ML20101D034

Request for Production & Interrogatories to Util Re Spent Fuel Pool.Certificate of Svc Encl.Related Correspondence

ML20101D034
Person / Time
Site:	North Anna
Issue date:	12/15/1984
From:	Jay Dougherty CONCERNED CITIZENS OF LOUISA COUNTY
To:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML20101D036	List: ML20101D034 ML20101D037 ML20101D042
References
CON-#484-726 OLA-1, NUDOCS 8412210280
Download: ML20101D034 (7)

Text

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99.b.

RELATED CORRESrvNoENCE

CCLC, 12/15/84 C 2!.[H.,EC UNITED STATES OF AMERICA 04 CC19 Ay gg NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 302iil'

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In the Matter of

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)

Docket Nos.

VIRGINIA ELECTRIC AND POWER CO.

)

50-338 OLA-1

)

50-339 OLA-1 (North Anna Power Station,

)

Units 1 and 2)

)

)

)

CONCERNED CITIZENS OF LOUISA COUNTY REQUEST FOR PRODUCTION AND INTERROGATORIES TO VEPCO Pursuant to 10 CFR S 2.740b, Intervenor Concerned Citizens of Louisa County requests that the following interrogatories.be answered fully, in writing and under oath, by one or more offi-cers or employees of Virginia' Electric and Power Company (VEPCO) who has personal knowledge thererof of, or is the closest to having personal knowledge thererof.

The interrogatories impose upon VEPCO a continuing obligation.

If, after answering a ques-tion, additional pertinent information comes to the attention of VEPCO, its employees or consultants, the previous answer should be amended.

Each question is to be answered in six parts, as follows:

A.

Provide the direct answer to the question.

B.

Identify all documents and studies, and the l$k2gggfo$o g

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particular parts

thererof, relied upon as the basis for the answer.

C.

Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.

D.

Identify the person providing the answer to the question.. If more than one person answered the question, indi-cate the respective portions answered by each.

In addition, identify all other VEPCO employees or consultants who have the expert knowledge required to answer the question.

E.

Explain whether VEPCO is aware of any ongoing or planned research bearing on the question.

Please identify such research.

F.

Identify the employee (s) or consultant (s), if any, whom VEPCO intends to have testify on the subject matter of the question.

Provide a statement of the qualifications of such persons.

The term document is to be construed broadly to include all writings, whether handwritten or not.

It includes documents from all sources, including those which were not prepared by or for VEPCO, as well as those which were intended only for limited distribution, e.g.,

memos to the file and telecon notes.

It also includes graphs, charts, and drawings of every kind.

Question 1.

Please supply the following information for each of the four commercial reactors (i.e., Surry 1 & 2, North Anna 1 l

& 2) operated by VEPCO:

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How many assemblies are contained in a full core?

b.

Set forth the refueling history and the future refuel-ing schedule for the reactor, including the number of assemblies replaced, or scheduled for, replacement.

Please include in the answer a description of the burnup rates to which the fuel was, or will be, subjected. -

c.

Describe the fuel used in the reactor including vendor, assembly dimensions (including weight), and degree of enrichment.

If this data has changed since the reactor was first licensed, please explain.

d.

What is the observed rate of cladding failure for fuel used in the reactor?

Please use and describe your own standards for failure.

2.

Please supply the following information for each of the spent fuel storage pools at Surry and North Anna:

a.

As currently configured, what is the maximum stor-age capacity for the pool?

Please specify the storage capacity of the cask loading area.

b.

What is the maximum capacity permitted by VEPCO's license for the plant?

c.

How many spent fuel assemblies are now stored in the pool?

3.

Has VEPCO undertaken any in-house or external studies of the possibility of expanding its spent fuel storage capacity

i at Surry or North Anna?

This question excludes VEPCO's 1982 application to the Nuclear Regulatory Commission for approval of a dry-cask storage f acility at Surr,y, but includes any study of (1) other kinds of new storage facilities and (2) expanded use of the existing spent fuel pools, such as but not limited to more closely-spaced poison racks, double-tiering of racks, and " pin consolidation" or "densification."

Please provide copies of the pertinent documents.

4.

Is it VEPCO's position that it is important (for any reason) to maintain a " full core reserve" in its spent fuel pools?

If so, please explain and provide copies of all pertinent documents, whether they support VEPCO's position or not.

5.

The following questions relate to VEPCO's application to the NRC for authority to construct a dry-cask storage facility at Surry.

a.

What is the status of VEPCO's application?

b.

What is the planned capacity of facility?

c.

Summarize the projected construction schedule for the facility, assuming that full NRC approval is received on (1)

February 1, 1985 and (2) August 1,1985.

Please include a de-scription of all construction activities that. are now underway, or that have been completed.

d.

Please prov'ide a copy of all documents in VEPCO's possession pertaining to the economic or technical feasibility of dry cask storage of spent fuel, e.

Please provide a copy of all correspondence be-

5-tween VEPCO and the NRC pertaining to dry cask storage of spent

fuel, i

6.

Has VEPCO performed studies of the economic costs of spent fuel transportation?

If so please provide copies.

7.

Has VEPCO performed studies of the human hecith and i

environmental effects of spent fuel transportation?

If so, please provide copies.

8.

Has VEPCO examined the proposed Surry-to-North Anna transportation route (s) to identify population centers, safe i

havens, traffic levels, road hazards, or environmentally sensi-tive areas (such as drinking water supplies)?

If so, please provide copies of documents pertaining to such examinations.

9.

Has VEPCO examined the proposed transportation route (s) to determine what kind of emergency response skills and equipment are possessed by the governmental departments and agencies that might be expected to respond in the event of an accident?

If so, please provide copies of all pertinent documents.

10.

Please identify the shipping casks that VEPCO plans to use to transport spent fuel f rom Surry to North Anna.

Have any defects or safety hazards over been associated with these casks?

If so, p. lease explain.

11.

Is VEPCO aware of analyses of what would happen to a 1

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spent fuel cask if it were involved in a transportation accident

.(including a fire)?

If so, please provide copies of all perti-nent documents.

12.

Please provide copies of all documents in VEPCO's possession pertaining to the role of emergency personnel in mitigating the effects of transportation accidents.

13.

Is is VEPCO's position that sabotage or diversion of a spent fuel shipment is not a significant threat to human health or the environment?

If so, please explain and provide copies of pertinent documents.

14.

In an af fidavit dated December 21, 1982 and submitted to the Licensing Board by VEPCO on December 22, 1982, M a r v'in L.

Smith referred to two " windows" during which it was important for VEPCO to make the proposed spent fuel shipments.

Please identify the basis for determining those windows.

Have any similar windows been identified for the future?

If so, please explain how they were determined.

Respectfully submitted, O

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i Gunsel for Concerned Citizens of Louisa County December 15, 1984 3045 Porter St. NW Washington DC 20008 (202)362-7158

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.....n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.g [:119 N1:21 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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)

)

In the Matter of

)

)

Docket Nos.

VIRGINIA ELECTRIC AND POWER CO.

)

50-338 OLA-1

)

50-339 OLA-1 (North Anna Power Station,

)

Units 1 and 2)

)

)

)

CERTIFICATE OF SERVICE I certify that copies of the foregoing CONCERNED CITIZENS OF LOUISA COUNTY REQUEST FOR PRODUCTION AND INTERROGATORIES TO VEPCO were served, this 15st day of December,1984, by deposit in the-United States Mail, First Class, upon the following:

Secretary Sheldon J. Wolfe, Chairman U.S. Nuclear Regulatory Comm'n Atomic Safety & Licensing Board Washington DC 20555 U.S. Nuclear Regulatory Comm'n Washington DC 20555 Dr. Jerry Kline Atomic Safety and Dr. George A. Ferguson Licensing Board School of Engineering O.S. Nuclear Regulatory'Comm'n Howard University Washington DC 20555 2300 5th Street, NW Washington DC 20059 Henry J. McGurren, Esq.

U.S. Nuclear Regulatory Comm'n Washington DC 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comm'n Atomic Safety and Washington DC 20555 Licensing Appeal Board U.S. Nuclear Regulatory Comm'n i

Michael W. Maupin, Esq.

Washington DC 20555 Hunton & Williams

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P.O. Box 1535 Richmond VA 23212 peYf.Dqoghertk/

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