ML20114B769
| ML20114B769 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/24/1985 |
| From: | Maupin M VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | CONCERNED CITIZENS OF LOUISA COUNTY |
| References | |
| CON-#185-276 OLA-1, NUDOCS 8501290492 | |
| Download: ML20114B769 (49) | |
Text
N RELATED CORRESPONDENCE
. .g January 24, 1985 UNITED STATES OF AMERICA E?
g NUCLEAR REGULATORY COMMISSION ,
DJ BEFORE THE ATOMIC 'In 20 A!() gg SAFETY AND LICENSING BOARD y,,,
'UW In the Matter of )
)
VIRGINIA ELECTRIC AND POWER )
d Docket Nos. 50-338/339 OLA-1 COMPANY )
)
(North Anna Power Station, )
Units 1 and 2) )
APPLICANT'S RESPONSE TO CONCERNED CITIZENS OF LOUISA COUNTY REQUEST FOR PRODUCTION AND INTERROGATORIES TO VEPCO I.
Answers and Objections to Interrogatories Applicant Virginia Electric and Power Company (the Company),
pursuant to 10 C.F.R. S2.740b, submits the following answers and objections to Concerned Citizens of Louisa County Request For Production and Interrogatories to VEPCO. The provision of these answers should not be deemed an admission that the Company considers the information relevant to the issues in this proceeding.
The Company's objections are as fcllows:
Subpart D of interrogatories 1 through 11 and 13 asks the Company in each case to identify all persons, other than the person answering the question, "who have the expert knowledge required to answer the question." In each case,' answering the question would require identifying and listing a large number of people, and so the Company objects to these questions on the 8501290492 850124 PDR ADOCK 05000338 G PDR
ground that preparing the answer would be oppressive and unduly burdensome.
Subpart B of interrogatories 1 throug'h 11 and 13 asks the Company in each case to identify the documents " relied upon as the basis for the answer," and Subpart C of each such interrogatory then asks the Company to' identify all other documents in its possession that " pertain to the subject matter of the question." The Company has answered each Subpart B below.
Moreover, the Company will produce for CCLC's inspection and copying documents responsive to both Subparts B and Subparts C.
In these circumstances, the Company objects to preparing written answers to Subparts C on the ground that preparing such answers would be oppressive and unduly burdensome. Compliance with the requests in Subparts C would require the Company to examine carefully each document it plans to produce for CCLC's inspection and copying and determine whether it should be listed. This would result in the listing of hundreds of documents. The Company believes that since CCLC will have an opportunity to review the documents, it should decide for itself whether they pertain to the subject matter of a particular question.
The interrogatories and the Company's answers are as follows:
Question 1: ,
Please supply the following information for each of the four commercial reactors (i.e., Surry 1 & 2, North Anna 1 & 2) operated by VEPCO:
1.a. How many assemblies are contained ~in a full core?
-- i A. Provide the direct answer to the question. ,
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B. Identify all documents and studies, and the particular parts -
thereof, relied upon as the basis for the answer.
This answer is common knowledge among the Company's nuclear personnel and consultants.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
See Answer 1.a.B.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
Marvin L. Smith. With respect to the knowledge of other Company employees and consultants, see Answer 1.a.B.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search.
No 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 person.
Marvin L. Smith if necessary. Mr. Smith's qualifications will be produced with the other documents that the Company produces in response to CCLC's December 15, 1984 Request for Production (the Company Documents) .
1.b. Set forth the refueling history and the future refueling 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.
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A. Provide the direct answer to the question.
The refueling history for all four (4) Company nuclear units is shown in Table A-1, which, along with the other tables referred to in this Answer, will be produced with the Company Documents and clearly marked. This table reflects the actual operation of all cycles completed to date. The number of assemblies replaced for each completed cycle is given in Table A-2. Table A-3 provides the actual accumulated batch /sub-batch burnups for the assemblies irradiated during these past cycles.
The projected refueling schedule for all four (4) Company nuclear units is given in Fuel Management Scheme (FMS) o 25B-Rev 1 and is provided as Ta'le A-4. FMS-25B contains the projected number of assemblies to be replaced as well as projected batch /sub-batch burnups.
The FMS is used as a planning and budgeting tool and provides a best estimate of projected fuel loads. The actual number of assemblies loaded for each cycle may vary from the FMS due to actual plant operation and the results of detailed nuclear calculations which determine the final fuel loading. Such is the case for North Anna 1 Cycle 6 and North Anna 2 Cycle 5. FMS-25B shows sixty-eight (68) assemblies of 3.6 weight percent U235 being loaded into each cycle whereas the actual number of fuel assamblies to be loaded into each cycle will be sixty-four (64) assemblies of
c which thirty-six (36) are 3.6 weight percent U235 and twenty-eight (28) are 3.8 weight percent U235.
In addition, the Company is also preparing to change its nuclear units to an extended burnup management strategy which will result in batch average discharge burnups on the order of 43,000 - 45,000 MWD /MTU. This burnup range is based on equilibrium cycle fresh fuel loadings of fifty-two (52) assemblies at Surry and sixty-four (64) at North Anna.
Implementation of this strategy will reduce the future total spent fuel output from the Company's nuclear units by.a few hundred ' assemblies over the life of the plants versus the current fuel management strategy. FMS-25B does not currently reflect this strategy.
B. Identify all documents and studies and the particular parts thereof, relied upon as the basis for the answer.
See the Tables described in Answer 1.b.A.
C.- Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
The documents described in Answer 1.b.A. are the most authoritative documents pertaining to the question. Other documents that will be produced with the Company Documents include or reference some or all of this information.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
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D. Dziadosz. Other persons who have the knowledge required to answer the question include M. L. Smith and R. M.
Berryman.
'E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search..
EPRI and DOE are sponsoring programs on core design and extended fuel burnup. The Company is not performing such research, but, in the ordinary course of business, it will be finalizing the orders for new fuel assemblies to be used in future refaeling cycles and evaluating-schedules for-refueling outages based on the operating and fuel performance of its Surry and North Anna units.
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.
M. L. Smith, if necessary.
1.c. Describe the fuel used in the reactor including vendor, as-sembly dimensions (including weight) , and degree of enrich-ment. If this data has changed since the reactor was first licensed, please explain.
A. Provide the direct answer to the question.
For North Anna:
The fuel rods in a fuel assembly are arranged in a square
-array with 17 rod locations per side. Two hundred and sixty-four rods, 24 guide thimble tubes and one instrumentation thimble' tube are arranged within a sup-porting structure to form a fuel assembly. The instrumenta-tion thimble is located in the center position and provides a channel for _ insertion of. an incore neutron detector if the
fuel assembly is located in an instrumented core position.
The guide thimbles provide channels for the insertion of either a rod cluster control assembly, a neutron source as-sembly, a burnable poison assembly or a plugging device, depending on the position of the particular fuel assembly in the core. Each fuel assembly is installed vertically in the reactor vessel an'd stands upright on the lower core plate.
The fuel rods consist of uranium dioxide ceramic pellets which are contained in slightly cold-worked Zircaloy-4 tubing that is plugged and seal-welded at the ends to encapsulate the pellets. The fuel pellets are right circular cylinders which consist of slightly enriched uranium dioxide powder that has been compacted by cold pressing and then sintered to the required density.
Numerical values of key parameters are listed below.
For Surry:
The fuel rods in a fuel assembly are arranged in a square array with 15 rod locations per-side. Of the total possible 225 rod locations par assembly, 20 are occupied by guide tubes for the control rods and burnable poison rods, and one central thimble is reserved for incore instrumentation. The remaining 204 locations contain fuel rods. In addition to fuel rods, a fuel assembly also includes a top nozzle, a bottom nozzle and seven grid assemblies. The 21 guide
m thimbles, in conjunction with the grid assemblies and the top and bottom nozzles, comprise the basic structure of the fuel-assembly.
The top and bottom ends of the guide thimbles are attached to the top and bottom nozzles, respectively. The grid assemblies are fastened to the guide thimbles at each location along the height of the fuel assembly at which lateral. support for the fuel rods is required. The fuel rods are contained and supported, and the rod-to-rod centerline spacing is maintained along the assembly, within this skeletal framework.
The fuel rods consist of uranium dioxide ceramic pellets contained in slightly cold-worked and partially annealed Zircaloy-4 tubing, which is plugged and seal-welded at the ends to clad the fuel. The fuel pellets are right circular cylinders consisting of slightly enriched uranium dioxide powder, which is compacted by cold pressing and sintering to the required density. Numerical values of key parameters are listed below.
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TABLE A-1 PARAMETER NORTH ANNA SURRY Fuel Vendor Westinghouse Westinghouse Assembly Array 17 x 17 15 x 15 UO Rods
- 264 204 2
Absorber Rods
- 24 20 Instrumentation Tubes 1 1 Assembly Dimensions 8.426" x 8.426" 8.426" x 8.426" U0 2 Weight
- 1154 lbs. 1118 lbs.
- Zircaloy Weight
- 244 lbs. 231 lbs.
Grid Type R L Number of Grids
- 8 7 Fuel Rod O.D. 0.374 inch 0.422 inch Enrichment: Region 1 2.10% 1.85%
Enrichment: Region 2 2.60% 2.55%
Enrichment: Region 3 3.10% 3.10%
- Per Assembly FOOTNOTE TO TABLE A-1 Only one of these parameters has changed since the initial licensing. In order to accommodate longer cycle lifetimes and better-fuel utilization, the enrichment has been increased over the years at both plants. Pr assemblies have enrichments as high as 3.6%.gsently, some Our current 1
Main,LA.P.: " Fuel Management Scheme 25B," Nuclear ~*
Engineering Technical Report No. 429 (Dec' ember 1984); table entitled " Detailed Subbatch Isotopics."
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2-4 operating licenses Permit a maximum enrichment of 4.1%
for both plants.
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"Surry Power Station Units 1 and 2 Technical Specifications," Virginia Electric & Power Co., through Amendment No. 97 (August 1984); paragraph TS 5.4-B.
" North Anna Power Station Unit 1 Technical Specifications,"
Appendix "A" to license No. NPF-4, Issued by the U.S. Nuclear regulatory Commission, through Amendment No. 59 (August 1984);
paragraph TS 5.3.1.
" North Anna Power Station Unit 2 Technical Specifications,"
Appendix "A" to license No. NPF-7, Issued by the U.S. Nuclear Regulatory Commission, through Amendment No. 41 (August 1984);
paragraph TS 5.3.1.
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B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
For North Anna:
- 1. " North Anna Power Station Units 1 & 2 Updated Final Safety Analysis Report," Virginia Electric & Power Company; Chapter 4, Table 4.1-1, and Paragraphs 4.2.1.2 and 4.2.1.2.1.
- 2. " Reference Core Report 17x17," WCAP-8185, Westinghouse Nuclear Energy Systems (December 1973).
For Surry:
- 1. "Surry Power Station Units 1 & 2 Updated Final Safety Analysis Report," Virginia Electric & Power Company; Chapter 3, Tables 3.3-1 and 3.5-1, and Paragraphs 3.5.2.1 and 3.5.2.1.5.
C. Identify.all other documents in VEPCO's possession which pertain to the subject matter of the question.
The documents described in Answer 1.c.B. are the most authoritative documents pertaining to the question. Other documents that will be produced with the Company Documents include or reference some or all of chis information.
D.. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
Dr.-R.-C. Anderson. Many other Company. employees also have the knowledge to answer this question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search.
The Company uses standard Westinghouse 15 x 15 and 17 x 17 fuels. Developmental research for this product goes on continually at Westinghouse.
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.
M. L. Smith, if necessary. If great detail is required, other persons may have to testify, depending on the area of inquiry.
1.d. What is the observed rate of cladding failure for fuel used in the reactor? Please use and describe your own standards for failure.
A. Provide the direct answer to the question.
Since fuel inspections have primarily been performed after cycles with elevated levels of primary coolant activity (greater than a few percent of the Technical Specification limit), the company's data base for assessing clad failure rates is limited, and the estimates of failure rates provided below are conservatively.high.
The Company has inspected six hundred ninety-three (693) assemblies at the Surry Power Station using sipping and ultrasonic examination or a combination of both techniques.
Sipping identifies assemblies which contain failed fuel rods while ultrasonic examination identifies the location of the failed rods within assemblies. Of these 693-assemblies, one hundred ninety (190) were inspected at the end of Surry 1 Cycle 6 and ninety-one (91) were inspected at theEend of Surry 1 Cycle 7, due to the elevated primary coolant activity levels in these cycles. An additional three hundred forty-four (344) assemblies were inspected to support the dry cask storage program and 68 were inspected as part of the DOE high burnup program. Based on these
examinations, the cladding failure rate for Surry fuel rods is estimated to be less than 0.11%.
A total of 347 assemblies have been inspected at the North Anna Power Station using a sipping examination technique.
Of these, one hundred eighty-five were inspected at the end of North Anna 1 Cycle 4 and one hundred sixty-two at the end of North Anna 2 Cycle 3, due to the elevated coolant activi-ties during these cycles. Based on these examinations, the cladding failure rate for North Anna fuel rods is estimated to be less than 0.04%.
Fuel rod failure is defined as any full perforation of the cladding. Perforations of the cladding are detectable by sipping or ultrasonic inspection techniques.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. "Surry Fuel Sipping Report - February-April 1983",
Nuclear Assurance Corporation, James Viebrock, dated June 1983.
- 2. " Work Report No. 905-547.22 BAl2, Project No. 905 BSN 23, Final Report FFRDS NPP Surry - 1", Brown Boveri Reaktor GMBH, dated May 1983.
- 3. "Surry Unit 1, Cycle 6 Failed Fuel Working Group Final Report", Westinghouse Electric Corporation, G. R. Kilp, dated July 1984.
- 4. " Ultrasonic Testing of Surry Power Station Spent Fuel July 30 through August 30, 1984", Babcock & Wilcox Com-pany.
- 5. K. H. Tarantino (General Electric) to W. R. Benthall (Vepco), " Vacuum Fuel Sipping Operation at North Anna I Nuclear Power Station" dated November 1, 1984.
- 6. K. H. Tarantino (General Electric) to W. R. Benthall (Vepco), " Vacuum Fuel Sipping Operation at North Anna II Nuclear / Power Station" dated November 2, 1984.
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- 7. NE Technical Report No. 280, "Surry Fuel Sipping Program February - March 1983, Phase A", N. P.
Wolfhope, dated March 1983.
- 8. NE Technical Report No. 292, "Surry Fuel Sipping Program, Phase B (Batch 8)", N. P. Wolfhope, dated May 1983.
- 9. NE Technical Report No. 303, "Surry Fuel Sipping Program, Phase C", N. P. Wolfhope, dated May 1983.
- 10. NE Technical Report No. 383, " North' Anna.1, EOC-4 Phase "A" Sipping", E. V. Moore, dated July 1984.
- 11. NE Technical Report No. 393, " North Anna 1, EOC-4 Phase "B" Sipping", N. P. Wolfhope, dated September 1984.
- 12. NE Technical Report No. 406, " North Anna 1, EOC-4 Phase "C" Sipping", N. P. Wolfhope, dated September 1984.
- 13. NE Technical Report No. 408, " North Anna 2, EOC-3 Sip-ping", N. P. Wolfhope, dated December 1984.
- 14. NE Technical Report No. 418, "Surry 1, EOC-7 Fipping",
E. V. Moore, dated December 1984.
- 15. Safety Methods Calculation Note SM-303, " Estimation of Cladding Failure Rates at Surry and North Anna", N. P.
Wolfhope, dated January 1985.-
- 16. NE Technical Report No. 253, "Surry Fuel Sipping-Program - January, February 1982", N. P. Wolfhope, dated September 1984.
- 17. -Nuclear Assurance Corporation Report NAC C-8208, "Surry Fuel Sipping Report, January - February 1982", James Viebrock, dated March 1982.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
The documents cited in Answer 1.d.B provide all the details of fuel examinations which have been-conducted at Surry and North Anna-by the Company. Other documents that will be produced with the Company Documents include or reference some or all of this information.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate the respective portions answered by each. In addition, identify
i all other VEPCO employees or consultants who have the expert knowledge required to answer the question.
N. P. Wolfhope. This information could also have been provided by others, including K. L. Basehore and E. V.
Moore.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search.
An ANS working group is currently studying the problem of identifying the number of defects within a given core based on the level of the primary coolant activity and the partic-ular isotopes found within the coolant.
F. Identify the employee (s) or consultants (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.
N. P. Wolfhope, if necessary. Mr. Wolfhope's qualifications will be produced with the Company Documents.
Question 2 Please supply the following information for each of the spent fuel storage pools at Surry and North Anna:
2.a. As currently configured, what is the maximum storage capacity for the pool? Please specify the storage capacity of the cask loading area.
A. Provide the direct answer to the question.
The current maximum storage capacity of the Surry 1 and 2 spent fuel pool is 1044 fuel assemblies. The current maximum storage capacity of the North Anna 1 and 2 pool is 966 fuel assemblies. The storage capacity of the cask loading areas at both Surry and North Anna fuel pools is zero fuel assemblies.
1 B. Identify all documents and studies, and the particular parts l thereof, relied upon as the basis for the answer. l
- 1. Surry Power Station Unit Nos. 1 and 2 Updated Final Safety Analysis Report (UFSAR), Section 9.12
- 2. North Anna Power Station Unit Nos. 1 and 2 Updated Final Safety Analysis Report (UFSAR), Section 9.1 C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
The storage capacities of the spent fuel pools are mentioned in many Company memoranda and studies concerning the Companys' spent fuel storage options that will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
H. Stephen McKay. Many other Company employees have knowledge on this subject and could have provided a response to this question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search.
No.
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.
M. L. Smith, if necessary.
2.b. What is the maximum capacity permitted by VEPCO's license for the plant?
A. Provide the direct answer to the question.
The maximum spent fuel storage pool capacity permitted by the Surry 1 and 2 operating licenses is 1044 fuel assemblies. The maximum spent fuel storage pool capacity permitted by the North Anna 1 and 2 operating licenses is 1737 fuel assemblies (recently amended from 966 fuel assemblies) .
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for this answer.
- 1. Surry Power Station Unit Nos. 1 and 2 Technical Specifications, Section 5.4
- 2. North Anna Power Station Unit Ncs. 1 and 2 Technical Specifications, 5.6
- 3. Amendment Nos. 61 and 45 to the North Anna Power Station Unit Nos. 1 and 2 Technical Specifications dated December 21, 1984.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
The storage capacities of the spent-fuel pools are mentioned.
in many memoranda and studies'concerning.the Company's spent fuel storage options that will be produced with the Company Documents.
. D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
H. Stephen McKay. Many other Company employees have knowledge on this subject and_could have provided'a response to this question.
E. Explain'whether VEPCO is aware of any ongoing or planned' research bearing on the question.* Please identify such re-search.
No.
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.
M. L. Smith, if necessary.
2.c. How many spent fuel assemblies are now stored in the pool?
A. Provide-the direct answer to the question.
As of January 9, 1985:
Surry Power Station 825 North Anna Power Station 425 B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. Memorandum from W. L. Stewart to Distribution, entitled
" Outage Schedule Forecast 1985 - 1987", dated January 4, 1985.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
The number of spent fuel assemblies in the spent fuel pools is mentioned in many memcranda that will be produced with the Company Documents..
D. Identify the person providing the answer to the que,stion.
If more than one person answered the question, ind:scate the respective portions answered by each. In addition, identify all other VEPCO employees or consultants who have';he expert knowledge required to answer the question.
H. Stephen McKay. Many other Company employees have knowledge on this subject and could have provided a response to this question.
.E. Explain whether_VEPCO is aware of any ongoing or planned research bearing on this question.- Please identify such-research.
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No.
E. 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.
M. L. Smith, if necessary.
Question
- 3. Has VEPCO undertaken any in-house or external studies of the possibility of expanding its spent fuel storage capacity at Surry or North Anna? This question excludes VEPCO's 1982 application to the Nuclear Regulatory Commission for approval of a dry-cask storage facility at Surry, but includes 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.
A. Provide the direct answer to the question.
Yes.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. "Surry Fuel Pool Study", Stone and Webster Engineering 1981.
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- 2. "A Study of the VEPCO Interim Spent Fuel Storage Program", Vepco E&C, Feb. 1983.
- 3. " Independent Spent Fuel Storage Installation - A Near Term Solution to Our Spent Fuel Storage Dilemma," Stone and Webster, presented at ANS Annual Meeting June 8-13, 1980.
- 4. " Study Estimate - Independent Spent Fuel Storage Installation (ISFSI) Surry 1 & 2", stone and Webster, March 9, 1982.
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- 5. "A Preliminary Assessment of Alternative Dry Storage Methods For the Storage of Commercial Spent Fuel", E.R.
Johnson Associates, November 1981.
- 6. "Vepco Spent Fuel Disposition Alternatives Study",
EBASCO Services, 1979.
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- 7. " Dry Cask ISFSI Subsurface Investigation and Foundation Report", Bechtel, August 1982. )
- 8. " Spent Fuel Storage Using Dry Casks At Surry Power Sta-tion - Preliminary Engineering", Bechtel, March 1982.
- 9. " Spent Fuel Storage Options Overview", conference held in Savannah, Georgia 9/26 - 9/29, 1982.
- 10. "Surry Power Station - Wet Pool Independent Spent Fuel Storage Installation", Gilbert Associates, 1984.
- 11. " Cost Comparisons for Onsite Spent Fuel Storage Options", EPRI NP-3380, May 1984.
- 12. " Annual Technical Review - Commercial Spent Fuel Management Program", October 1984.
- 13. " Annual Technical Review - Commercial Spent Fuel Management Program", October 1983.
- 14. " Review of Proposed Dry Storage Concepts Using Probablistic Risk Assessment", EPRI NP-3365 Final Report, February 1984.
- 15. " Engineering and Safety Features of Modular Vault Dry Storage", Paper by GEC Energy System Limited.
- 16. " Cost Comparisons For Onsite Spent Fuel Storage Options", EPRI NP-3380 Final Report, May 1984.
- 17. " Foreign Programs For the Storage of Spent Nuclear Power Plant Fuels, High Level Waste Canisters and Transuranic Wastes", PNL-5089, April 1984.
- 18. " Payment Changes Fo'r Federal Interim Storage of Spent Nuclear Fuel From Civilian Nuclear Power Plants in the TTitited States", DOE /S-0022, July 1983.
.' 19. " Federal Interim Storage Fee Study for Civilian Spent Nuclear Fuel: A Technical and Economic Analysis",
DOE /S-0023, July 1983.
- 20. " Spent Fuel Storage Requirements", DOE-RL-84-1, May 1984.
21.- " Proceedings of the 1983 Civilian Radioactive Waste Management Information Meeting", CONF-831217, February 1984.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
c._ ._ _ _ _ _
m This subject matter is discussed in many documents that will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
H. Stephen McKay. Many other Company employees have knowledge on this subject and could have provided a response to all or part of this question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search.
The. Company is aware of the following research programs on the expanded use of spent fuel pools and other types of new storage.
- 1. All of the programs under the DOE. Commercial Spent Fuel Management Program,
- a. The company's dry cask Cooperative Agreement Program.
- b. Carolina Power and Light's_ dry concrete-silo Cooperative Agreement Program.
- c. Rod consolidation programs at TVA and Northeast Utilities.
- d. GE/ Morris REA dry cask test program.
- e. TVA cask. testing program.
-f. NFS, West Valley transportable dry storage cask program.
- 2. Dry cask research is also ongoing in the following countries: Federal Republic of Germany, France, .
Switzerland, United Kingdom, Canada, Japan, and the Soviet Union.
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.
M. L. Smith, if necessary. If details are required with respect to the structural capacity of the Surry pool, H. S.
McKay, whose qualifications are included with the Company Documents.
Question:
- 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.
A. Provide the direct answer to the question.
The Company's position on " full core reserve" was explained
.in an affidavit submitted to the Licensing _ Board by the Company on December 22, 1982 (see Question 14) . To summarize, maintaining a " full core reserve" is considered prudent utility management practice for economic reasons.
Certain maintenance and. repair activities.at Surry can, as stated in the referenced affidavit, require removal of all spent fuel from the reactor to the spent fuel pool. If the Company had to unload a full core at Surry and was unable to do so, an extended outage would be required at Surry, L.
resulting in replace nent power costs of several hundred thousand dollars per day.
The NRC has issued a proposed rule (10 CFR Part 53) that discusses maintenance of full core reserve. The proposed rule states " Commission policy has been to permit continued operation at licensed reactor facilities where less than full core reserve is maintained because such operation does 1
not constitute an undue risk to the health and safety of the public. While a full core reserve capability is not an NRC safety requirement, the Commission has recognized that the maintenance of a full core reserve would be a prudent management practice on the part of the reactor operator.
This proposed rule also states "A recent Department of Energy study on spent fuel storage estimated that if full core reserve were needed and not available, it would result in 50-90 days of reactor shut down and loss of power. The cost to a utility's customers of an unscheduled outage is often in excess of $500,000 per day in replacement. power costs alone. In addition to the potentially high costs of operating without full core reserve, a statistical evaluation of full core removals from nuclear power plants indicates that a full core discharge would be expected to occur about once every three years."
The Company has operated Surry in the past without full core reserve while the project to rerack . the Surry spent fuel pool was being ' completed, and if no option to loss of full core reserve were available, the Company would plan to
l operate without full core reserve again unless an outage ;
occurred which required a full core discharge. However, the ;
Company believes that it is important to maintain full core reserve to avoid the potential for an extended, expensive outage.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. Affidavit of Marvin L. Smith to the Licensing Board dated December 21, 1982.
- 2. Proposed Nuclear Regulatory Commission rule 10 CFR Part 53, Criteria and Procedures for Determining the Adequacy of Available Spent Nuclear Fuel Storage Capacity.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
The Company has not performed formal studies on whether full core reserve should be maintained; however, many memoranda and studies that will be produced with the Company Documents deal with when full core reserve will be lost and with plans to implement additional spent fuel storage options to maintain full core reserve.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
M. L. Smith. Many other Company employees have knowledge on this subject and could have provided a response to this question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search.
~.
s
e The Company is advised that NRC issued on January 8, 1985, the final version of 10 C.F.R. Part 53. We are not aware of any other ongoing research in the area of whether utilities should maintain full core reserve.
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.
M. L. Smith, if necessary.
Question 5:
The following questions relate to VEPCO's application to the NRC for authority to construct a dry-cask storage facility 4
at Surry.
5.a. What is the status of VEPCO's application?
A. Provide the direct answer to the question.
The application for a dry cask Independent Spent Fuel Storage Installation (ISFSI) was submitted to the NRC in October 1982. The NRC has sent the Company a total of 54 e
formal questions of which 47 have been answered. The answers to the remaining 7 questions will be forwarded to the NRC during February 1985. The Company is also in the process of updating the ISFSI Safety Analysis Report (SAR)
- : and Environmental Report (ER) to incorporate the information forwarded to the NRC to answer their requests for additional information; this effort should be completed by April 1, 1985. The Company has chosen the GNS Castor V/21 cask as the lead cask for facility licensing. GNS' Topical Report review by the NRC has been completed, and GNS is presently updating its Topical Report to incorporate the information m.
requested by NRC. The GNS Topical Report update will be completed by February 1, 1985.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. The documents produced in response to Question 5.e.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
This subject matter is mentioned in many documents that will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
H. Stephen McKay. M. L. Smith also has the kncwledge required to answer the question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such re-search.
No.
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.
M. L. Smith, if necessary.
, 5.b. What is the planned capacity of the facility?
A. Provide the direct answer to the question.
Surry Units 1 and 2 refueling estimates current at the time the License Application was prepared indicated that a total of 82 casks, each holding 24 assemblies, could be needed at the Surry ISFSI. Various factors affecting Surry spent fuel disposition could result in fewer than 82 casks ultimately
e being needed. The design basis for the ISFSI, and its sup-porting calculations, is for a full complement of 84 casks.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer,
- 1. Surry Power Station ISFSI License Application, Safety Analysis Report and Environmental Report.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
This subject matter is mentioned in many Company documents that will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
H. Stephen McKay. M. L. Smith also has the 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 re-search.
No.
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.
M. L. Smith, if necessary.
5.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 description of all construction activities that are now underway, or that have been completed.
A. Provide the direct answer to the question.
The Company estimates'that the construction of the concrete mat and security facilities will take seven months. This i
period could be extended by bad weather. The Company
,e-e v.
estimates that the delivery time for dry casks is from 10 to 12 months. As of January 9, 1985, the only construction
- activities which had been completed were the taking of subsoil samples (borings) for use in facility engineering.
Performance of any other construction activities without NRC approval would be grounds for denial of a license under 10 C.F.R. Part 72.31 (b) . The Company plans to request permission from NRC to begin construction after NRC issues its Environmental Assessment.
' B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. ISFSI Project Schedule
- 2. Code of Federal Regulations, Title 10 Part 72.31(b)
C. Identify all other documents in.VEPCO's possession which pertain to the subject matter of the question.
This subject matter is mentioned in other documents that will be produced with the Company Documents.
D. Identify the person providing the_ answer to the question.
If more than one person answered the question, indicate 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.
H. Stephen McKay. M. L. Smith also has the 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 re-search.
n No.
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.
M. L. Smith, if necessary.
w
5.d. Please provide a copy of all documents in VEPCO's possession pertaining to the economic or technical feasibility of dry cask storage of spent fuel.
See Part II, Request for Production 5.e. Please provide a copy.of all correspondence between VEPCO and NRC pertaining to dry, cask storage of spent fuel.
See Part-II, Request for Production Question 6: '
Has VEPCO performed studies of the economic costs of spent
-fuel transportation? If so, please provide copies.
A. -Provide the direct answer to the question.
Yes B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. " Spent Fuel Disposition Alternatives Study For VEPCO,"
Ebasco Engineering, PC., dated March 1980, Appendix B.
2 .- Memo, D. R. Fishback to John Austin, " Comparison of Intrasystem Shipping Cost Estimates," March 22, 1982.
3.. " Report on Assistance in Procurement of Spent Fuel Shipping _ Cask and Service," Nuclear Audit and Testing Company, Inc., March 30, 1982.
=4. ' Memo,-H. H. Barker to M.-L. Smith, "Surry to North Anna Spent Fuel. Transportation Costs," October 19, 1982.
- 5. Memo,.M. L. Smith to D. R. Fishback, "Information Requested on Spent Fuel Handling and Reracking Cost,"'
- November 12, 1982.
- 6. Memo,iH. H. Barker to M. L. Smith, " Budget Status of Spent Fuel' Transportation Costs and Comments'on Draft Interim Spent Fuel Storage Plan Study," February 10, l' 1983.
C. Identify all other documents in VEPCO's possession which i- pertain to the subject matter of the question.
( Other documents that pertain to the subject matter of.this
< question will be produced with the Company Documents.
D. Identify the person providing the answer _to'the question.
If more than one person answered the question, indicate the i'
(
L
respective portions answered by each. In addition, identify all other VEPCO employees or consultants who have the expert knowledge required to answer the question.
Brian H. Wakeman. Other Company employees who have the knowledge to answer all or part of this question include M.
L. Smith and Dennis Fishback.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such research.
No 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.
M. L. Smith, if necessary.
Question 7:
Has VEPCO performed studies of the human health and environmental effects of spent fuel transportation? If so, please provide copies.
A. Provide the direct answer to the question.
Yes.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. "Surry Power Station Units 1 & 2, Applicant's Environmental Report," Supplement Volume 1, pages 239 through 261.
.T
- 2. " North-Anna Power Station Units 1, 2, 3, & 4, Applicant's Environmental Report," Supplemental Volume 1, pages 5-36 through 5-50.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
Other documents that pertain ~ to the subject matter of this question will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
Brian H. Wakeman .
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such research.
The Company is aware of an ongoing project being conducted for the Virginia Department of Emergency Services by the Virginia Polytechnic Institute and State University on the routing of spent fuel from Surry to North Anna.
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 Company has not determined who, if anyone, will testify on the subject matter of this question.
Question 8:
Has VEPCO examined the proposed Surry-to-North Anna transportation route (s) to identify population centers, safe havens, traffic levels, road hazards, or environmentally sensitive areas (such as drinking water supplies) ? If so, please provide copies of documents pertaining to such examinations.
A. Provide the direct answer to the question.
In preparing its application for route approval under 10 CFR 73.37, the Company examined the proposed transportation routes several times to identify route mileages, travel times, safe havens, food and fuel stops, governmental boundaries and potential road hazards.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. 10 CFR 73.37
- 2. Memo, B. H. Wakeman to H. H. Barker, " Transshipment Routes and Route Concerns," August 7, 1980.
u
e
- 3. Letter, R. H. Leasburg to R. F. Burnett, " Spent Fuel Shipping Route Approval," July 13, 1982.
- 4. " Spent Fuel Transportation Routing Plan For Transshipment From Surry Nuclear Power Station Units 1 and 2 to North Anna Nuclear Power Station Units 1 and 2," June 1982.
4
- 5. Letter, T. S. Sherr to R. H. Leasburg, July 28, 1982
- 6. Letter, R. F. Burnett to R. H. Leasburg, October 20, 1982 C.- Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
Other-documents that pertain to the subject matter of this question will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate-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.
Brian H. Wakeman.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such research.
The Company is aware of an ongoing project being conducted for the Virginia Department of Emergency Services by the Virginia Polytechnic Institute and' State University.on the routing of spent . fuel from Surry to North Anna.
F. Identify the employee ('s) or consultant (s) , -if any, whom VEPCO intends to have testify on the subject matterof the question. Provide a statement of the qualifications of such persons.
B. H. Wakeman, if necessary. Mr. Wakeman's qualifications will be produced with the Company Documents.
Question-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 micht be' expected to respond in the event of an accident? If so, please provide copies of all pertinent documents.
A. Provide the direct answer to the question.
No. In 1982 and 1983, however, the Company worked with all 19 counties and cities through which the proposed routes pass to develop a seminar for emergency response personnel on spent fuel transportation accidents. The Virginia Department of Emergency Services was also involved in review of the seminar. Since its development, the Company has arranged for the following governmental entities to sponsor this seminar for their fire, police and rescue personnel.
City of Hopewell Prince George County Henrico County Chesterfield County Mineral Fire Department Personnel from the following state agencies, counties or cities attended one of the above seminars.
Virginia State Police Virginia Department of Emergency Services City of Petersburg City of Colonial Heights Sussex County Surry County Dinwiddie County City of Emporia B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. Memo, E. Munsey to G. G. Seigler, October 21, 1982
- 2. Letter, W. L. Stewart to Addressees, November 23, 1982
- 3. Memo, B. H. Wakeman to Distribution, December 9, 1982
- 4. Memo, W. R. Benthall to Distribution, February 28, 1983
- 5. Letter, R. H. Leasburg to Addressees, April 8, 1983
_34
- 6. Memo, B. H. Wakeman to H. H. Barker, August 9, 1983
-7. Course Text including:
Radioactive Materials Transportation Information and-Incident Guidance, DOT /RSPA/MTB-81/4, US Department of Transportation, 1981.
Emergency Planning and Response for Transportation of Radioactive Materials, Nuclear Transportation Group, April 1983.
Guidance for Developing State and Local Radiological Emergency Response Plans and Preparedness for Transportation Accidents, FEMA-/ REP-5, Federal Emergency Management Agency, March 1983.
8.- Course script.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
The Company does not know of any such documents.
D. Identify the person providing the answer to the question.-
If more than one person answered the question, indicate 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.
Brian H. Wakeman.. H. H. Barker also has the knowledge required to answer this question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such'
-research.
The Company is aware of-an. ongoing project being conducted for the Virginia Department of Emergency Services by-the Virginia Polytechnic Institute.and State University on the routing of spent. fuel from Surry to North Anna.
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.
B. H. Wakeman,'if necessary.
+
Question 10:
Please identify the shipping casks that VEPCO plans to use to transport spent fuel from Surry to North Anna. Have any defects or safety hazards ever been associated with these casks? If so, please explain.
A. Provide the direct answer to the question.
The shipping cask is Model No. TN-8L, NRC Certificate of Compliance No. 9015, Revision 8, dated May 18, 1984. Two of these casks are licensed and owned by Transnuclear, Inc.,
White Plains, New York. The Company has registered with the Nuclear Regulatory Commission under 10 CFR 71.12 as a user of this cask. Questions were raised by the Sierra Club about cask shipment of failed fuel, but these issues have been resolved by NRC. With this exception, the Company is not aware of any defects or safety hazards having been associated with these two casks or the cask model.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. TN-8 and TN-9 Safety Analysis Report, Vols. 1 and 2, April 8, 1980
- 2. Letter, K. Goldmann to C. E. MacDonald, October 31, 1980
- 3. TN-8 and TN-9 Safety Analysis Report, Addendum for the TN-8L Packaging
- 4. Letter, K. Goldmann to C. E. MacDonald, June 17, 1981
- 5. Letter, K. Goldmann to C. E. MacDonald, May 3, 1983
- 6. Letter, K. Goldmann to C. E. MacDonald, May 27, 1983
- 7. Letter, C. E. MacDonald to K. Goldmann, June 3, 1983
- 8. Letter, G. T. Tjersland to W. N. Thomas, August 9, 1983
- 9. Letter, C. E. MacDonald to Addressees, April 13, 1984
- 10. Letter, C. E. MacDonald to K. Goldmann, May 18, 1984
2*
- 11. Letter, C. E. MacDonald to W. L. Stewart, May 29, 1984
- 12. 10 CFR 71 C. IdentifyallotherdocumentsinVEPCb'spossessionwhich pertain to the subject matter of the question.
Other documents that pertain to the subject matter of this question will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
Brian H. Wakeman. Kurt Goldmann also has the knowledge necessary to answer this question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such research.
No. .
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.
M. L. Smith, if necessary, with respect to the identity of the casks. Kurt Goldmann, if necessary, with respect to the absence of defects and safety hazards.
Question 11:
Is VEPCO aware of analyses of what'would happen to a spent fuel cask if it were involved in a transportation accident
'(including a fire) ? If so, please-provide copies of all pertinent documents.
~~
.A. Provide _the direct answer to-the-question.
As part of the ' Safety Analysis Report .(SAR) for the TN-8L shipping cask, several accidents, including an engulfing
-fire, are examined. To confirm cask damage predictions,-a half-scale cask was subjected to testing by the Franklin L
+
l Institute, and the results are also contained in the SAR. j l
In addition, DOE and NRC have commissioned several studies ,
in the past on accident scenarios, accident frequency and potential cask damage from transportation acciden'ts.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. TN-8 and TN-9 Safety Analysis Report, April 8, 1980
- 2. Transportation Technology Quick Reference File, TTC-0049 May 1981
- 3. Protection Provided Against Severe Accident or Sabotage Events During Transportation, W. R. Lahs, undated
- 4. Executive Summary, Safety Issues in the Transportation of Radioactive Materials, Drs. J. C. Courtney and E. N.
Lambremont, February 1984
- 5. NUREG-0170, Final Environment Statement on the Transportation of Radioactive Materials by Air and Other Modes, December 1977 C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
Other documents that pertain to the subject matter of this question will be produced with the company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
Brian H. Wakeman. M. L. Smith and H. S. McKay also have knowledge required to answer this question.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such research.
The Company is aware of an ongoing project being conducted by the Nuclear Regulatory Commission entitled, "The Modal Study of Transportation Safety."
r e
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 Company has not decided who, if anyone, will testify on the subject matter of this question.
Question 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.
See Part II, Request for Production Question 13:
Is it 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.
A. Provide the direct answer to the question.
It is the Company's position that sabotage or diversion do not present a significant threat to human health or the environment. A recent NRC study, described in the Federal Register, Vol. 49, No. 112, June 6, 1984, pp 23867-23872, supports this position.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. 10 CFR 73.37
- 2. Federal Register, Vol. 49, No. 112, June 6, 1984, pp 23867-23872.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
Other documents that pertain to the subject matter of this question will be produced with the Company Documents.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate the respective portions answered by each. In addition, identify
4 all other VEPCO employees or consultants who have the expert knowledge required to answer the question.
Brian H. Wakeman. Other employees with the knowledge required to answer this question include M. L. Smith.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such research, No.
9 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 Company has not decided who, if anyone, will testify on the subject matter of this question. ,
Question 14:
In an affidavit dated December 21, 1982 and submitted to the Licensing Board by VEPCO on December 22, 1982, Marvin 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.
A. Provide the direct answer to the question.
.The basis for determining the " windows" for shipment was explained in the subject affidavit. To summarize, the vindows are established based on the planned refueling schedules for the North Anna and Surry Power Stations. The number of spent fuel assemblies scheduled for shipment from Surry to North Anna is planned on a schedule that will avoid the loss of full core reserve at Surry. Shipments will also be planned when possible on a schedule that will avoid making shipments when a refueling outege'is planned at Surry or North Anna for the reasons indicated in the subject m
_40 D'
affidavit. In addition, the Company would prefer to avoid shipments during the winter when weather conditions could result in delays and increased costs. g, Similar shipping " windows" have been identified for the future. Based on current fuel management plans, the company expects to lose full core reserve at Surry by approximately 58 fuel assemblies during the refueling outage scheduled at Surry Unit 1 for May 25, 1986. The Company will thus need to remove at least this number of fuel assemblies from Surry prior to the outage to avoid the loss of full core reserve.
As part of a Cooperative Agreement Program with DOE, the Company may be able to remove part or all of the 58 spent fuel assemblies from the Surry spent fuel pool for storage in dry spent fuel storage casks prior to this date. The spent fuel that can be stored in dry storage casks depends-on both the schedule for shipping spent fuel to a federal site.for testing as well as on the licensing of the construction of a dry storage cask Independent Spent Fuel Storage Installation at Surry (see Answer 5). If the Company were assured of being able to place at least 58 >
spent fuel assemblies into dry storage by May 25, if)6, the plans to ship spent fuel to North Anna would be deferred or cancelled. However, if the removal of spent fuel for dry storage cannot be assured, the Company will need to ship some or all of these fuel assemblies to North Anna prior to the Surry Unit 1 outage in May 1986. Based on the present refueling outage schedules, the Company would need to
41-complete these shipments by the end of 1985. The " window" for these fuel shipments would thus be between July 1, 1985 and December 20, 1985.
B. Identify all documents and studies, and the particular parts thereof, relied upon as the basis for the answer.
- 1. Affidavit of Marvin L. Smith.to the Licensing Beard dated December 21, 1982.
- 2. Memorandum from W. L. Stewart to Distribution, entitled
" Outage Schedule Forecast 1985-1987," dated January 4, 1985.
- 3. Memorandum from D. Dziadosz to M. L. Smith entitled,
" Estimation of Spent Fuel Pool Inventory", dated January 8, 1985.
C. Identify all other documents in VEPCO's possession which pertain to the subject matter of the question.
Fuel Management Plans and refueling outages schedules are routinely created by the Company to reflect current plans in this area. The Company has a number of these plans and schedules, and memoranda which discuss these schedules. The answer to the question is based on the most recent information available.
D. Identify the person providing the answer to the question.
If more than one person answered the question, indicate 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.
M. L. Smith. Other Company employees with the knowledge required to answer part or all of the question include: R.
M. Berryman, H. S. McKay, and D. Dziadosz.
E. Explain whether VEPCO is aware of any ongoing or planned research bearing on the question. Please identify such research.
There is no ongoing research on this question. In the ordinary course of business, the company will be finalizing the order for the new fuel assemblies to be used in future
refueling cycles and evaluating schedules for refueling outages based on the operating and fuel performance of its Surry and North Anna units.
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.
M. L. Smith, if necessary.
II.
Request for Production With the exception of the documents requested by CCLC pursuant to its Interrogatory 5.d., documents requested by CCLC or requested to be identified will be made available for inspection and copying by CCLC at the offices of Hunton &
Williams, 707 East Main Street, Richmond Virginia. Counsel for the Company and CCLC are currently discussing whether it is necessary for the Company to produce the documents requested in Interrogatory 5.d.
Respectfully submitted, l
VIRGINIA ELECTRIC AND POWER COMPANY Uk By /s/ Michael W. Maupin Michael W. Maupin, Counsel Of Counsel Michael W. Maupin Marcia R. Gelman HUNTON & WILLIAMS P.O. Box 1535 l Richmond, Virginia 23212 Dated: January 24, 1985 t __
@TEC n.. .. q%
UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION -1(;y\-
'O'i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD dI!'gg A'$
In the Matter of ) '!<
) ~ lOj[1h[,jf VIRGINIA ELECTRIC AND POWER COMPANY ) Docket Nos. 50-338/339-OLA-1
)
(North Anna Power Station, )
Units 1 and 2) )
AFFIDAVIT OF ROSS C. ANDERSON City of Richmond )
) ss Commonwealth of Virginia )
Ross C. Anderson, being duly sworn according to law, deposes and says that he is Engineer, Virginia Electric and Power Company, and that the answers to Interrogatory 1.c. , contained in Appli-cant's Response tx) Concerned Citizens of Louisa County Request for Production and Interrogatories to Vepco are true and correct to the best of his information, knowledge and belief.
. :Y m j hiL) { . k,w/3.!w)
Ross C. Anderson Sworn to and subscribed to ,
before me this & day of January.1985.
d ((L M
~
L l hi Notary Pubric
- My Commission expires ' Bb j /t. / hk 1
F O
getATED CORR UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,
~~
l gg' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD *gg w\'y A?OS In the Matter of )
VIRGINIA ELECTRIC AND POWER COMPANY Docket Nos. 50-338/339-OkN141 s
- C:
y (North Anna Power Station, )
Units 1 and 2) )
AFFIDAVIT OF DAVID DZIADOSZ City of Richmond )
) ss Commonwealth of Virginia )
David Dziadosz, being duly sworn according to law, deposes and says that he is Supervisor Nuclear Engineering, Virginia Elec-tric and Power Company, and that the answers to Interrogatory 1.b., contained in Applicant's Response to Concerned Citizens of Louisa County Request for Production and Interrogatories to Vepco are true and correct to the best of his information, knowledge and belief.
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. David Otiadoszgf/ cp Sworn to and subscrfbed to before me this & day of January 1985.
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Notary Public My Commission expires dNe > xb r V4(c. / 9 ff.
I
ft!!ULTED CORRESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION E,,qp BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Jn 28 mo gg In the Matter of )
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VIRGINIA ELECTRIC AND POWER COMPANY ) Docket Nos. 50-338/339-OLA-1
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(North Anna Power Station, )
Units 1 and 2) )
AFFIDAVIT OF H. STEPHEN MCKAY City of Richmond )
) ss Commonwealth of Virginia )
H. Stephen McKay, being duly sworn according to law, deposes and says that he is Senior Staff Engineer, Virginia Electric and Power Company, and that the answers to Interrogatories 2.a., 2.b.,
2.c., 3, 5.a., 5.b., 5.c., contained in Applicant's Response to Concerned Citizens of Louisa County Request for Production and Interrogatories to Vepco are true and correct to the best of his information, knowledge and belief.
H. StyhenMcKay Sworn to and subscribed to before me this J/6k day of January 1985.
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Notary.Public L[(fY My Commission expires Odid[( M bth)& /'l87
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NTED CORRENChWJQ UNITED STATES OF AMERICA : .3 y ,
NUCLEAR REGULATORY COMMISSION Uf'
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'8 g ,.
In the Matter of )
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- c. w VIRGINIA ELECTRIC AND POWER COMPANY ) Docket Nos. 50-338/339-OLA-1
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(North Anna Power Station,. )
Units 1 and 2) )
AFFIDAVIT OF MARVIN L. SMITH City of Richmond )
) ss Commonwealth of Virginia )
Marvin L. Smith, being duly sworn according to law, deposes and says that he is Supervisor Nuclear Engineering, Virginia Elec-tric and Power Company, and that the answers to Inte'rrogatories 1.a., 4 and 14, contained in Applicant's Response to Concerned Citizens of Louisa County Request for Production and Interroga-tories to Vepco are true and correct to the best of his informa-tion, knowledge and belief.
y Y n Marvin L. Smith Sworn to and subscribed to before me this @ day of January 1985..
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Notary Publi~c fl My Commission expires bittrLd1Lil c'J/o /f(( .
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w AtLATto copp UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,
.:.R BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
"> 09 2d A!0 :20 In the Matter of )
VIRGINIA ELECTRIC AND POWER COMPANY ) Docket Nd . d 338/339-OLA-1
)
(North Anna Power Station, )
Units.1 and 2) )
AFFIDAVIT OF BRIAN H. WAKEMAN City of Richmond )
) ss Commonwealth of Virginia )
Brian H. Wakeman, being duly sworn according-to law, deposes and says that he is Engineer, Virginia Electric and Power Company, and that the answers to Interrogatories 6, 7, 8, 9, 10 and 11 contained in Applicant's Response to Concerned Citizens of Louisa County Request for Production and Interrogatories to Vepco are-true and correct to the best of his information, knowledge and belief.
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Brian H. Wakeman Sworn to and subscrped to before me'this Ol> day of
' January 1985.
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. ( dbb Notary Public My Commission expires 1/Mul:#/ /h M' ..
, k LATED CORREN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION. a-rr BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,j o o to nt In the Matter of ) ,y q
) ,; s 5E9v v VIRGINIA ELECTRIC AND POWER COMPANY ) Docket Nos". 50-338/339-OLA-1
)
(North Anna Power Station, )
Units 1 and 2) )
AFFIDAVIT OF NORMAN P. WOLFHOPE City of Richmond )
) ss Commonwealth of Virginia )
Norman P. Wolfhope, being duly sworn according to law, de-poses and says that he is Senior Staff Engineer, Virginia 31ec-tric and Power Company, and that the answers to Interrogatory 1.d., contained in Applicant's Response to Concerned Citizens of Louisa County Request for Production and Interrogatories to Vepco are true and correct to the best of his information, knowledge and belief.
L_ R wm Norman P. Wolfhope '
Sworn to and subscribed to before me this M day of January 1985.
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//O /LL Notary Public f bl My Commission expires dirAIlb ble./I(( . -
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CERTIFICATE OF SERVICE WELATED CORRESPONW I hereby certify that I have this date served Applicant's Response to Concerned Citizens of Louisa County Request For Production And Interrogatories to Vepco upon each of the persons named below by depositing a copy in the United State mail, properly stamped and addressed to him at the address set out with his name:
Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief Docketing and Service Section Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George A. Ferguson School of Engineering Howard University 2300 5th Street Washington, D.C. 20059 Henry J. McGurren, Esq.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James B. Dougherty, Esq.
3045 Porter Street, NW
. Washington, D.C. 20008 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 6t/ MM
' Dated: January 24, 1985 By /s/ Michael W. Maupin Michael W. Maupin, Counsel for Virginia Electric and Power Company
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