, which were already l
l licensed. The Oconee operating license had been issued before l Table S-4 was adopted, and a site-specific environmental review of transportation effects had been performed. McGuire's spent fuel transportation had been reviewed under Table S-4.
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-The intervenors in Catawba sought to raise contentions that challenged the adequacy of the Staff's environmental. analysis of spent fuel-transshipment and attempted to sidestep Table S-4.
The Board disallowed these contentions, which closely track u CCLC's Contention 1. Among other things, the intervenors argued that-Table S-4 was inapplicable because it was based on shipment to a reprocessing plant, while the destination of Duke's spent fuel was Catawba. .The Board found no basis for making such a distinction. Id. at 292. WASH-1238, which underlies Table S-4, supports that result. The analysis in WASH-1238 is a general analysis of the impact on the environment from the transportation of nuclear fuel . . . to and from a light-water-cooled nuclear power reactor . . . WASH 1238 at 3.
The Commission's Statement of Considerations accompanying the rule that adopted Table S-4 indicates that although a reprocess-ing facility was assumed to be the destination of spent fuel, that assumption played no part in the Commission's' evaluation of the Staff's analysis. 40 Fed. Reg. 1005 (January 6, 1975). The objective was to assess the environmental effects of transporta-tion for a " typical" nuclear power reactor. Id. Simply stated, the effects of transshipment reflected 4, S ulo S-4 turn on factors other than destination.
The Board in Catawba also rejected the argument that Table S-4 was inapplicable because it contemplated only shipment to an l
2
- As will be seen, they also track closely CCLC's Contention l 5 in OLA-1.
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b
, ac ultimate' destination while the Catawba proposal contemplated
, shipment for interim storage followed by shipment to an ultimate destination. It found no basis for concluding that the diversion of spent. fuel to Catawba would result in appreciably greater
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environmental effects than shipment directly to the ultimate destination. 17-NRC at 294. CCLC has not alleged any-l " appreciably greater" effects attributable: solely to diversion of Sorry fuel for interim storage at North Anna.
Having found Table S-4' applicable, the Board concluded that the intervenor's contentions on spent fuel transportation were
" impermissible attacks on a Commission rule." m Id. This is precisely how the Board in this proceeding should dispose of the first two Bases for Contention 1.
CCLC's third Basis for Contention 1 is the risk of sabotage.
To be sure, effects of sabotage are not included in Table S-4.
4 In its Statement of Considerations, the Commission said in' adopting Table S-4:
[ (S]abotage and diversion of shipments of fuel and waste to and from reactors are not covered in the Environmental Survey and are not accounted for in the values contained in the Summary Table. The environmental effects
, of sabotage and diversion, therefore, are beyond the scope of the rule and are subject to appropriate separate consideration in individual reactor licensing proceedings. 40 Fed. Reg. 1007 (January 6, 1975).
3 In fact, the distance from Surry to North Anna is about 180 miles. Environmental Assessment at 27. The distance from North-Anna to the reprocessing site used in the WASH-1238 analysis is 300 miles. WASH-1238, Supplement 1, Table S-1 (April ~1975).-
Thus, the combined distance is under 500 miles, which is only (Footnote Continued) 4
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'Thus , this third Basis for Contention 1 is not barred by 10 CFR S 2.758. But it suffers from a more fundamental defect. It is not stated with reasonable specificity as required by 10 C.F.R.
. S ' 2.714 (b) . ,
1 A contention must include a reasonably l specific articulation of its rationale - i e.g., why the applicant's plans fall short of certain safety requirements, or will have a particular detrimental effect on the environ-ment. Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), LBP-82-16, 15 NRC 566, 570 (1982).
Here is CCLC's Contention 1 statement on sabotage in its 4
entirety:
Other environmental costs-associated with the proposed license amendment include the risk of sabotage, the effects of which would be comparable to those of a serious transporta-tion accident . . . Because of all of these
. risks, the proposed license amendment will give rise to significant environmental effects. Third Draft at 2-This is hardly " specificity." CCLC has had more.than a year to shape its contention on sabotage. Yet we are not told now the sabotage might be carried out, what the effects on the cask and spent fuel might be and what health effects could be expected.
Moreover, despite having the Staff's documents available, CCLC has not said what is wrong with the Staff's analysis. The Staff has concluded in its Safety Evaluation that the probability of a sabotage event is remote and that attempted sabotage, even if successful, would not produce serious radiological (Footnote Continued) one-half of the 1,000 mile shipment assumed for purposes of Table i S-4.
1
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l consequences. Safety Evaluation at,4.4. The Staff supports its findings with' work performed at Sandia National Laboratories to
' determine the consequences of cask rupture. CCLC has not alleged a-single fact that casts doubt on the Staff's analysis. Thus,,
the third Basis for Contention 1, as is the case with the first two, is also an impermissible ground for admitting Contention 1.
- 2. Contention 2 VEPCO has not shown that the shipping casks to be used to transport Surry spent fuel to North Anna meet NRC standards.
I CCLC states as its Basis for this Contention: "Compli-ance . . . must be shown before the license amendment can be issued." (Third Draft at 2.) In fact, compliance has been shown.
Vepco plans to use the TN-8L shipping cask for the proposed shipments. 10 C.F.R. S 71.12 (a) grants a general license to the Applicant to ship spent fuel "in a package for which a . . .
certificate of compliance . . . has been issued by the NRC." 10 C.F.R S 71.12 (c) (1) requires that Vepco have a copy of the certificate of compliance, and S 71.12 (c) (3) requires it to register with NRC, prior to the first shipment, its plans to use the cask.
All of the foregoing provisions have been complied with.
Transnuclear, Inc., the owner of the TN-EL cask, has obtained a certificate of approval for the cask under Part 71. Vepco has a copy of the certificate, and a copy is attached hereto as Attach-ment 1. Moreover, Vepco haa filed, and NRC has acknowledged, the i
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, required registration.- "This registration is reflected in Attachment 2.
In'short, compliance with the requirements of Part.71 has been shown. .CCLC has not stated, with particularity or other-wise, any admissible basis for this contention despite_all.the
, time it has'had to investigate the cask characteristics. As the Board said in Duke Power Co (Catawba Nuclear Station, Units 1 and
- 2) , LEP-82-16, 15 NRC 566, 570 (1982): "It is not enough . . .
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merely to allege that aspects of an applicant's plans will not
- comply with Commission regulations."
f t 3. Contention 3 s
i Neither.VEPCO nor the NRC Staff has adequately considered i the alternative of constructing a dry cask storage facility.at the Surry station.
In the Applicant's Response to Questions Posed By the Licensing Board, which was filed by Vepco on April 1, 1983,-in this proceeding, Vepco discussed the circumstances under which the NRC Staff must provide an analysis of altE.* natives. It-is.
not necessary to repeat that discussion here, but it will be helpful to restate the important conclusions. There are two.
First, S 102 (2) (E) of NEPA, 42 U.S.C. S 4332 (E) , provides that Federal agencies shall develop and describe alternatives to recommended courses of action for any proposal "which involves unresolved conflicts concerning alternative uses of available resources." Second, it is well-established in NRC practice that, absent such an unresolved conflict, alternatives need not be analyzed in instances where the environmental effects of a proposed action are insignificant. Portland General Electric Co. !
, 1
o . -
(Trojan ' Nuclear- Plant) , ALAB-531, 9 - NRC 263, 266 (1979); Duke
- Power Co. '(Amendment to Materials License SNM-1773-Transportation of Spent Fuel from 'conee O Nuclear Station'for Storage at.McGuire Nuclear Station) , ALAB-651, 14 NRC 307, 321-22 (1981).
With respect to the first principle, the short answer is that CCLC has neither contended nor suggested in its statements of basis that this proceeding involves any ' unresolved.conflic't over use of available resources, and the Staff has found none.
As for the second principle, CCLC has attacked only in i Contentions.1 and 5 in OLA-1 and Contentions 1 and 3 in OLA-2 the Staff's conclusion that no environmental impact statement is required. For reasons set out above in Section A, paragraph 1 of this Response, Contention 1 in OLA-1 is inadmissible. As will-be '
seen from the discussions that follow, the other contentions raise the same, and only the same, argunents as Contention 1 in OLA-1 raises, and so they are inadmissible for the same reasons.
Thus, CCLC is'left without any valid contention challenging the Staff's conclusion that no significant environmental effects will result from Vepco's proposals. If thu Staff's conclusion is not
, challenged by an admissible contention, it must be treated as
! correct. If it is correct, then no discussion of alternatives is ;
required, and Contention 3 is inadmissible as well. :
i 1
- 4. Contention 4 VEPCO has not shown that its physical protection system l satisfies NRC regulatory requirements.
The sole basis for this contention is that "all of the information concerning such security measures has been deleted
XI _11_
from the'available documentation on file at the NRC's public document room." Third Draft at 4.
LIn.its application for permission to store Surry spent-fuel.
assemblies at North Anna, Vepco stated on page 71, under the heading Physical Protection, "This page is withheld from public disclosure pursuant to 10 CFR 2.790 (d) (1) ."
In fact, all that appears on page.71 is a cross reference to Vepco's Spent Fuel Transportation Routing Plan (the Plan), which was filed wit'h NRC on July 13, 1982 pursuant to 10 CFR S 73.37.
The Plan was withheld from the Public Document Room initially,
, but in response to two Freedom of Information Act requests it was released, with one minor exception,4 and placed in the Public Document Room almost two years ago.
Vepco recognizes, however, that some confusion may have~been caused by the withholding of page 71 of the OLA-1 Application from the Public Document Room. So Vepco provided CCLC by mail on August 3, 1984 with a copy of the Plan. CCLC has agreed that it will review the Plan and by August 14, 1984 either withdraw or modify Contention 4. CCLC has further agreed, subject to this Board's approval, that if it enlarges upon this Contention,.Vepco and the Staff may have seven days from the date of service to I
respond.
.I 4
The public copy of the Plan does not show " safe havens" designated for truck use."
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- 5. Content' ion 5
- The Environmental Assessment prepared by the NRC Staff is
= inadequate.in the following respects:
(a) it does not evaluate the risks of accidents (including sabotage) involving Surry-North Anna shipments; (b) it does not evaluate the consequences of credible accidents involving Surry-North Anna shipments; (c) -it does' not evaluate the alternative of constructing a dry cask storage facility at the Surry station.
Contentions 5 (a) and (b) , of course, suffer from the same shortcoming as Contention 1 of OLA-1. To the extent they deal with accidents, they constitute attacks on Table S-4 and.are thus inadmissible under 10 CFR S 2.758. To the extent they deal with sabotage, they lack basis and specificity and do not challenge the. conclusion in the Staff's Safety Evaluation that attempted sabotage would not produce serious radiological consequences. At 4-4.
Contention 5 (c) is inadmissible for the same reason that Contention 3 is inadmissible. No consideration of alternatives '
is required, because CCLC has not posed a single admissible contention to the effect that an environmental impact statement is required here.
B. Proceeding OLA-2
- 1. Contentions 1, 2 and 3 These contentions are identical to contentions 1, 3 and 5, respectively, in OLA-1 and they are inadmissible for the same reasons. They are also inadmissible for another reason.
Each of these contentions is raised in connection with OLA-2, which involves Vepco's proposal to enlarge its spent fuel
.s
- , w storageLcapacity at' North Anna 1.and 2. Yet each. Contention.
deals only with transportation of Surry fuel to North Anna.
+
. CCLC's only asserted basis for linking the two is this:-
- The modification.of the North Anna spent fuel; pool,is designed to accommodate.the 500 assemblies that VEPCO intends'to remove from the Surry spent fuel pool. Actions-that are related in this way cannot be " segmented" for
- purposes of the environmentgl review. required
+
by NEPA. Third Draft at 6.
NRC case law, however, indicates tha the OLA-1 and OLA-2 proposals can and should be segmented. In Duke Power Co. (Amend-I-
ment to Materials License SNM-1773- Transportation of Spent-Fuel from Oconee Nuclear Station for Storage at McGuire Nuclear Station) , ALAB-651,14 NRC 307 (1981) , the Appeal' Board stated the test for determining whether an agency's environmental review
- has to cover only a particular proposal or some larger plan of which the propcsal is but a part. The review may be limited to
[.
the proposal alone if the proposal has " independent utility" and
- if authorizing the proposal would not foreclose the agency's freedom to deny other parts of a larger plan. 14 NRC at 313.
The Duke proceeding involved a proposal to ship 300 spent fuel
- assemblies from Oconee to McGuire. The record showed that Duke i
planned to make additional shipments in the future, and the Board i found that the Staff's environmental analysis should have covered the future shipments as well as the 300 that were the subject of 1
the application. The Appeal Board, however, disagreed. It b
5 While it.is true that an enlarged North Anna pool would accommodate Surry assemblies, it would accommodate North Anna assemblies equally well in the same spaces if no Surry fuel were sent to North Anna.
1
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concluded.that the 300 shipments would have " manifest independent utility," because they would provide a significant near-term
- benefit. At 315. The Appeal. Board also found that authorizing I the 300 shipments would not prejudice the evaluation of.any future request to make additional shipments. 'The Appeal Board
'also observed in passing'that reracking has " manifest independent L
utility." Id.
f Vepco's OLA-2 proposal also has " manifest independent utility." As the OLA-2 application indicates, if no Surry' fuel
- is shipped to North Anna, North Anna will lose full core' reserve.
(FRC) in 1989. If the 771 additional spaces-proposed in OLA-2 were provided and if no Surry fuel were shipped, loss of'FCR
~
could be extended at North Anna until 1998. Spent Fuel Storage
- at 4. With the adoption of the Nuclear Waste Policy Act of 1982,
, it is reasonably clear that an ultimate repository is unlikely to be available. before 1998, and so Vepco will need the additional
]
space that its OLA-2 proposal would provide even if no Surry fuel is ever sent to North Anna.
CCLC has not taken issue with any of these facts or stated i any way in which the usefulness of the OLA-2 proposal is depen-dent on the approvt.1 of the OLA-1 proposal. It is hard to imagine either a clearer case of independent utility or any basis whatever for accepting CCLC's OLA-2 Contentions.
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' Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY.
i By /s/ Michael W. Maupin Michael W. Maupin, Counsel Of Counsel Michael W. Maupin Marcia R. Gelman HUNTON & WILLIAMS P. O. Box 1535 Richmond, Virginia 23212 Dated: August 14, 1984 '
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. CERTIFICATE OF SERVICE t
I hereby certify that I have this day served Applicant's Response to Contentions of Concerned Citizens of Louisa County upbn each of the persons named below by depositing a copy in the United States. mail, properly stamped and addressed to him at the
. address set out with his name: ,
Secretary ,
s U. S. Nuclear Regulatory Commission.
Washington, D.C. 20555 t Attention: Chief Docketing and Service Section
- Sheldon J. Wolfe, Chairman
! Atomic Safety and Licensing Board Panel
- U. S. Nuclear Regulatory Commission Washington, D.D. 20555 Dr. Jerry Kline i
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 j
i Dr. George A. Ferguson V i' School of Engineering i Howard University l 2300 5th Street Washington, D.C. 20059 i Henry J. McGurren, Esq.
l U.S. Nuclear Regulatory Commission
- Washington, D.C. 20555 James B. Dougherty, Esq.
. 3045 Porter Street, NW l Washington, D.C. 20008 ,
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
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Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 By: /s Michael W. Maupin Michael W. Maupin, Counsel for Virginia Electric and Power Company Dated: August 14, 1984 i
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Attachment 1
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UNITED STATES E
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,1 s NUCt. EAR REGULATORY COMMISSION 6*'r l*W
. WASHINGTON. D. C. 20555 g ,
o e R. F. DRISCOLL N
- -@h'4j[ A.L.30GG.JR) MS/
, . J. O. IASTWOOD ##
FCTC: RHO * " * * * ('**"* 3,bec 71-6698, 71-9015, mzRs B.6 u e-+
' 71-9001, 71-9016, N R 1 3 ,S84
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99 Gentlemen:
A The enclosed Certificates of Compliance:
(a) Require inerting of dry spent fuel shipments; and (b) Prohibit the shipment of failed spent fuel unless specifically authorized in the Certificates of Compliance.
These changes are effective immediately for one or more of the Certificates of Compliance for which you are a user under the general license provisions of 10 CFR 971.12.
Sincerely, 8
Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosures:
- 1. Certificates of Compliance Nos. 6698, 9001, 9010, 9015, 9016, and 9023
- 2. Approval Record
- 3. Sierra Club ltr dtd 11/0//83 P
cc w/encls: See next page Identical letters sent to those on enclosed list
. _ _ . _ . . _ _ _ .__ _ . . __ _ , _ _ ~ . . _ _ _ . _
. i APR 131984 l
'# l cc w/encls:
l Mr. L. Santman
- Department of Transportation Mr. Arnold A. Weintraub Department of Energy Department of Energy ATTN: Mr. James M. Peterson P.O. Box 550 Richland, WA 99352 Department of Energy ATTN: Mr. A. T. Newmann P.O. Box 14100 Las Vegas, NV 89114 EG&G Energy tieasurements ATT!!: tir. Patrick C.11urphy, Jr.
P.O. Box 1912 Las Vegas, NV 89101 Oak Ridge National Laboratory ATTN: tir. Ililliam E. Terry P.O. Box X Oak Ridge, TN 37830 Reynolds Electric & Engineering Co., Inc.
ATTII: ftr. Arden E. Bicker P.O. Box 14400 Las Vegas, NV 89114 tiestinghouse Electric Corporation ATTN: fir. ' A. P. Weber P.O. Box 708 liercury, NE 89023
- ^ ' ' - ' - _ _ ..
_ _ _ __ . ~ _. . _ . _
' Model Nos. NFS-4, IF-300, NLI-1/2, TN-8', TN-8L, TN-9, and NLI-10/24
Addressees: w/encls ,
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Babcock and Wilcox Company Dairyland Power Cooperative
-ATTN: Mr. A. F. Olsen - ATTN: Mr. J. D. Parkyn P.O. Box 239 P.O. Box 275 Lynchburg, VA 24505 Genoa, WI 54632 Baltimore Gas & Electric Company Duke Power Company ATTN: Mr. A. M. Vogel ATTN: Mr. W. O. Parker, Jr.
P.O. Box 1475 422 South Church Street Baltimore, MD 21203 Charlotte, NC 28242 Battelle Columbus Laboratories Florida Power and Light Company ATTN: Mr. Harley L. Toy ATTN: Mr. Robert E. Uhrig 505 King Avenue P.O. Box 529100 Miami, FL 33152 Columbus, OH 43201 Boston Edison Company Florida Power Corporation ATTN: Mr. Richard Machon ATTN: Dr. Patsy Y. Baynard Rocky Hill Road P.O. Box 14042 Plymouth, MA 02360 St. Petersburg, FL 33733 l Carolina Power & Light Company General Electric Uranium ATTN: fir. B. H. Webster itanagement Corporation 1 Route 1, Box 327 ATTN: Mr. D. M. Dawson, S-56 New Hill, NC 27562 P.O. Box 508 Sunnyvale, CA 94086 4
Chem-Nuclear Systems, Inc.
! ATTN: lis. Robin Deal GPU Nuclear Corporation 1
240 Stoneridge Drive, Suite 100 ATTN: Mr. Thomas Snider Columbia, SC 29210 P.O. Box 388 Forked River, NJ 08731
- 1 Commonwealth Edison Company
- ATTN: Director of Nuclear Licensing Hittman Nuclear & Development Corp.
l P.O. Box 767 ATTN: Mr. Bruce S. Rowe Chicago, IL 60690 9151 Rumsey Road 2 Columbia, MD 21045 , ,
Commonwealth Edison Company ATTN: Mr. N. J. Kalivianakis Maine Yankee Atomic Power Co.
22710 206 Avenue North ATTN: Mr. L. H. Heider Cordova, IL 61242 Turnpike Road (RT 9)
Westboro, MA 01581 Connecticut Yankee Atomic Power Company i ATTN: Mr. R. H. Graves Nebraska Public Power District R.R. No.1, P.O. Box 127E ATTN: Mr. Jerry V. Sayer East Hampton, CT 06424 P.O. Box 98 1 Brownville, NE 68321 i
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. APR 13 384 Addressees: w/encls(continued) 6 Nebraska Pubite Power District Virginia Electric and Power Company ATTN: Mr. J. M. Pilant ATTN: Vice President - Nuclear Operations P.O. Box 499 P.O. Box 26666 Columbis, NE 68601 Richmond, VA 23261 Northern States Power Company Westinghouse Electric Corporation ATTN: f1r. L.O. tiayer ATTN: tir. A. J. Nardi 414 tiicollet Mall, 8th Floor P.O. Box 355 Minneapolis, MN 55401 Pittsburgh, PA 15230 Nuclear Assurance Corporation Wisconsin Electric Power Company ATTN: Mr. Charles R. Johnson ATTN: fir. Sol Burstein 5750 Peachtree Parkway 231 West Michigan Norcross, GA 30092 1111waukee, WI 53201 Omaha Public Power District ATTN: tir. T. L. Patterson 1623 Harney Onaha, NE 63102 Rochester Gas & Electric Corporation ATTN: tir. John E. Itaier 89 East Avenue Rochester, NY 14649 Smith-Emery Company ATTN: !!r. !! ark S. Dunham 781 East Washington Los Angeles, CA 90021 Southern California Edison Company ATTN: fir. R. H. Bridenbecker 2244 Walnut Grove Avenue Rosemead, CA 91770 Transnuclear, Inc.
ATTN: fir; Kurt Goldmann One North Broadway White Plains, NY 10601 Vermont Yankee Electric Company ATTN: Licensing Engineer 1671 Worchester Road Framingham, MA 01701 i,
4
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1 ,,(c ,on gi, u.s. NUCLEAR REGULATORY CEMMISSl!N -
I t 3, CERTIFICATE CF CZMPLIANCE ,
l 'o cFa f t FOR RADIOACTIVE MATERIALS PACKAGES !.
t a centiricArs ~uween e R(Vi$10M NUMg(R s. PAC = AGE IDENitriCATlON NUwe(R e PAGE NUM8(A e rOTAL NUUSER PAGES ,
p 9015 7 USA /9015/B( )F 1 5 $
l 2 PetAueLE 1 a. This certificate is issued to certify inat the packaging and contents described in stem $ below meets tne applicaele safety standards set fortn in Title 10. Code ll Of Federal Regulations. Part T1,-Packaging of Radioactive Materials for Transport and Transportation of Radioactive Material Under Certain Conditions /*
3 c. This certificate doe, not relieve tne consignor from compliance with any requirement of the regulations of the U S. Department of Transportation or otner
'l applicante regulatory agencies, including tne gova nment of any country enrougn or into whicn the package well be transported. ,M 11 @
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3 Transnuclear, Inc.
5 3 Transnuclear, Inc. application dated %
1 One North Broadway April 9,1980, as supp:emented. R j White Plains, NY 10601 E Ir f c oocart~uue<a 71-9015 Y 4 a co~oirious This certificate is conditional upon fulfilling the requirements of to CFR Part 71. as applicable, and the conditions specified beiow h t 5. in K lE:
1 (a) Packaging E' 2 i
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(1) Model Nos.: TN-8 and TN-8L j i
.E g (2) Description p 3
d Lead, steel and resin shielded irradiated fuel shipping casks. The >E il casks approximates a right circular cylinder 1,718 mm in diameter and ,E I
il 5,516 mm long. The cavity consists of three (3) stainless steel i
( square pressure vessels welded to an end plate and a circular stepped top flange, separated by a T-shaped copper plate and surrounded with 9
q ;I q 84C + Cu plates. Each cavity is 230 x 230 mm and 4,280 mm long. The D
- t main shielding consists of 135 mm of lead, 26 nm of steel and 150 mm D il of resin. A wet cement layer is located between the lead and the I outer shell. Radial copper fins are welded to the outer shell and ,j l)@
dj cover the surface of the cask between each end drum. The Model No.
TN-8 has 150 rows of fins and the 11odel No. TN-8L has 104 rows of m fins. I dl !!
t The lid is a welded stainless steel shell containing lead and resin 3 l! shields. The pressure vessels are closed and sealed by sixteen (16),
d
, 1-1/4-inch diameter bolts and two silicone rubber or Viton 0-rings -t m located within recessed grooves on the too flange. Each extremity of !!
m the cask is surrounded by circular stainless steel drums reinforced by .I A radial gusset plates and filled with balsa wood. A disk shaped impact i l
4 limiter, constructed of carbon steel and balsa wood is fastened to I j each drum with four (4),1-1/4-inch bolts. The vent and drain lines I M which penetrate the inner cavity are equipped with positive closures. .I
( In addition, all access ports are protected by the impact limiters. I 11 !
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- ,9
, l CONDITIONS (continued) ll
- I lN l Page 2 - Certificate No. 9015 - Revision No. 7 - Docket No. 71-9015 fl l fn l !N l 'N l S. (a) Packaging (continued) N l (2) Description (continued)
I %
I Trunnions are used for lifting and tie-down of the package. The casks it I
l weigh approximately 36,000 kg.
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I (3) Drawings f r .
3 The flodel No. TN-8 packaging is constructed in accorda a with g R Transnuclear Drawing No. 9317.01, Rev. J. The Model No. TN-8L is E
,M constructed in.accordance with Transnuclear Drawing No. 9317.138, R Il Rev. A. The materials of construction and welds shall be in accordance
!! with Annex A, B, and C to Chapter II of the Application. @l l
11 I I (b) Contents t I
(1) Type and form of material J llI Irradiated PWR uraniun oxide fuel assemblies of the following specifications :
gl t i
di 't
, g Fuel fonn Clad UO P E l8 Cladding material Zr or S$ ellets I E
l', fiaximum initial U content / assembly, kg 469 flaximum average initial U-235 enrichment, w/o 3.2 g j! Maximum bundle cross section, in 8.5 %
i Maximun active fuel length, in 144 1 1 Mininum cooling time, day 150 %
Maximum weight / fuel assembly, kg 733; and E (i) Group I fuel assemblies j,li I; '
Initial fuel pin pressure at 100*F, psig Maximum average burnup, MWD /i1TU 250 38,500; or it
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p.
(ii) Group II fuel assemblies if-i j' is fiaximum average burnup, inlD/liTV 36,000 8
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l Page 4 - Certificate No. 9015 - Revision No. 7 - Docket No. 71-9015 t
I I I r I 7. Known or suspected failed fuel assemblies (rods) and fuel with cladding defects l l greater than pin holes and hairline cracks are not authorized. ;
l 8. Prior to each shipment, the package must meet the tests and criteria specified !
g for each shipment (operation) in Chapter VIII of the Application, as amended I I May 3,1983 (Chapter 6.0, Operations Program). !
I i
- j. 9. The package contents must be so limited that under normal conditions of transport, J jg the total dose rates must not exceed 17 mrem /hr at one meter from the surface of g is the package. ig 31 Eq l 10. Any system used for cooling down the package must be provided with a pressure F, '
relief device set so that the maximum pressure in the containment vessel cannot l exceed 7 atmospheres during the cool-down process. i l
- 11. The systems and components of each packaging must meet the periodic tests and :
- criteria specified in Chapter VIII of the Application. Each packaging that I i fails to meet these criteria must be withdrawn from servico until corrective !
action has been completed.
l
! 12. Repair and maintenance of the packaging must be as described in Chapter VIII of !
! the Application. '
i
- 13. All valves, fittings, seats and relief devices must be of the type, size, model ('
and manufacture as indicated on the design drawings. The resin material mst be i of the specifications stated in Annex A to Chapter'II of the Application. (.
f 14. Prior to first use, each packaging must meet the acceptance tests and criteria j specified in Chapter VIII of the Application, as amended. !si
! W l 15. In accordance with Annex L to Chapter VIII, at periodic intervals not to exceed iif I
two (2) years, the thermal performance of the cask nust be analyzed to verify that the cask operation has not degraded below that which is licensed. Following j
lg l the initial acceptance tests, the heat source may be that provided by the decay :g.
j heat from the loading of the package, provided that the heat source is equal to l&
at least 25". of the design heat load for the package. Each cask that fails to l
- meet the thermal acceptance criteria given in Annex L of the Application mst be withdrawn frca service until corrective action can be completed or the license f lH E
f I
l amended to limit the package to a lower heat load,
- 16. The package authorized by this certificate is hereby approved for use under the ,'Is Ei general license provisions of 10 CFR $71.12. i iE
- 17. Expiration date: June 30, 1985. @g k5 W E!
l I
____ - _____-_ a
l l CONDITIONS (continued) ll
- g I in I E l Page 5 - Certificate No. 9015 - Revision No. 7 - Docket No. 71-9015 I
1 lgE Ig I I N
- I REFERENCES !
i l l3E l Transnuclear, Inc. application dated April 9,1980.
g Supplements dated: October 31, 1980; June 17, 1981; and May 3, and 27, 1983. lj[
II 1 I
B FOR THE U.S. NUCLEAR REGULATORY C0t1 MISSION t I t' I t
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'ju Charles E. MacDonald, Chie ;g il Transportation Certification Branch ji 8
Division of Fuel Cycle and I l Material Safety, NMSS 9
l Dated: APR 131984 r I
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UNITED STATES DISTRIBUTICII LIST - WRC
- $g" W0s,h* NUCLEAR REGULATORY COMMisslON C'*"" -
D WASHINGTON, D.C. 20555 J. M. D f . R. F. DRISCoLL A. L. 30GG. JR.
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$'+, .,. . . . f 3. o. uswoon MM 18 gg4 TECB LIBRARY @RIGIM O gggg FCTC: RHO 71-9015 ,,,,, T. L 4.e s '*6 NGIG E!O 9 0 '. Ol' J.01.
g_ gw Transnuclear Inc. '
ATTN: Mr. Kurt Goldmann One North Broadway White Plains, NY 10601 Gentlemen: ,
As requested by your letter dated May 1,1984, enclosed is Certificate of Compliance No. 9015. Revision No. 8. for the Model Nos. TN-8 series shipping packages. This certificate supersedes in its entirety Certificate of Compliance No. 9015, Revision No. 7, dated April 13, 1984.
Changes made to the enclosed certificate are indicated by vertical lines in the margin. ,
Virginia Electric and Power Company has been registered as a user of these packages under the general license provisions of 10 CFR 671.12 or 49 CFR 5173.471.
This approval constitutes authority to use these packages for shipment -
of radioactive material and for the packages to be shipped in accordance with the provisions of 49 CFR 5173.471.
Sincerely, Ch M d, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosures:
- 1. Certificate of compliance No. 9015 Rev. No. 8
- 2. Approval Record cc w/encls:
Mr. Richard R. Rawl Department of Transportation i
Virginia Electric & Power Company l
ATTN: Vice President - Nuclear Operations .
P.O. Box 26666 Richmond, VA 23261 l
$ . s conomoks tcontinvec) k
'. . l E l I L l Page 2 - Certificate No. 9015 - Revision N3. 8 - Docket No. 71-9015 I-1 E I E 1 E I I i S. (a) Packaging (continued) i 1 ,' I j (2) Description (continued) l j Trunnions are used for lifting and tie-down of the package. The casks weigh approximately 36,000 kg.
a !g 1 et 1 (3) Drawings if 1 .I j
- g The Model No. TN-8 packaging is constructed in accordance with Transnuclear Drawing No. 9317.01, Rev. J. The Model No. TN-8L is
}r, a constructed in accordance with Transnuclear Drawing No. 9317.138, lg 3 Rev. A. The materials of construction and welds shall be in accordance lE 1 with Annex A, 8, and C to Chapter II of the Application. il 1
j (b) Contents ,
jf-ll
'l ll a (1) Type and fom of material i 1 . I
] specifications:
l j Fuel form Clad UO P h 3 Cladding material . Zr or S$ ellets g i Maximum initial U content / assembly, kg 469 E 2 !!aximum average initial U-235 enrichment, w/o 3.2 E 4 -1 Maximune bundle cross section, in 8.5 E-
]3 Maximum active fuel length, in tiinimum cooling time, day 144 150 f a Maximum weight / fuel assembly, kg 733; and !g 1 ( !rE a (i),- Group I fuel assemblies i lE 1
1 j i t
Initial fuel pin pressure at 100*F, psig 250 if g Maximum average bunup, IMD/MTU 38,500; or {g 1 s (ii) Group II fuel assemblies !.E 1 . k j Maximum average burnup, MWD /11TU 36,000 l
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1 i 1 I 1 E 1 . E 4 E 1 E 4 IE 1 5 1 '
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conolisons ccontinueci I Page 3 - Certificate No. 9015 - R; vision No. 8 - Docket No. 71-9015
, I I
l S. (b) Contents (continued) 1 3 (2) Maximum quantity of material per package I
j (i) For the contents described in Item 5(b)(1)(1):
! Three (3) PWR assemblies. The maximum decay heat load is not to 1 exceed 35.5 kilowatts per package and 12 kilowatts per assembly 1 for the Model No. TN-8 packaging and 23.7 kilowatts per package j and 7.9 kilowatts per assembly for the Model No. TN-8L packaging.
y (ii) For the contents described in Item 5(b)(1)(ii):
1 Three (3) PWR assemblies. The maximum decay heat load and the 1 maximum free gas volume are not to exceed the limits listed in
- j the table below
- ,
) g Decay Heat per Assembly, kw(a) MaximumFregGas(NTP)(b) per Assembly, m 1
.1 0.5 0.186 i
1.0 0.181 l 3.0 0.161 5.0 g 0.147 i 7.0 0.136
'a 9.0 0.128 1
jil Notes: (a) Decay heat load per assembly shall not exceed 7.9 kilowatts for TN-8L packa NTP conditions are 25*C and one (1) bar.ging.
- ) (b) 1 1 (iii) PHR assemblies may be shipped either with or without burnable j poison rod, thimble plug, or control rod assemblies, j
- q (iv) As needed, appropriate component spacers may be used in the cask cavity to properly position the fuel assemblies.
3
- 1 (v) The maximum weight of the contents (fuel assemblies, component
] spacers, inserts, etc.) shall not exceed 2,200 kg.
f'b (c) Fissile Class III ll Maximum number of packages per shipment One (1) ll l 6. The cask cavity must be dry (no free water) when delivered to a carrier for
\
l transport. Residual moisture must be promptly removed from the cask cavity by 3
the methods described in Annex I to Chapter VIII of the Application. The cavity i must be promptly backfilled with 1.0 atm of helium, nitrogen, or argon gas.
!I i
)
l l V--------------------------------- *-----------._-------.
. < l' r
CcNom:NS (contasued) '
3 t Pa'ge 4 - Certificate No. 9015 - R;; vision No. 8 - Docket No. 71-9015
. .- 1 I'
l 7. Known or suspected failed fuel assemblies (rods) and fuel with cladding defects I greater than pin holes and hairline cracks are not authorized. '
l 1 8. Prior to each shipment, the package must meet the tests and criteria specified t I for each shipment (operation) in Chapter VIII of the Application, as amended l May 3,1983 (Chapter 6.0, Operations Program).
1 I 9. The package contents must be so limited that under nonnal conditions of transport, I the tetal dose rates must not exceed 17 mrem /hr at one meter from the surface of I the package.
l 10. Any system used for cooling down the package must be provided with a pressure i relief device set so that the maximum pressure in the containment vessel cannot
- I exceed 7 atmospheres during the cool-down process.
I i
i 11. The systems and components of each packaging must meet the periodic tests and I
criteria specified in Chapter VIII of the Application. Each packaging that 1
i j fails to meet these criteria must be withdrawn from service until corrective action has been completed.
i I
i i 12. Repair and maintenance of the packaging must be as described in Chapter VIII of
! I the Application.
I
.l 13. All valves, fittings, seals and relief devices must be of the type, size, model l and manufacture as indicated on the design drawings. The resin material must be
! I of the specifications stated in Annex A to Chapter II of the Application.
j .l .
- I 14. Prior to first use, each packaging must meet the acceptance tests and criteria
-l specified in Chapter VIII of the Application, as amended.
1 j- J 15. In accordance with Annex L to Chapter VIII, at periodic intervals not to exceed 1 l two (2) years, the themal perfomance of the cask must be analyzed to verify
- I that the cask operation has not degraded below that which is licensed *. Following I ,.
the initial acceptance tests, the heat source may be that provided by the decay j heat from the loading of the package, provided that the heat source is equal to
- j at least 25% of the design heat load for the package. Each cask that fails to
- 3 meet the themal acceptance criteria given in Annex L of the Application must be
, :1 withdrawn from service until corrective action can be completed or the license l
1 amended to limit the package to a lower heat load.
1
{ [
- The themal perfomance test is not required at periodic intervals
. , when the maximum decay heat load per package does not exceed 25% {i '
l l of the design heat load, i l l 16. The package authorized by this certificate is hereby approved for use under the ,
l general license provisions of 10 CFR 671.12. '
l 17. Expiration date: June 30, 1985.
l
)l l
!I i
!I i.l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _* _
_____,___,__,,,.,y,_m_ _ . - , ~ . . _ , . . _ - - , , _ , . _ _ . , _ . , . _ , . , . . , . . , , . . . , _ . , . . . _ . , - _ . . . . - . _ , . . . _ _ , , _ _ _ . _ _ _ _ . _ _ , , , . . , . . _ _ , . . - _ - . . ~ .
m a a m m a a a a m m a.w e e n a m m m a m a * ,a = m = = + + + ^
- m a n a a a a m mea a m m
. CONDITIONS (contunued)
Page 5 - Certificate No. 9015 - Revision No. 8 - Docket No. 71-9015 REFERENCES Transnuclear Inc. application dated April 9,1980.
Supplements dated: October 31,1980; June 17,1981; May 3, and 27,1983; and May 1, 1984.
FOR THE U.S. NUCLEAR REGULATORY COMMISSION
-- /)
Char es . acDonald, Chier ~
Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS Dated: MAY 181984 i
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Transportation Certification Branch o -
Ap)roval Record Model Nos. T1-8 and TN-8L packages Docket No. 71-9015 By application dated May 1,1984, Transnuclear. Inc. requested a revision to Certification of Compliance No. 9015 regarding the perfomance of periodic themal evaluation tests of the package.
The Certificate of Compliance requires at least 25% of the design heat load for the package. Each of the Model No. TN-8 series packagings procured by the applicant were themally tested at the fabricator at .
heat loads of 75 percent or greater of the design heat load.
The applicant proposes that the periodic evaluation of the thennal
.perfomance not be perfomed when the heat load of the fuel to be transported is less than 25% of the licensed design heat load of 35.5 kw. The test shall be perfomed prior to the transport of fuel having a total heat load of more than 25% of the design heat load (8.8 kw) if 2 years or more have elapsed. since the previous test.
The requested change to the periodic test requirements has no impact upon the containment capability, structural integrity, heat rejection capability, shielding effectiveness or criticality control of the Model No. TN-8 series packagings. It should be noted that internal cavity wall temperatures are monitored and recorded following each loading and prior to unloading of all packages. Any gross deviation frun predicted temperatures will be evaluated to detemine the cause.
The NRC staff agrees that for limited heat loads (25% or less of rated capacity), periodic themal tests are not of great significance and can be deleted as a requirement.
e Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, WSS Date: MAY 181984 s
- - - _ - - , . - . , - _ - - - . .-- - .-_m ,y --, v. m - -,