ML20128A557
| ML20128A557 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/21/1985 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#285-196 OLA-1, NUDOCS 8505240258 | |
| Download: ML20128A557 (147) | |
Text
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ORIGINA! _
U h n E D S m .'E S NUCEFAR REGULATORY COMMISSION l(a**, L'g.
IN THE MA1irn Oh: DOCKET NO:
VIRGINIA ELECTRIC & POWER COMPANY 50-338-OLA-1 (NORTH ANNA POWER STATION, UNITS 1 & 2) 50-339-OLA-1
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Q-I.OCATION: CHARL0TTESVILLE,'VA PAGES: 174-292 DATE: MA? .n 1985 0
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ace-FEDERAL REFORTERS, INC.
8505240250 050521 ON
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444 North Capitol 50tet .
PDR ADOCK0500h$30 g T Washington, D.C. 20C01 (202)W-3K0 ,,
. W::lEh . 174 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE Tl!E ATOMIC SAFETY AND LICENSING BOARD 4
5 ---------------------------------X t
6 In the matter of t :'
- Docket Nos 50-338-OLA-1 '
7 VIRGINIA ELECTRIC & POWER COMPANY: 50-339-OLA-1 8 (North Anna Power Station, 9 Units 1 & 2) : .
10 ---------------------------------X 11 U. S. District Court for tho 12 Western District of Virginia Room 300 13 255 West Main Street Charlottosville, Virginia 22903 14 Tuesday, May 21, 1985 15 -
!!aaring in the abovo-ontitled matter was convened ,
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at 9:02 a.m., SIIELDON J. WOLFE, presiding:
17 BEFORE:
18 S!!ELDON J. WOLFE, Chairman 19 Nuclear Regulatory Commission ,
Atomic Safoty and Licensing Board !
20 :
JERRY R. KLINE, Member l 21 Nuclear Regulatory Commission j
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) Atomic Safoty and Licensing Board i 22 GEORGE A. FERGUSON, Member 23 Nuclear Regulatory Commission ,
Atomic Safety and Licensing Board '
24 was.em neport.,,, inc.
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- W21ch -
175 1 APPEARANCES:.
I 2 On behalflof Applicant, Virginia Electric & Power Company:
3 MICHAEL W. MAUPIN, Esquire-
[,k ); MARCEA R. GELMAN, Esquire 4 Hunton & Williams.
800 East' Main Street 5 Richmond, Virginia 6 On behalf' of Intervener, Concerned. Citizens of Louisa County:-
7 JAMES DOUGHERTY, Esquire
-8 3045' Porter Street, N.W.
Washington, D. C., 20008 9
10
. .On behalf of NRC' Staff:
II HENRY J. McGURREN, Esquire
'12 WILLIAM.D. PATON, Esquire
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Office of Executive Legal Director 13 Nuclear Regulatory Commission Washington, D.-C.,-20555 14 15 16 17 18 19 20 21 g
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22 23 24 nee-Federsi nooners, sne.
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176 Suet j C_ O N T,E,N,T,S_
2 Limited Appearance Statements:
l Christine Osmer Page 180 I'} 3 -
4 Carol Frome Page 185 5 Jerry Rosenthal Page 186 6 Fay Rosenthal Page 194 7 Susan Sassano Page 195 8 Rain Zohav Page 196 !
9 Donal Day Page 199 l
- l 10 11 DIRECT CROSS REDIRECT RECROSS BOARD
--~s 12 Paul N. McCreery )
() 13 Joseph M. Pickworth) 217 229 240 Marvin L. Smith 246 253 287 278 i
14 15 EXHIBITS 16 Identified Received 17 Licensee's Exhibit Number 1 207 213 18 Licensee's Exhibit Number 2 208 213 '
Licensee's Exhibit Number 3 208 213 19 Licensee's Exhibit Number 4 209 213 Licensee's Exhibit Number 5 209 213 20 Licensee's Exhibit Number 6 210 213 Licensee's Exhibit Number 7 210 213
,s 21 Licensee's Exhibit Number 8 210 213
( '~') Licensee's Exhibit Number 9 211 213 i 22 Licensee's Exhibit Number 10 211 213 !
Licensee's Exhibit Number 11 211 213 !
23 Licensee's Exhibit Number 12 212 213 Licensee's Exhibit Number 13 212 213 24 Licensee's Exhibit Number 14 212 213 i A*Fwww Rnenm. irc Licensee's Exhibit Number 15 213 213 l 25 l
176-A Su3T j E, X H I B I T ,S, (Continuing) 2 Identified Received j y-'y -3 _ Staff Exhibit Number 1 ~214 216
-\_/ Staff Exhibit Number 2 215 -216 4
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E A.Y_ - I_ N_ S
~6 Testimony of Paul N. McCreery Follows Page 220 7 !
Testimony of Joseph M. Pickworth Follows Page 222 8
Testimony ~of Marvin L. Smith Follows Page 247 i
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Wal 1 177 1 _P _R'O _C E _E _D _I N _G _S I
i (9:02 a.m.)
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(~~3 3 JUDGE WOLFE: The hearing is now in session in V
4 the case of Virginia Electric and Power Company, North 5 Anna Power Station, Units-1 and 2, NRC Docket Nos. 50-338 OLA-1,l r
6 and 50-339 OLA-1. 4 7 Licensee has requested amendment to its operating 8 license permitting the North Anna Power Station to receive 9 and store 500 spent fuel assemblies from the Surry Power t
10 Station. In its Consolidated Contention 1, final form as of 11 January 7, 1985, Intervener, Concerned Citizens of Louisa I-
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, 12 ) County alleges that: The Staff's environmental assessment is
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13 , inadequate and an environmental impact statement should be
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IS The basis for this contention are two-fold: First, 16 ! the environmental assessment did not evaluate the probability
- /' and consequences of accidents occurring during the transpor-10 , tation of spent fuel casts from the Surry Station to the North 19l l Anna Station, which might be occasioned by acts of sabotage f
20 ' or by error of Applicant's employees in preparing the casts e
21,; ;i for shipment.
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22 Second, contrary to the National Environmental 23 ; Policy Act, 41 USC 4332 (2) (E), consideration was not given 24 to the alternative method of constructing a dry cast storage Ace Federd Reporters, Inc.
25 facility at the Surry Station which is feasible, can be effected e i
1 2hWA1; 178 El in a timely manner.- ItLis the least expensive'and safest
=2 method for at 'leasti fifty years, and can be used on or off ,
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) site.
~4 The Board will take evidence upon this consolidated 5 Contention 1 during this proceeding. To.my left is~ Judge 6 George Ferguson,-Engineer, and to my right is Judge Jerry 1
7 'Kline,Jand environmental scientist, and I am Sheldon Wolfe, 8 legal member and Chairman of the Board. j 9 Will counsel for the . parties identify themselves ;
10 .from left to right?
-1Ih MR. McGURREN* Your Honor, my name is Henry J.
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.a 12 4 McGurren, and on my left is William D. Paton. Together we-13 . represent the U. S. Nuclear Regulatory Commission Staff. ,
'14 MR. MAUPIN: My name is Michael W. Maupin, and 15 with me at the table is Marsa'R. Gelman. W'e are lawyers with 16 .the firm of Hunton & Williams, and we represent .the Licensee,
- 7- Virginia Electric-and Power Company.
18 , MR. DOUGHERTY: James Dougherty, for the Inter-F d
19 d vener, Concerned Citizens of Louisa County.
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JUDGE WOLFE: All right. We will take limited L 21 appearance statements, as you are aware between 9:00 a.m.
22 i this morning and 12:00 noon today, but we will proceed with 23 the evidentiary hearing during any lulls in the taking of 24 limited appearance- statements between those hours of 9:00 a.m.
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25 .and'12:00 noon today.
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j Tonight, between 7:00 p.m., and 10:00 p.m., is 7
set aside exclusively to take limited appearance statements. !
F 3- Now, with respect to the limited appearance b statements, oral limited appearance statement will be limited i
4 5 to five minutes each, but written limited appearance statements 6 - may be submitted without limitation on length.
7 These written statements will be forwarded and 8
lodged in the docket room of the_ Nuclear Regulatory Commission 9
in Washington, D. C.
t 10 The limited appearance statement is not presented 11 under oath, and is not evidence. It serves to alert the Board 12 ] and the parties to areas in which evidence need be induced.
O 13 I might add that the Board thinks it best that ja - -- not to respond to any questions that may be posed by a 15 limited appearance individual, because a question may impinge 16 upon something that the Board is considering in this case
- 7 and it would be prejudicial for the Board to respond to such isl,! questions, and would also be inappropriate for the Board to
- 9 " respond to various and sundry questions involved in this i
~20 case that might also be involved in cases pending before other 31 ;, Boards.
O 22 As far as I am aware, no limited appearance 23 individual has written asking, to our Docketing Section in 24 Washington, D. C., that he or she wishes to make a limited h-Federd Reporters, Irm.
25 appearance statement.
1-4-Wil. 180 ; j
! l 1 We would give priority appearance to'anyone who t
2 had so written in-to Washington, D. C.-
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i r'( 3 Several people have signed in on the Register, which
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, 4 is on a small tableLat'the entrance to the courtroom and we 5 will'take them in the order of their identification.
- i 6 All right, we will proceed then if there is
- 7. nothing else at this-time. We will' proceed to take the 8 limited appearance statements. l 9 All right. Christine Osmer?
10 Whereupon, 11 1 1
it 12 6 LIMITED APPEARANCE STATEMENT
^ () 13 OF 14 > CCHRISTINE OSMER J
15 JUDGE WOLFE: Just a moment, please.
16 [ 'If you would care to, you may stand there and give your oral 17 statement, or you may be scated over in the jury box, whichever 18 is your pleasure.
ti 19 " MS. OSMER: Thank you.
20 ' JUDGE WOLFE: All right, Ms. Osmer.
21 f MS. OSMER: I appreciate the opportunity to address 22 this assembly. My name is Molly Osmer. I am a member of the 23 Concerned Citizens of Louisa County.
24 I have given much time and enery to the issue of Am.Federd Reporters, Inc.
25 transporation of highly radioactive nuclear waste. I am sure i
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- -1 y u have heard from many concerned: citizens in the past who 2
have donated their.energie's-t'o nuclear' issues. This is g 3 simply because nuclear issues and specifically that of trucking b .-spent- fuel' is . so' very important.
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5 At this point, I would.like to thank the press 6
and .thentelevision channelsifor helping the public at-large 7
realize the importan'ce of this issue to gain an understanding--
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.of the hazards associated with the shipment of radioactive' i
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.Thank you for keeping.the information dissiminated h-11 and: debate alive.
s 12 ) It has been stated that you cannot seriously i3 [ consider ~ the ' fact that there has .already been 'an accident on'the now approved route,.an accident involving fresh fuel.
11 15 L:An accident that dramatically demonstrated the county and the zi6 li utility's inability to deal'with an accident involving nuclear gr materials.
18 , . It was-two hours after~the truck. turned over before i
19 j - the Office of . Emergency Services in Louisa was notified.
- 20 Fortunately, fresh fuel is not dangerous. As utility spokesmen ya put-it, at least it wasn't spent fuel.
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22 The driver was convicted of reckless driving and 1
23 failing to have a safety check; human error on two counts. l 24 I hear that the accident cannot be seriously Ass-Feder::1 Reporters, Inc.
25 considered because it is a single event not presented in a i
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1-6-W21 182 larger context. A larger context would give us more I 1
2 perspective because it would include statistics of all trucking; i
e~w 3 accidents per mile traveled.
- (vJ-4 I contend that an accident involving spent fuel 5 is more than a statistic to the citizens of Virginia. We i 1
6 cannot afford to have anything higher than zero percent accident 7 per mile. There is no such thing as acceptable risk with 8 spent fuel.
End 1. 9 SusT fols.
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.#2-1-Suet 1 I agree with the logic of evaluating the bigger 2 picture rather than merely the single story. You should 3 evaluate all levels and perspectives involved with this is-
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4 sue. I believe you have not seriously and adequately ad-5 dressed the issues of environmental impact emergency prepared-6 ness, road damage, among others.
7 Why do we continue to narrow the perspective?. To 8 justify a decision? The most important consideration I 9 think is the dry cask storage option, an on-site option 10 that would obviate the need to ship, an option that both 11 utility Tind our environmental group agrees the preferred
~x 12 option, our first choice.
13 It is logical to consider the fact'that we have 14 the less dangerous, more economical solution of dry cask 15 storage close at hand. I suggest that your time and energy 16 would be best utilized in pursuing this option.
17 It is simply not necessary that we expose the 18 citizens of Virginia to the risk of spent fuel. Please do 19 not keep narrowing your perspective for political reasons.
20 Keep the big picture in mind.
~ 21 It's a very important decision; it's yours to
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22 make. You can make an exciting, careful decision or you can 23 make this just the same old story.
24 Thank you very much.
Ace-Federal Reporters, Inc.
25 JUDGE WOLFE: Ms. Osmer, would you clarify this
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- 2-2-S ueT j accident. That was, I think you said, due to the negligence 2
of the truck driver; is that correct?
( ) 3 (The witness nodded in the affirmative.)
4 And who was he -- whose employ was he in; do you 5 know?
6 MS. OSMER: I do not have that information 7
here at this point. I can get it for you.
8 JUDGE WOLFE: Yes. But it was due to his negli-9 gence?
10 MS. OSMER: He was convicted of reckless driv-11 ing.
,_ \ 12 JUDGE WOLFE: Yes. There was no evidence as far N ']
13 as you know that that accident was due to sabotage or due 14 to some error by the Licensee's employees in preparing the 15 fuel for shipment?
16 MS. OSMTR: The safety check of the truck was not 17 adequately addressed.
18 JUDGE WOLFE: I'm sorry.
19 MS. OSMER: There was a safety check failure 20 of the truck itself. But I don't know of any other safety s 21 violations in the preparation of that.
22 JUDGE WOLFE: I take it this was fresh fuel?
23 MS. OSMER: Fresh fuel.
24 JUDGE WOLFE: Rather than spent fuel. Absent Ace-Federal Reporters, Inc.
25 more, I would have to conclude that the Licensee's employees
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- 2-3-Suet. .I were not connected with that shipment. But I don't have 2 any other information on that at this point.
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{ 3 MS. OSMER: I would be happy to get that for I 4 you.
5 JUDGE WOLFE: Yes. Mr. Maupin, if you have any 6 information on that point that I have made inquiry of, would 7 you advise us as soon as you can? Preferably -this afternoon 8 if that's possible, about this matter.
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9 MR. MAUPIN: Yes, sir.
10 JUDGE WOLFE: Thank you, Ms. Osmer.
Il MS. OSMER: Thank you.
.rg 12 (The witness stood aside.)
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13 JUDGE WOLFE: Carol Frome.
14 MS. FROME: My name is Carol Frome. I am a 15 concerned citizen.and resident of Louisa County. I want 16 to thank you for the opportunity to address this assembly.
'INDEX- 17 I want the Nuclear Regulatory Commission to severe 18 its alliance with the nuclear industry and to begin acting i- 19 to preserve and protect the American people.
20 I want the Nuclear Regulatory Commission to admit
, 21 dhat nuclear accidents can happen and have already happened, bq 22 and to consider the costs in human lives and property of a 23 major nuclear , accident before it's too late.
24 I want the Nuclear Regulatory Commission to recog-Asefasersi Moorwes, Inc.
25 nize the safety and environmental issues involved in the
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transport of spent nuclear fuel and in every other stee of 52-4-Suet 2
generating electricity for nuclear power, including day to
,N 3 day management and repair of reactors, handling and transport G
4 of activated fuel, storage and disposal of high level and low 5
level waste, decommissioning and long term disposal of re-6 tired reactors.
7 I want the Nuclear Regulatory Commission to 8
designate responsibility for radiation related cancer and 9 for damage to human lives and property.
10 And this week I want the Nuclear Regulatory Com-11 mission to deny VEPCO licensing to transport spent nuclear 12 fuel, since progress on the dry cask storace option is immi-p_
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13 nent and makes this more risky process unnecessary.
14 Thank you.
15 JUDGE WOLFE: Thank you, Ms. Frome.
16 (The witness stood aside.)
17 JUDGE WOLFE: Jerry Rosenthal.
MR. ROSENTHAL: My name is Jerry Rosenthal. I am 18 19 the curfent President of the Concerned Citizens of Louisa 20 County.
21 I live with my wife and three children in Louisa
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22 County, eighteen miles, one hundred and fifty yards west, southwest of the North Anna Nuclear Power Plant. I want to 23 24 briefly touch on a variety of subjects today which are Ace-Federal Reporters, Inc.
25 directly related to the subject of nuclear waste storage.
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- 2-5-Suet 1 And that is in itself most important, for the I l
2 subject which we discuss here isn't as VEPCO and the NRC Staff l rN 3 want it to be, just this small variety of sub-specialties on v
4 the transport and handling of some of Surry's excess nuclear 5 garbage. What we are discussing is the generic matter of 6 nuclear waste disposal.
7 To be distracted by the leaves and not to see the 8 forest or the eco system is to miss this matter completely.
9 First, I would like to talk about the Nuclear 10 Regulatory Commission itself and our relations with this body.
11 Again, what we talk about is important but so. really important p_ 12 as what we don' t talk about. We won't talk about, real acci-
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13 dents, only accidents on paper or computer simulation. We 14 won't talk about the real accident carrying fresh nuclear fuel 15 on this exact route that VEPCO and the NRC want to see the 16 spent fuel coming down. We won't talk about the real issues 17 of nuclear waste disposal, how the Federal government has 18 failed time and time again to come to any acceptable plan to 19 handle these toxic wastes, how the utilities keep closing 20 their eyes and saying: It's someone else's problem.
21 We won' t talk about the emergency response to
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22 accidents. Again, we won' t say how poorly Louisa County
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23 responded just one year ago when a real nuclear truck acci-l 24 dent occurred.
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25 We won't talk about the routes or the process of
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l l2-6-Suet 1 choosing the routes. We won' t talk about the environmental l I
2 concerns of shipping or handling or storage, because VEPCO I
- ~1 3 and the NRC Staff think that some table made fifteen years 4 ago accurately addresses our real concern.
5 No environmental impact study or discussion. Not 6 one word about the reality of the route, the bridges, the 7 winding roads, the no-passing zones, the Mineral Elementary 8 School, or the possible effects an accident might have on the 9 farms, ground water, or the future of Louisa County and the 10 _ Commonwealth of Virginia.
11 We won't talk about the casks which have never 7_s 12 been physically tested, or the tie downs or the trucks, or 0] 13 who would be responsible in the event of an accident.
14 We won't talk about the insurance subsidized by 15 Ohe government. We won't talk about the fact that trans-16 shipment means moving the fuel twice, once in and hopefully l 17 once out.
18 We won't talk about the extra radiation on the 19 community, the workers, the entire doubling of risks. We i 20 won't talk about these things because the NRC is so short-
~s 21 sighted that the issue must be narrow and clear.
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22 We won't talk about them because the NRC and the 23 industry, despite loud testations to the contrary are friends.
24 Much of the problem can be clearly laid on the steps of the Aar-FederW Reponen, Inc.
25 Federal government. They have taken the authority without
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j -taking!the responsibility.- They fostered' nuclear, power V
.2 without' understanding the technology at all.
3 They believed the so-called experts who said:-
') :Even if thefsolution doesn't exist now, we will have an 5 answer soon.
'6 But the piper has come to call his tune andLthere 7 _are no easy-_ answers.: And the government flounders.
8 At the1same time as a lot of.these problems can 9 be laid at the government's steps, I would like to thank 10 Senator John Warner, Senator. Paul Trible, and Congressman 11 French Slaughter' and their staffs for working with us and
.12 VEPCO and committing.themselves to work to expedite dry cask O'. 13 . storage through . this same body.
14 I hope their voices are being heard and the answer 15 is: iGet on with dry cask now.
16 State government is even in a more embarrassing l l
-17 position. They have no' authority except to carry out the 18 orders from above. The Health Department and subsequently 19 the Office of Emergency Services must choose a route without 20 any alternative except which one. There are ways in which 21 the State could positively respond, by having the Legislature "c) 22 and the State Corporation Commission restrict the blank check 23 that they have given to VEPCO.
24 A lot of the problem lies in that VEPCO has m noo,=., Inc.
1!5 unlimited funds from which they earn profit, even if they
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- 2-8-Suet 1 spend them, given to them by the State. This travesty of 2 justice must stop. VEPCO is using our money with profits
^1 3 to their shareholders to fight us. It's illogical, unpro-4 ductive and ultimately counterproductive.
5 At the same time, the State is blindly led about 6 by the Federal government and VEPCO on high level waste, the 7 issue of low level radioactive waste is lurking in the back-8 ground. We are aware of plans to use Louisa as a dump for 9 low level waste.
10 We shall fight. On the State level, we want to 11 thank Ed Hauck, State Senator, for his support over this
, -.s 12 entire matter. ' Local government is an entirely different
! l 13 story. They were originally rightfully concerned over control 14 over their own roads and land use, protecting their homes, 15 land and businesses.
16 Certain selfish interests, with ties to VEPCO, 17 wanted all along to compromise, to sell out, to give in at i
18 any price. These so-called business interests could see no l t
19 furtter than the end of their pockets and were successfully 20 resisted by caring, farsighted people.
21 A lot of people thought: Well, you can never i
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22 beat them so why try.
23 And in the end, Louisa, VEPCO, through deceit and >
I 24 selfish interests, wore down the good guys and won what we Am-Federal Reporters, Inc.
25 hope was a hollow victory. I need to thank here the former
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)2 19-Suet 1 Chairpersons of the Board, James King and Nancy Wink, and 2 especially the two youngsters on the Louisa Board of 3 Supervisor, -Mac Kursey and Eddie Hottinger, for their fore-4 ' sight and political courage and strength.
END'#2 5 Simon 3 f1ws 6
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I Vepco itself has been a real wonder to deal with.
2 They have their highly paid and professional public relations 3
group. Some of these people are salesmen who will say
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4 anything and do just about anything to get the job done.
5 others are genuinely interested and involved and you can't 6
tell them apart.
7 Vepco has no incentive to be reasonable. With unlimited ratepayer dollars, a Compliance State Corporation 9
Commission and State Legislature millions of dollars in pay-10 roll and tax payments and millions more in advertising, they 11 have always gotten their way.
~~ Now Vepco, or is it Virginia Power or Dominion 13 Resources, well, anyway, this billion dollar business has 14 consistently changed their assumptions, projections and not 15 to mention their name.
16 With hunting and grunting and pushing paper faster 17 than you can read it, they have smothered their opposition 18 in red tape paperwork and buzz words.
19 For the concerned citizens it has been a long, 20 hard road, and it isn' t easy for all of us as volunteers
- to keep up the work. We have battled without money. Where 22 Vepco has admitted to spending over a million dollars, we 23 haven't spent ten thousand. We can't hire the expert witnesses 24 Ace-Federal Repoeters, Irw.
at de hop of a hat, m ry W donars, emy ad ad emy 25 appeal is thought about.
193 Sim 3-2 1 We spend our time both on fund raising and on 2 moving ahead.
3 I want to thank here Willie and Christine, Tommo,
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4 Joyce, Donna, Tayler and Molly and the hundreds of contributors 5 and other workers from all over the County and the State who 6 have worked for a cause and not because they were getting 7 paid.
8 JUDGE WOLFE: Mr. Rosenthal, would you conclude 9 now. You have run over at least two minutes. I gave you 10 a little more time.
11 MR. ROSENTHAL: A special thanks to our Attorney 12 Jim Dougherty. -
i 13 In summary, I urge this body and those in Congress 14 and in positions of power and those in the audience and those 15 at home to help protect my family from t. pointless, needless 16 and dangerous gamble and stop the foolishness before it is 17 too late.
18 Thank you.
19 (Applause.)
20 JUDGE WOLFE: Thank you, Mr. Rosenthal.
21 I didn' t intend when I asked Mr. Maupin to check 22 back on the answers to my questions with respect to Ms. Osmer.
23 Mr. Dougherty, if you have any information that you think 24 the Board should have on this in response to the Baa*d's Ace Federal Reporters, Inc.
25 question, please so advise this afternoon, and I so request
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. Sia 3-3 1 the staff attorneys to likewise advise the Board later this 2 afternoon.
3 All right. Fay Rosenthal.
4 LIMITED APPEARANCE STATEMENT 5 op 6
FAY ROSENTHAL 7 MS. ROSENTHAL: My name is Fay Rosenthal and I 8 live in Louisa County. I just want to say a few things 9
about human error which my husband says I am an expert 10 witness on.
II I would like to believe that human error is not 12 p possible or even not likely. But I look at the news everyday 13 and it is just full of people doing crazy things on purpose Id or by accident.
15 I feel the nuclear power industry was undertaken 16 without adequate foresight and planning. Nobody figured out
'I7 in advance what to do with all the poisenous waste. If that I8 large tremendous issue has never been resolved satisfactorily, I9 I just can't believe that all the minor contingencies have been 20 resolved a hundred percent or even close.
21
, Hindsight isn't going to do any of us much good 22 if there is an error in transshipment, and as a citizen 23 of Louisa County I am worried.
24 Thank you.
Ace 4ederal Reporters, Inc.
25 JUDGE WOLFE: Thank you, Ms. Rosenthal.
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195 Sia 3-4 I Sue Sassano.
2 MS. SASSANO: Good morning.
r 3 JUDGE WOLFE: Would you spell your name, please.
4 MS. SASSANO: s-a-s-s-a-n-o.
5 JUDGE WOLFE: Thank you.
6 LIMITED APPEARANCE STATEMENT 7 OF 8 SUSAN SASSANO 9 MS. SASSANO: I want to say that Jerry Rosenthal ---
10 JUDGE WOLFE: You reside in Gordensville, Virginia; II is that correct?
I2 MS. SASSANO: Right, but in Louisa Coun'ty. That 13 is our Post Office number.
14 Jerry Rosenthal has spoken for me. So I am not 15 going to go over all that, but I do want you to know that 16 I appeared before the AEC on May 1973 in the Louisa County 17 Courthouse to express my concerns on the storage of nuclear 18 waste and the safety of transporting such waste.
I9 on May 1979 I spoke before the Virginia Senate 20 Committee in Richmond and told them of my concerns and how 21 no amount of careful supervision of the storage and trans-22 portation would solve the problems if there is no way to 23 dispose of this waste.
24 Now here it is May 1985. That is 12 years. After Ace 4ederal Reporters, Inc.
25 attending many NRC meetings and writing numerous letters, I
196 im 3-5 I still have these concerns with no answers for a solution, 2 even up to this date.
3 Since there is an alternative of dry cask storage 4 at Surry, I request that you deny issuing Vepco this license 5 for transporting spent fuel from Surry to North Anna.
6 Thank you.
7 JUDGE WOLFE: Thank you.
8 (Applause.)
9 Rain Zohav. Ms. Zohav, your name is spent R-a-i-n, 10 first name, and Z-o-h-a-v, last name?
II MS. ZOHAV: Correct.
12 JUDGE WOLFE: And you reside in Charlottesville, 13 Virginia?
14 MS. ZOHAV: Yes, I do. My two children, however, 15 reside half the time in Louisa County with their f ather. So 16 this is a major concern of mine.
17 LIMITED APPEARANCE STATEMENT 18 OF ,
19 RAIN ZOHAV 20 MS. ZOHAV: First of all, I would like to thank 21 you for taking the time to listen to public opinion. I would 22 hope that you would also take that public opinion into account 23 when you make your decision.
24 In matters of safety it is wise to err on the side Ace-Federal Reporters, Inc.
25 of cuation. It is also wise to listen occasionally just to
t 197 r f *
'813?3-6'. 'l ' common-sense. Common sense tells many of us that. transporting
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_s 2 ~ highly radioactive materials along these little country roads t.
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3 -when there-is another alternative doesn't make sense. And -,
~d,n t. .
4 itlis' also reasonable ' to expect :that waste produced in US fone'plantibe dealt with at that plant.. There is the option 6 .of dry cask storage.and that seems to be the more reasonable 7 way, to take. :
[ ,
-8 Many of us have studied the testing done around
-# 'the transshipment. We' are not convinced that every situation 10 that could'. happen in real life has been accounted for. One II example. of that 'is the time it can withstand high flames and-12 ' heat in a fire. It is only tested for. half an hour, but i :O-.
13 .there are a lot of things on the road that are combustible 14
- x. that,will burn for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
l 15 There are -a lot of situations that just haven' t 16 been dealt with, and' all of us have heard of many unexpected i 17 difficulties'in all-kinds of technical situations where
-18 the experts sit down and say well, we didn' t expect this 8 and we don'.t really know what to do. That is what makes
- us. skeptical of the technology because there are too many 21 unanswered questions.
22 Also, some of us have looked over the emergency l
i.
23 plans and what to do in case of an accident and they seem t
2 sadly lacking. Cordoring off an area isn't going to do much j 25 There just aren't if the radioactivity is somehew released.
i
- . - - _ - _ . . - - - - _ _ . - - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ .a
198 Sim3-7 I those kinds of protections written in for anyone to even 2 use.
3 Mostly I am here as a mother. I would like you 4 to know that I have two children and that I don't believe 5 risking their long-term health and safety or the health 6 and safety of any of our children or of any people makes sense.
7 It doesn' t make sense to think about short-term 8 expediency when you are dealing with such dangerous materials.
9 So I urge you deny the license for transshipment to Vepco.
10 A lot of us who have dealt with Vepco over the Il years have grave reasons to distrust this company. They 12 don' t have a very good record when it comes to safety and m
13 when it comes to letting local officials know when there 14 has been some kind of leak. The folks in Spottsylvania have 15 heard it over the radio rather than from the company itself.
16 When our own supervisors went to tour the plant, 17 their little meters that were on their suits were tampered 18 with. So that in case they got exposed to too high a level I9 of radiation, the buzzer wouldn't go off.
20 This is the kind of company that we know and deal 21 with that maybe on a national level you don't know these 22 incidents that make us distrust the company.
23 It seems as if dry cask storage on site is a much 24 more viable option. So I urge you to deny the license for Aes.d.coi n.pe.n inc.
25 it is unnecessary, expensive and transshipment to Vepco.
+-
Sim 3 58 199 1
most importantly unwise.
2 (Applause.)
3 JUDGE WOLFE: Thank you, Ms. Zohav.
( }
-~'
4 Donal Day. Mr. Day, the Donal is Donald without the last "d"; is that correct?
5 4 MR. DAY: That is correct.
7 JUDGE WOLFE: And you reside in Charlottesville, 8 . Virginia?
9 MR. DAY: Albemarel County.
10 JUDGE WOLFE: Thank you.
11 MR. DAY: Just to repeat all of that, my name 12 is Donal Day and I am a resident of Albemarel County.
I 13 am an experimental physical physicist at the University 14 of Virginia. I am here today to strongly urge you not to 15 grant Virginia Power a license to transship spent fuel 16 from Surry to North Anna.
57 We must ask ourselves what is to be gained by the 18 shipment of spent fuel rods from Surry to North Anna.and 19 who will benefit from this temporary solution to the bigger
. 20 problem of the lack of a national program for the disposal 21 of high level waste? Who benefits from increasing the
\_/
) 22 radioactive inventory at North Anna from two billion curries 23 to four billion curries? Are the analyses of fuel reracking 24 and pin compaction and cask fatigue completely understood he.d I h, ween, inc.
25 to guarantee the safety against equipment failure accidental L
r ..
200 Sim 3-9 I
or deliberate?'
2 Of course the primary consideration in the 3
(~] determination of' this request for a license must'be the v
4 health and safety of the public.
5 Short-term considerations of economics, dividends
~
6 and the narrow concerns of a corporate special interest group 7
must never have the same weight as the interests of the 8 public at large.
What are the consequences of not shipping spent 10
- fuel from Surry? According to the NRC report, NUREG 20,
' dated February 1985, the presently authorized storage capacity 12 at Surry, will be fully utilized in 1987.
I ,)
13 Transshipment not considered, the presently I4 authorized capacity at North Anna will be utilized in 1991.
15 The net gain at the outside then is four years of operation.
16 The shipment of spent fuel is no solution to the II high-level waste problem. In fact, a casual reading of the I8 political winds indicates that a more permanent temporary
- storage solution is necessary before a final depository 20 for high-level nuclear waste is found.
21
. The attractiveness of dry casks over this interim 22 period is that it is the very same technology that will be 23 used for the intermediate storage of spent fuel.
What is the worst possible scenario tha*. would result from not shipping spent fuel from Surry to North Anna?
201 m -0 I First, we lose our optimistic four years of 2 operation of the Surry plants.
3 Virginians'uso approximately one and a half 4 quadrillion BTUs of energy of all forms per year. The 5 nation uses approximately 70 quadrillion BTUs.
0 Since the turn on of Surry 1 and 2 in early 1973, 7 they have produced a tot.al of 95 megawatt hours of 8 electricity. Or including the energy loss and production 9 of that electricity, there are approximately 300 megawatt 10 hours of power. That is about 25 megawatt hours per year.
II
. If we convert that 25 megawatt hours to quadrillion 12 BTUs, it is a fraction of one percent of the total energy 13 consumed by Virginians. It is a slightly -larger fraction Id of one porcent of the total energy consumed in Virginia 15 for the production of electricity. It is an insignificant 16 part of the energy mix in Virginia.
I7 The Surry plant constitutes only 13 percent of 18 Virginia Power's electrical production capacity, which is I9 nearly two times as large as the average power demand on 20 their. system. Virginia Power in its greatest demand period 21 r has an overcapacity for production of electricity, as does 22 the neighboring utility systems from which power can 23 be purchased.
24 Aca.deroi n. pore.rs, ine.
Wm a u m d dat in de wat can 25 scenario of no transshipment of' spent fu61; Virginians
202 l Sia 3-11 l l
l j will feel no energy crunch. Remember that in 1980 and '81 l 2 the Surry plants were completely out of operation for the
- 3 replacement of steam generators.
l )
4 -Virginians can do without the Surry power plants 5 and still have a vital and growing economy. Obviously the 6 loss of production from an investment of a half a billion 7 dollars is not an attractive one for the owners of the planc.
8 They would of course try to corrale the pubic to pay for 9 their predicament. That is obviously the subject of another 10 hearing before another agency.
11 This worst case scenario does not have to come 12 about. Dry cask storage on site at Surry is an obvious
_) 13 solution to the predicament. Storage takes place at the 14 point of origin, the storage is more secure and more tolerant 15 of accidents and dry casks do not require the continual flow 16 of water to carry away the tremendous amounts of heat 17 generated by residual reactions in the spent fuel assemblies, 18 and megacuries of electricity is kept off our highways.
19 Before closing, I would like to say a word 20 about the potential for sabotage of these shipments and the 21 sabotage of the pools at North Anna where they might be j 22 stored.
23 Usually when the public, and if one reads the 24 regulations of the NRC, when one considers sabotage the Ace-Federal Reporters, Inc.
25 specter of a terrorist attack comes to mind complete with
3-12 203 1 commando-like raids by a well-armed and well-organized 2 group bent on destruction or blackmail of the United States.
3 The response to this notion, the beyond design
,J 4 changes that reduce the design-basis threat, would include 5 military training for plant security and the issuance of 6 automatic anti-personnel weapons.
i end Sim 7 Joa fols 8
9 10 11 12 i
V 13 14 15 16 17 18 19 20 21 m
i 1 im' 22 23 24 Ace-Federal Reporters, Inc.
25
i 4-1-Wal 204 1 Of course, force cannot overcome suicide attacks by airplanes on a truck or a spent fuel cooling area, nor l 2
i
/~T 3 do the regulations effectively reduce the potential for v
4 internal sabotage. The internal threat of an insider, 5 including an employee. i 6 Examination of Licensee Event Report she" that 7 the number of, ' employee problems' has been increasing in 8 recent years, and consequently the inside threat is increasing.!
9 Obvious procedural methods, design and hardware can contribute 10 to prevent the insider threat, but as an example of an insider 11 threat, I only remind you of a few years ago at Surry the t
12 l very same plant from which the shipments of spent fuel are to
()
s "
13 originate, two workers were'able to pour corrosive chemicals 14 on a fuel storage pool, damaging some of the fuel assemblies.
15 When coming forward, they suggested that their 16 demonstration was to point out the lack of internal security
- 7 at the plant. This demonstration cost them their jobs and 18 : cost VEPCO some face with the public.
0 19 .
However, the sabotage of spent fuel rods contain f
20 l an immense inventory of poisonous materials as something that i
, 21 ) will mean the loss of confidence in VEPCO by the public. It
(_/ i 22 l would mean the loss of life, livelihood, and would present a a
P 23 i! a cruel legacy of our foolishness to the future.
11 -
24 In conclusion, the consequences of not shipping
.b Federd Reporters, Inc.
25 are not as great as the owners of the plant would like us to
4-2-Wn1 205 1
believe.
2 There exist alternatives to shipment of spent
(~T 3 fuel, namely dry cast storage, which is more in keeping with A.)
4 the long path of the eventual solution to the high level waste 5 Problem of the United States.
6 No probabilistic risk analysis cranked out by 7 a piece of cilicen can ever protect the public from the 8 sabotage of hits shipment of spent fuel by a disgruntled'and 9 determined insider. I urge you to refuse this request for 10 a license to transport spent fuel from Surry to North Anna.
+
11 Thank you very much.
12 (APPl ause.) ,
) JUDGE WOLFE: Are there any other individuals in 13 :
14 L the audience who wish to make a limited appearance statement 15 at this time who have not signed in?
16 - (No response.)
ry All right. We will now proceed -- as we indicated --
18 ' during any lulls in the taking of limited appearance statements,-
19 we'will proceed with the evidentiary hearing.
20 Would counsel approach the bench, please?
- 21. . (Off the record bench discussion ensues.)
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22 All right. We will proceed with the evidentiary 23 portion of the hearing. The~first thing, Mr. Maupin, do you 24 have some exhibits that you wish to have marked for identifi-Am-FWwd Rgartws. lts 25 cation and offered into evidence. ;
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'4--3-Wnl 206 l
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1 MR. MAUPIN: .Yes, sir. I think you will recall, 2 Judge Wolfe,'that on March 19, 1985, the Board issued an 3 Order requesting the parties to consult and see if they'could 4 agree on their respective exhibits and to advise the Board-5 as to what'those exhibits were and whether any party had any 6 objection to the admissibility. of any exhibit. ,
4 7 You asked us to do that by.May 3rd. That date i
8 was subsequently extended to May.9, 1985.
{.
9 On May 9th, on behalf of all three of the parties, :
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10 I- sent.you a ' joint list of exhibits and it might' be appropriate ['
i 11 and -- as that letter was disclosed, there was no objection 12t h ~ to the" admissibility of the exhibits.
'O.. ! >
134 I propose I go ahead and discuss on the record 14 ' Licensee's exhibits and move their admission into evidence.
End 4. 15 .
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207
- 5-1-Suet ; MR. .MAUPIN: The Licensee's first exhibit is a document consisting of 76 pages with five attachments. It 2
( 3 is entitled " Virginia Electric and Power Company, Surry LJ Power Station, Unit Number 1 and 2, Shipping of Spent Fuel 4
5 TN-8L Shipping Cask Loading and Handling Procedures."
6 I propose that this document be marked as 7
Licensee's Exhibit 1 for identification.
I am g ing t hand the court reporter three copies 8
9 of that document.
JUDGE WOLFE: All right.
10 jj (The document referred to is marked 12 as Licensee's Exhibit Number 1 for IN XX 13 identification.)
VOICE: Would you permit me to interrupt? Someone 14 15 has set off the duress alarm. Could we check the duress 16 alarm here? l JUDGE WOLFE: Certainly. We will stand in recess 17 18 for a few minutes.
19 (Short recess.)
1 JUDGE WOLFE: All right, Mr. Maupin. l 20 1
21 MR. MAUPIN: The second document consists of 75 pages and five attachments. But the record ought to show 22 that the first page is numbered Page 2 of 76. The cover page 23 24 apparently is not attached. And the last page of the document Ace-Federal Reporters, Inc.
25 prior to the attachment is 76 of 76.
208 l5-2-Suet j It is entitled " Virginia Electric and Power Company, 2
North Anna Power Station, Unit 1 and 2, Receipt and Storage s , 3 f Spent Fuel, TN-8L Shipping Cask Unloading and Handling v
4 Procedures."
5 I Propose that this document be marked as Licensee's 6 Exhibit 2 for identification. And I will give the court 7
reporter three copies, i
8 JUDGE WOLFE: All right. So marked.
9 (The document referred to is marked 10 as Licensee Exhibit Number 2 for INDEX 11 identification.)
a 12 MR. MAUPIN: The third document consists of 99
/s )
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13 Pages, printed front and back, and two additional unnumbered 14 pages.
15 It is entitled "An Assessment of the Safety of 16 Spent Fuel Transportation in Urban Environs."
17 The upper left-hand corner it has a reference jg that begins Sandia Report; that's S-a-n-d-i-a. That is 19 followed by SAND 82-2365.TTC-0398. ;
20 IProposethatthisdocumentbemarkedasLicensee'sf
< 21 Exhibit 3 for identification.
( )
'^'
22 JUDGE WOLFE: So marked.
I 23 (The document referred to is marked ;
l 24 as Licensee's Exhibit Number 3 for hFeder1 Reporters, Inc.
I 25 identification.)
f
e-209
- 5-3-Suet j MR. MAUPIN: I then have a series of photographs.
2 I will propose that we put an independent number on each.
(~'; 3 The first is a colored photograph, roughly 8x11.
t <
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4 And I will describe it as cask arriving at the power station.
5 In the upper right-hand corner it has a sticker with the let-6 ter A on it.
7 And I propose that this photograph be marked for 8
identification as Licensee's Exhibit 4.
9 JUDGE WOLFE: So marked.
10 (The photograph referred to is marked 11 as Licensee's Exhibit Number 4 for INDEXX 12 identification.)
l >
!' '/
MR. MAUPIN: And I will provide three copies of 13 14 each of these photographs to the reporter.
15 .
The second photograph -- let me say, all of these 16 are in color and all are roughly the same size.
17 The second photograph I will describe as front of trunnion with tie down and impact limitator. It has a l 18 l i 19 capital B in the upper right-hand corner, and it should be ;
I 20 marked for identification as Liccensee's Exhibit 5. l 1
21 JUDGE WOLFE: So marked.
I i
'# (The photograph referred to is 22 23 marked as Licensee's Exhibit Number ,
INDEX 24 5 for identification.)
Am-FederJ Ceporters, Inc.
25 MR. MAUPIN: The next photograph is described as
n . . -
-210 45-4-Suet 1 shock absorbing rear cover, rear trunnion, impact limitator, 2 'and rear tie down. And it is marked capital C and should be
{} 3 marked for identification as Licensee's Exhibit 6.
4 JUDGE WOLFE: So marked.
4 5 (The photograph referred to is marked
'6 as Licensee's Exhibit Number 6 for NDEXX 7 identification.)
8 MR. MAUPIN: The'next photograph I will describe 9 as cask on power station, cask handling crane. It has a 10 capital D in the upper right-hand corner and should be marked
. ,11 as Licensee's Exhibit 7.
.,- 12 JUDGE WOLFE: So marked.
(/
13 (The photograph referred to is marked 14 as Licensee's Exhibit Number 7 for 15 identification.)
16 MR. MAUPIN: The next photograph is described 17 loosening lead bolts at AGNS, and using capital.A penetration 18 to vent air.
19 This photograph i's now marked as' Exhibit E and 20 should be marked for identification as Licensee's Exhibit 8.
21 JUDGE WOLFE: So marked.
22 (The photograph referred to is marked 23 as Licensee's Exhibit Number 8 for 24 identification.)
Ass-Feder:1 Reporters, Inc.
25 'MR. MAUPIN: The next photograph is described as
211
- 5-5-Suet 1 cask with skirt at HENS. It is now marked with a capital F 2 and should be marked for identification as Licensee's Exhibit f~') 3 9.
LJ 4 JUDGE WOLFE: So marked.
5 (The photograph referred to is marked 6 as Licensee's Exhibit Number 9 for INDEX 7 identification.)
8 MR. MAUPIN: The next photograph is described as 9 lowering cask into station pool. It's marked with a capital 10 G and should be marked for identification as Licensee's Exhibit 11 10.
~
73 12 JUDGE WOLFE: So marked.
\] I 13 (The photograph referred to is marked 14 as Licensee's Exhibit Number 10 for 15 identification.)
16 MR. MAUPIN: The next photograph is described as 17 cask in station pool, lead steel on. It's marked now with a i
18 capital H, which should be marked for identification as 19 Licensee's Exhibit 11. i i
20 JUDGE WOLFE: So marked. I 21 (The photograph referred to is marked 7
V 22 as Licensee's Exhibit Number 11 for 23 identification.) l i
24 MR. MAUPIN: The next photograph is described as -
Ace-Federj Reporters, Inc.
25 cask in station decontamination area, templet ready for bolt
212
- 5-6-Suet 1 tightening. It's marked with a capital I and should be 2 marked for identification as Licensee Exhibit 12.
l ') 3 JUDGE WOLFE: So marked.
4 (The photograph referred to is marked 5 as Licensae Exhibit Number 12 for 6 identification.)
7 MR. MAUPIN: The next photograph is described as 8 vacuum drying attachment at AGNS. It is marked now with 9 a capital J, and it should be identified, or marked for 10 identificatica as Licensee's Exhibit 13.
11 JUDGE WOLFE: So marked.
,s 12 (The photograph referred to is marked L) 13 as Licensee Exhibit Number 13 for 14 identification.)
15 MR. MAUPIN: The next photograph is described as I
16 cask being prepared for shipment at the power station. It j l
17 is marked now with a capital K, and it should be marked for i I
18 identification as Licensee's Exhibit 14.
19 JUDGE WOLFE: So marked.
20 (The photograph referred to is marked s 21 as Licensee Exhibit Number 14 for
)
22 identification.)
23 MR. MAUPIN: Finally, the -- the final photograph ,
24 is described simply as cask lid. It is marked with a capital Ace-Fed o neponm, inc.
25 L and should be marked for identification as Licensee's
l 213
~ #5-7-Suet ) Exhibit 15.
- 2 JUDGE WOLFE: So marked.
3 (The photograph referred to is marked j
4 as Licensee Exhibit Number'15 for 5 identification.)
6 MR. MAUPIN: Now-I believe, Judge Wolfe, that there 7 are no objections to the admissibility of these exhibits, and 8 I move their admission into evidence at this point.
9 JUDGE WOLFE: It is my understanding that there is 10 no objection to Licensee's Exhibits 1 through 15 being admit-11 ted into evidence.
12 (Mr. McGurren and Mr. Dougherty' nod in the
. \,.
13 affirmative.)
14 By nods of heads of counsel, I understand that is 15 so. Therefore, Licensee's Exhibits 1 through 15 are admit-16 ted into evidence. f'
'17 (The documents and photographs pre--
18 viously marked as Licensee's Exhibit 19 Numbers 1 through 15 for identifica-
-INDEXX- '20 tion are admitted into evidence.)
21 Mr. McGurren.
22 MR. MC GURREN:- Your Honor, consistent with the 23 letter dated May 9th, 1985, as indicated in that letter, 24 the Staff has two documents that we now request be marked m Reporw s.Inc.
25 for identification.
i I
l 214
- 5-8-Suet 1 The first document, Your Honor, is entitled 2 " Environmental Assessment, Finding of Proposed No Significant Impact in the Matter of the Proposed Amendments for the
( )- 3 4 North Anna Power Station, Units Number 1 and Number 2 to 5 Receive a.d Store Surry Power Station, Units Number 1 and 6 Number 2, Spent Fuel and for Increasing the Spent Fuel 7 Storage Capacity at the North Anna Power Station, Units 8
Number 1 and Number 2, Docket Numbers 50-338 and 50-339."
9 This document, Your Honor, is a four-page document.
10 Attached to that document is a 34-page document entitled 11 " Environmental Assessment by the Offices of Nuclear Reactor
,- 12 Regulation and Nuclear Material Safety and Safeguards Related
(_y) 13 to Increasing the Spent Fuel Storage Capacity and the Storage 14 of Surry Spent Fuel at the North Anna Power Station, Units 15 Number 1 and Number 2, Virginia Electric and Power Company 16 and Old Dominion Electric Cooperative, North Anna Power l 17 Station, Units Number 1 and 2, Docket Numbers 50-338 and t
18 50-339." {
19 Your Honor, I ask that this marked as Staff 20 Exhibit 1 for identification.
,s 21 JUDGE WOLFE: So marked.
I )
(The document referred to is marked 22 23 as Staff Exhibit Number 1 for .
INDEXX 24 identification.)
Am-Feder) Reporters, Inc.
25 MR. MC GURREN: Your Honor, the other document i
215
- 5-9-Suet 'l referenced in the May 9th letter is the Staff Safety Evalua-2 tion which consists of pages with a table of contents begin-(} 3 ning -- immediately following the table of contents, Pages 4 1-1 through Page 6-1, with an Appendix A, consistinglof 5 A-1 through A-4, and an Appendix B consisting of Pages B-1 6 and B-2.
7 This document is entitled " Safety Evaluation by 8 the Offices of Nuclear Reactor Regulation and Nuclear Material 9 Safety and Safeguards Related to Increasing the Spent Fuel 10 Storage Capacity and the Storage of Surry Spent Fuel at the 11 North Anna Power Station, Units Number 1 and Number 2, 12 Virginia Electric and Power Company and Old Dominion Electric 13 Cooperative, North Anna Power Station, Units Number 1 and 14 Number 2, Docket Numbers 50-338 and 50-339."
15 I also ask, Your Honor, at this point that this 16 document be marked as Staff Exhibit 2 for identification. l l
17 JUDGE WOLFE: So marked.
18 (The document referred to is marked 19 as Staff Exhibit Number 2 for 20 identification.) ,
1 IN; 21 MR. MC GURREN: Your Honor, at this time, consistent k-)
22 with the agreement of the parties we ask that these two docu- 1 23 ments be received into evidence.
24 MR. MAUPIN: No objection.
AmeJederd i:eportm, Inc.
25 JUDGE WOLFE: There being no objection, by agreement l
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216- l l
- 5-10-S ue T 1. of - the parties, Staff Exhibits 1 and 2 are admitted into
-2 evidence.
- ("% . .3 (The documents previously marked as O
4 Staff Exhibit Numbers 1 and 2 for 5 identification are' admitted into 6 evidence.)
INDEXX '7 (The Board members are conferring.)
8 JUDGE WOLFE: All.right. Mr. Maupin or Ms. Gelman, 9 your witnesses.
10 MS. GELMAN: Yes. Would Mr. McCreery and Mr.
11 Pickworth please step into the jury box?
c- 12 JUDGE.WOLFE: Ms. Gelman, I.had some difficulty k/ in hearing you. Would you speak up so I can hear you,
. 13 14 please?
15 Would you. identify these witnesses again? I simply 16 didn' t hear you. j 17 NS. GELMAN: Yes. Mr. Paul McCreery and Mr.
18 Joseph Pickworth.
19 Are you going to swear them in, Judge?
L20 . JUDGE WOLFE: Would you identify yourselves for 21 the record, please? Who is who? The man on the left.
22 MR. MC CREERY: I am Paul McCreery.
23 JUDGE WOLFE: McCreery. All right.-
i l 24 MR. PICKWORTH: Joseph Pickworth.
Ase-reseres neoormes, inc.
25 JUDGE WOLFE: Yes. Would you both stand and raise
217 j 1
)5-ll-Suet 1 your right hands?
2 (The witnesses are sworn by Judge Wolfe.)
Whereupon,
(~'l w ,i 3
4 PAUL N. MC CREERY 5
and 6
JOSEPH PICKWORTH are called as witnesses by and on behalf of the Licensee and, 7
8 having first been duly sworn, were examined and testified 9 as follows:
10 DIRECT EXAMINATION 11 BY MS. GELMAN:
INDEXX 12 Q Mr. McCreery, please state your full name and O 13 address.
A My name is Paul N. McCreery. I live in Aiken, 14 15 South Carolina. I am Manager of Aiken Operations for Trans-16 nuclear, Incorporated. l 17 Q Are you familiar with the document dated May 9th, 18 1985 entitled " Testimony of Paul N. McCreery" consisting of
.19 20 pages and containing three appendices?
20 A I am.
- 21 Q Nas it prepared by you and under your supervision ;
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22 and direction?
23 A It was. !
24 Q Mr. McCreery, do you have any corrections to this AceJederJ Reporters, Inc.
25 testimcny?
218 I I
i
- 5-12-Suet I A Yes, I do. On Page 14, the first paragraph, last 2 sentence, I would ask that you delete the words, "To my
(~ ) 3 knowledge," and insert in their place, "With one exception."
t/
4 I recently became aware that prior to the cask 5 cooling operation at the reactor site in New Jersey, a section 6 of transparent hose used as a cyclas became cloudy and it 7 was replaced. The hose is not a part of the cask equipment '
i 8 that is supplied by the plant. The section replaced had a i 9 quick Chicago-type connector at each end. The replaced !
10 section had no seals in it. l 11 When the cask filled and began sending water t
7~. 12 through this hose, something less than one quart of water
( ) t' va!
13 leaked through the unsealed connectors and several workmen 14 near the base of the cask received contamination from the i i
15 ' leak. All were promptly and readily decontaminated, and 16 there was no internal contamination.
l 17 The skin dose is calculated to be human at .5 MR 18 maximum. This particular incident involved an administrative 19 procedure outside the realm of cask handling and, therefore, i
20 was not covered by cask handling procedures containing any ,
-,. 21 of the procedure checkoffs, like those to be used at Surry i
)
22 and North Anna. +
23 Moreover, the incident posed no significant 24 threat to the health and safety of the public, and I am ;
Am-FMud Reorms, lm. l 25 confident that there was no significant impact on the workmen. {
219 I l
- 5-13-Suet j A similar incident is unlikely to occur at one 2
of Virginia Power's reactor sites, since, one, a different type of mechanical-joint is used, a non-fixed connect type,
-3 4
and, two, once the joint is connected it' remains in its 5
connected condition throughout the successive shipping END #5- '6 campaign. ,
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'220 Sim 6-1 1 Q Are there any other corrections to the testimony, 2 Mr. McCreery?
, 3 A (Witness ;1cCreery) No.
.(' ' '
4 Q Is the testimony to the best of your knowledge 5 'true and correct?
- 6 A It is.-
7 Q Do you wish to adopt it as your testimony?
8 A I do.
9 MS. GELMAN: Mr. Chairman, I move admission of 10 the testimony of' Paul N. McCreery in o evidence and request 11 that it be -bound into the transcript.
12 JUDGE WOLFE: Any objection?
(/ 13 MR. GURREN: No objection, Your Honor.
14 MR. DOUGHERTY: No objection.
15 JUDGE WOLFE: The testimony of Paul;N. McCreery 16 will be incorporated intIo the record as if read.
17 MS. GELMAN: I will hand the clerk three copies.
18 (The testimony of Paul N. McCreery follows:)
19 20 21
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( 22 23 24
- Ace Fedorol Reporters, Inc.
25
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May 9, 1985
(
UNITED STATES OF AMERICA 4 NUCLEAR REGULATORY COMMISSION r
BEFORE=THE ATOMIC SAFETY AND LICENSING BOARD LIn the-Matter of )
t )
VIRGINIA _ ELECTRIC AND ) Docket Nos._50-338/339-OLA-1 POWER COMPANY _ )
. )
~
l(North Anna Power )
Station, Units 1 and 2) )
T
_ESTIMONY'OF PAUL-N. McCREERY O i-Introduction
- My.name is Paul'N. McCreery. I am Manager, Aiken Operations-for Transnuclear, Inc. (TN). My. address is'1607 Huntsman Road, Aiken, South Carolina 29801.
I received.a B.S. degree in Physics from Louisiana State University in 1948. I have also had 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of graduate studies.in_-engineering and business. I have worked in the nuclear field in engineering and administrative capacities for 32: years, the last:13 of which were involved with spent fuel
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transport cask design, fabrication, licensing and operations.
I have had extensive hands-on experience with every currentl'y-licensed light water reactor spent fuel cask in the
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_2 U.S., plus other casks in the process of being licensed for dI transport or storage.
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This work is documented in reports on file in Allied-General Nuclear Services records and with-the Department of Energy. My resume is attached to this testimony as Appendix 1.
I have been^ asked to address that portion of Concerned Citizens of Louisa County's (CCLC) Consolidated Contention 1 dealing with human error. That contention states as follows:
The Staff's Environmental Assessment is inadequate and an Environmental Impact Statement should be prepared. . . .
[T]he Environmental Assessment did not evaluate the probability and consequences of accidents occurring during the -
transportation of spent fuel casks from C. the Surry Station to the North Anna Station which might be occasioned by . . .-error of applicant's employees in preparing the casks for shipment.
My testimony, in summary, is that design features and handling 4
. procedures asscciated with the cask that Virginia Electric and i
Power Company (Virginia Power) plans to use make insignificant the likelihood and effect of any human error in preparing casks-for shipment.
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II.
'( Cask description
'A . General features The particular TN cask to be used.for the
.Surry-to-North Anna _ shipments is the model TN-8L. It is designed to carry three pressurized water reactor fuel assemblies, one in each of three compartments. Specifically, l the cask cavity consists of.three stainless steel square pressure vessels welded to an end plate and a circular stepped top flange, separated by a T-shaped copper plate and surrounded
('.J 'with. boron carbide'and copper plates. Eac'h cavity is 230 X_230 mn and 4,280 mm:long. The main shielding consists of 135 mm of. ,
lead, 26 mm of steel and 150 mm of resin. A wet cement layer is located between the lead and the outer steel shell to reduce heat flow in the event of fire. Radial copper fins are welded 4
to the outer shell and. cover the surface of the cask between the end drums.
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Each end of the cask is surrounded by stainless steel drums reinforced by radial gusset plates and filled with balsa wood. A disk-shaped snock absorbing cover, constructed of carbon steel and balsa' wood, is fastened to each drum with
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> four, 1-1/4 inch bolts. The cask has six trunnions, which are the structures-int which the cask is handled. Impact limiters
-are attached-to the trunnions to reduce impact loads in the i
e 1 .
event of a side drop onto a trunnion. Certain vent and drain g.
L(_); lines, described.below, which penetrate the inner cavity are equipped with positive closures. In addition, all access ports are protected by the shock absorbing covers. A copy of NRC's Certificate of Compliance, issued to certify.that the cask meets the safety standards in 10 C.F.R. Part 71, is attached as
-Appendix 2. Also attached, as Appendix 3, is a diagram of.the cask with its_ components labelled.
B. Penetrations The principal cask penetration, of course, is the.
(} opening on the top of the cask through which spent fuel is
--loaded.and unloaded. The lid that covers this opening is a welded stainless steel circular flanged shell containing lead and_ resin shields. The lid is secured by sixteen 1-1/4 inch
. diameter bolts and is provided with a double seal consisting of two concentric Viton "O-rings" located within recessed grooves t
l on the top flange.
t In addition, there are three penetrations that lead to
.the fuel cavity. The "A" penetration passes through the lid
.and is 1-1/2 inch in diameter. This penetration is used for cask evacuation and drying-(in the vacuum drying test described
)
Ebelow), and venting when the cask is being filled with water.
- -The "A" penetration is sealed by the "A" plug, which is a lead-filled flanged cylinder that has one "O-ring" seal on the
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underside of the flanged portion'and is-secured to the lid by h three bolts.
The "B" penetration is a penetration from the bottom of the lid that passes upward through a Hansen valved quick-disconnect fitting. It is sealed by a circular flange with a single "O-ring" and is held in place by three bolts. The Hansen valved connector acts as a second seal. The "B"
, penetration is used to' provide access for instrumentation to.
obtain pressure readings within the cask during cask handling operations.- It is also used for backfilling the cask with nitrogen and, when the cask first arrives, to compare the
() ~ pressures inside and outside the cask. If the cask pressure inside the cask is greater than that outside, the excess pressure is vented through the "B" penetration through the .
reactor's radwaste system.
l The "C" penetration is a penetration formed by the i drain lines at the bottom of the cask that converge into a
. single Hansen valved quick-disconnect fitting. It is used to i:
drain water out of the cask and to fill the cask with water.
It is sealed-by a flange cover, with one "O-ring," and three bolts. Again, the Hansen valved. connector acts as a second 1
{}. seal.
i: The "A" and "B" penetrations are located in the lid.
Thet"C" penetration is located on the side of the cask near its bottom.
There is also an opening in the lid that does not lead j j%
(-) into the fuel cavity. This "D" opening is an access port to ;
the annulus between the two lid "O-rings". It is sealed by a-threaded plug with an "O-ring" on the underside of'the-head of.
the plug. It' allows access from the top of the lid to the space between the two "O-rings" so that the integrity of the main lid'"O-rings" can be checked.
Each cover of the "A" through "D" openings has a Viton "O-ring", with a circular cross section. Three bolts in the "A", "B" and "C" penetrations, the threaded plug in the "D" opening,,and the 16 bolts in the lid are torqued to levels '
{ )- specified in the operating procedures, in a specified sequence.
The specified torque is applied to the bolts to compress the "O-rings" and form a tight seal against the metal on both sides, and to pre-stress the bolts. Metal ~to metal contact
,between the closure flanges in the lid or body limits the compression of the "O-rings" to pre-selected values to assure that no excessive force or deformation is applied to the Viton
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"O-rings" irrespective of the torque valves applied to the closure bolts. The Hansen valved connectors in the "B" and "C" penetrations act as a second seal. .
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III.
.(_r)\ - Safety-related design features :
Certain design features of the model TN-8L cask minimize 1the potential for damage-producing human error in cask -
handling. Some of these design features make errors less
-likely. Some would minimize the effect of an error if one were committed. The cask is designed (1) to be shipped " dry;" (2) to carry fuel.that is more recently discharged, and therefore hotter, than the:Surry fuel; (3) to carry the maximum payload that can be cransported by highway; (4) to have one more seal on the' lid and on two of the other three penetrations into-the p/
~- cask cavity than is necessary to satisfy NRC requirements; (5) -
to use elastomeric sealing material rather than metallic seals; (6)'to be of a relatively simple design; and (7) to withstand extreme accident conditions.
First, the cask is shipped " dry," i.e., with no water in the fuel. cavities. That precludes the development'of steam pressures inside the cask, since there is no residual water that can turn to steam. The absence of steam pressure reduces the possibility of a release of radioactive gas in th'e event an employee erred and, for example, failed to properly tighten the
-.- lid bolts, or failed to detect a defective seal. If no positive pressure exists inside the cask, there is no driving fo'rce to force radioactive gases outside the cask. Also, the less pressure, the less chance for a seal to fail.
.. - . . . _ _ _ . _ , - , . - , - , _ . , . ~ . , _ . , _ _ _ . _ . _ - . - . . . _ . . . _ . . . _ - , _ _ . . _ _ _ . _ . - , . - _ .
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Second, theteasks were designed to carry fuel that has
): 'been discharged-from the' reactor only six months and is thus
" hot" (thermally) with'a decay heat of approximately eight kw per ' assembly.~ ;The design-parameters of the cask enable it to contain pressures of 105 psig, with a safety factor of three.
The_Surry fuel that will be shipped to North Anna has been out of the reactors for over five years, with a heat output per.
assembly;of less than two kw, and so is producing heat at only.
a fraction of'the design capacity of the cask. This.is another important_ safety factor'over and above the original design safety. factor of three. The fact that the fuel to be_ shipped' i() is being selected from reactor discharges that indicated a low relative activity,.and thus no major failures, also makes it less likely that a significant driving force would be created
</ .inside the cask.
Third, the cask is, designed to carry the maximum payload that can be transported-by highway. One unloading / loading cycle removes as much fuel as three loads in the only other available highway cask model. The likelihood of handling errors is thus decreased during any given shipping campaign, since-Virginia Power will need one-third as many shipments with the model TN-8L cask.
Fourth, while only one seal for each penetration will satisfy NRC requirements, the cask features double seals for the lid opening and two of the other three penetrations into
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,a m a
N , l u-the caskicavity. Thus, 3.n the event a seal on:the lid, or on .
fm; - cenetration were defective, and an e'mployee
'O the l '.'B" . or' "C"
- failed-to detect this, another seal would' back- up the - first-
- seal. _The "A" penetration has a single. seal with a metal
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(" shield") plug.
Fifth, the cask uses' seals.made of a rubber-like naterial (Viton) rather_than metallic seals. A seal'containing this rubber-like material is less susceptible to damage than a metallic seal, in that.if it is deformed during handling cperations it will regain its original shape. This minimizes the possibility of additional handling which would be required if'a seal had to be changed, and thus decreases the' likelihood
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of error.
Sixth, the cask.is relatively simple in design. The
- simplicit'y of design _results in easy-to-follow operating The
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procedures, which I shall discuss at greater length below.
less complicated the operation of the cask, the less likely it is_for an error to occur. And, if an error occurred,-it would be easily detected and corrected.
Finally, the cask is designed' pursuant to 10 C.F.R. 5 71.73 to withstand certain accidents without significant damage. For example, it is designed to. withstand a 30 foot-
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drop onto an essentially unyielding surface, a side drop of 40 inches onto a 6-inch diameter steel bar, exposure for not less than 30 minutes to a fire of not less than 1475 F. and m
A rimmersion under at least-three feet of water for not l'ess than gN/ eight hours.
.Some of the benefits of the TN-8L can be illustrated by a few "what-if" questions. For example, what if one of the penetrations leading to the. fuel cavity, once opened, is not subsequently sealed?
First, with the exception of the "A" penetration, not only one, but two, seals,would have to be left open for:there
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Second)-
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-to be any passageway for radioactive gas to escape.
bothtthe "B" and "C" penetrations contain Hansen valved connectors which have automatic closure devices that operate when a coupling is disconnected from them. Third, the absence-
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of a proper seal would be indicated by both the leak test and the vacuum drying test, required by the operating procedure.
What if a seal is defective or the bolts are not tightened with enough force to properly compress a seal?
This is not likely to happen. Seals are visually inspected every time the cask is loaded or unloaded, and replaced if necessary. Indeed, examinations of the seals and bolt torquing are included in the quality control " checkpoints" that are required under_ the operating procedure. But even if a seal were defective, and.this went undetected during
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. inspection, no radioactive gas would escape. First, there is a second seal to back the first seal up on the lid and on the "B" and "C" penetrations. Second, since we are dealing with a dry
m - -
1
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- cask- the integrity of1theilid seal and the "C" Hansen dm). _ .
connector are verified:during the dryness' test. Further, if
,. the bolts are not properly tightened or if.the seal is defective on the lid, the "A"-plug, the "B" flange, or the "C"
.Hansen connector, those penetrations will not pass the leak test. - The. operating procedure requires the. operator to~ check
' whether the bolts are properly tightened if these tests are failed. .If the bolts are properly tightened, the operator will disassemble and-replace the seal and repeat the torquing and testing procedures. Cavity drying and leakage tests are performed under a vacuum. Dryness-and leakage acceptance l{} criteria would'not be met with defective seals. Third, the1 e cask is " backfilled" with nitrogen to one atmosphere- -
(absolute),-so that the pressures ~inside and outside the cask are equalized. In the absence of a driving. force inside the cask to. drive any gas past the seal, no gas will escape through a defective seal. Although residual heat from the spent fuel could increase the temperature and thus the pressure inside.the cask, creating a. driving force, . any residual heat would be insignificant,since the fuel to be shipped will be more than five1 years old. The driving force thus created would also be r' insignificant, and little, if any,-gas would be driven past a d'
defective seal.
What if fuel cladding fails when the shipment is en route?'
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. - - ----,--e..y---- ,_-,,,-.--m,---,, ,.m, y. -,.,.-3,-,
- , , ,-,_vp_.,- y.,, ,.--.,.,..,w.,,,,,, ,,y,.,y n,,,v.,pe,w,,.._y_-r-,
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=The' fuel' rods.are pressurized'with gas. If the fuel-
[([ f cladding; fails, gas will'1eak into the cask cavity and increase
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the cavity gas pressure. The cask is,: however, designed to withstand _far more pressure.than would result even if all-fuel g -rods in the1 shipment fail and all,the pressurized gases are released into the cask cavity. The total accumulated gas in
.such a' case will not' create a pressure exceeding 20 lbs. per square inch, one-fifth the maximum working pressure the cask was designed to. withstand. And since the cask'has a design-safetyLfactor of three, the cask will actually withstand many:
times this amount of' pressure. In any event, experience has A shown that fuel that has not failed in the reactor is unlikely.
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- ' to fail in storage or during transport.,
L What if a seal began to leak en route?
Again, thisz is not likely-to happen since (1) the seals are routinely replaced once a year despite-the fact that the shelf-life of a. seal is five years, and after the complete. set is replaced, the cask is leak-tested under a vacuum of 1/1,000,000 of normal air pressure, (2) a deteriorating seal will fail.the inspections and leak test, and (3) for a healthy seal to rupture in transit, more pressure would be required p than can be_ generated in all combinations of u
pressure-increasing incidents that can take place within the cask under normal transport conditions. Seals are so well protected that it is difficult to develop a scenario for the failure of one en route.
m l
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- 13-In the~unlikely event a seal did begin to leak en kq)
. . route, however, little gas would escape,-since with fuel over
~five' years old there would not-be enough residual heat to-
-create a significant driving force inside the cask. 'Even a modest amount of failed fuel will'not drive gas out of_the cask at a significant rate.
What if the tractor and trailer should separate from one another?
This-happens-occasionally in the trucking business and
-has been known to happen at least once with a spent fuel cask.
There'was no damage to either cask or trailer. The cask is designed to withstand far more severe accidents. Moreover,
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cask haulers have recently been required to formalize (QC
, check)-the lock-up test procedure that is routinely performed by truck drivers.
What if the cask tie-downs were net secured?
Even if the cask is not tied down properly it will arrive at its destination without incident unless it is involved in a rather serious accident. If the cask should fall.
off the trailer en route, the probabability is very small that the cask would be seriously damaged. The cask is designed to j]) withstand much more severe conditions without breach of
-containment.
The success of these design features has been-borne out i
by experience. There.are over 65 similar casks in use on a g -
,, , . , . , , _ _ ,x ,u7,w__r_, ,,, - , , , ,.e-,_ ,,....,m_,,,..., ,-.,-%....,_i,,_-..,-~~.,.,,y,
,__m,, m,_,_,-.- ,, +-- ----9_m. w
t routine basis throughout the world. They transport fuel'that
-(_ O) is much nearer.the design limits for heat-output and radiation than the Surry fuel. Other-similar casks in the U'.S. have Ltransported over 30 loads of fuelzfrom West Valley, New York to Morris, Illinois and are presently transporting fuel from West Valley to. Forked River, New Jersey. To my knowle'dge, there
.have been.no instances of. human error of any consequence associated with any of.these cask operations.
IV.
Cask Handling Procedures From the time the empty cask is removed from the truck
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'itntil it is placed back on the truck filled with spent fuel, the following procedures are prescribed:
- 1. The cask protective devices are removed.
- 2. Cask-.is taken to decontamination area.
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- 3. Skirt (cover) is placed on it, so that radioactive contamination will not accumulate on fins while the cask is in_the spent fuel pool.
- 4. _The 16 bolts that engage the cask lid are removed.
l' 5. Cask is' filled with water then moved to the loading l station in the pool.
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- 6. Cask lid is removed while cask is under water.
'7 . Cask lid is lifted above the water with a crane.
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- 8. The seals are' inspected'for defects.
Y')ks- 9. Any seals that have defects are replaced.
- 10. Three assemblies are loaded into the cask.
- 11. The cask lid is replaced _while cask is under water.
_12. Cask is lifted partially out of water, and four bolts are replaced, hand-tight, in lid.
- 13. Cask is_ moved to decontamination area, and the remaining 12 bolts are installed.
- 14. Numbered template prescribing the order for bolt tightening is placed on the cask.
- 15. All'16 bolts are tightened to 290 ft. lbs. with s
[J. calibrated torque wrenches.
- 16. The. water in cask is drained (gravity draining) through penetration "C."
- 17. Leak tightness of the lid seal is checked'through the "D" opening.
- 18. The air is evacuated from the cask.
- 19. Any remainidg moisture is evaporated.by the vacuum drying system.
- 20. When pressure inside cask is less than 20 millibars, cask is tested for 10 minutes. If
()- pressure increases no more than three millibars during this time the seals are working and the cask is dry (vacuum drying test).
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j 21.-The evacuated cask is-back-filled with nitrogen to
'( ) prevent oxidation of the fuel.
- 22. The cask is backfilled with nitrogen to one atmosphere, in order-to equalize the pressures inside and outside the cask.
- 23. Remaining penetrations into the cask are checked' under. vacuum for leak-tightness.
- 24. Skirt is removed, and,the cask.is ready to be moved
.to truck.
-25.1The cask is secured to its specially designed
-trailer by a system designed to restrain.the cask j{' in all three motion modes.
- 26. The cask protective devices are attached to ends and trunnions. Security seals are attached at each end.
- 27. These procedures are repeated when.the shipment
-reaches its end destination and the cask is unloaded, except for the seal leak tests and except that four bolts remain in the lid until the loaded cask begins its descent into the fuel pool.
A supervisor watches as the operator performs-each' step gr '( of the operating procedure. The supervisor's responsibility is V
to ensure that the' operators perform each step in the proper sequence and as prescribed by the operating procedure. The procedure contains a " check-off" space beside each step
delineated'to_ verify that each step has been properly (N-v) performed. In addition, whenever a step is taken that requires that its performance be verified by readings of pressure, torque or visual' examination,'these values or attributes are confirmed by a quality control representative.
These procedures, which will be introduced as Exhibits in this_ proceeding, are based on over 500 cask-years' operating experience. Similar casks have been used in Europe since the 1970's. There.have been at least 50 loadings and unloadings in the United States. The procedures have evolved from this operating experience and from knowledge gained through
,3 technical investigations.
A. generic operating procedure has been approved.by NRC along with the cask's Safety Analysis Report. The site-specific procedures are reviewed and verified by Transnuclear, Inc. to conform to the generic requirements.
These procedures minimize the potential for human error. They are written so that the requirements of each step
-are clearly stated. They are detailed rather than complicated.
They'do not leave situations open to operators' interpretation.
Again, each step must be checked-off by a supervisor, and every
, time observations affecting safety are made they are checked by a quality control inspector.
In addition, the procedures include "self-checking" operations, i.e., procedures that would make manifest any
earlier mistake. For example, the " dryness" test under vacuum
() will not pass if the lid or penetration bolts are not in place, or if the-cask is not drained of water, or if the seals are defective.
I have observed in part at least eight loadings at West Valley and about as many unloadings at Dresden and Oyster Creek, all utilizing procedures similar to the Surry procedures. I' have observed similar loadings and unloadings in Europe. I have the experience of participating in " dry runs" or. training exercises in which the operators became familiar with casks before.any fuel was handled. The only errors I ever
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observed took place during the earliest loadings, for which.TN c]
v provided around-the-clock technical oversight, and these were inconsequential, for example,-tightening lid bolts out of
-sequence or not turning on the vacuum pump for a proper warm up period before use.
Before the Surry-to-North Anna shipments are made, Virginia Power personnel will have been trained to properly implement these procedures. They have had about seven hours of class' room instruction and one " dry run" without fuel, and will have TN technical oversight of initial operations.
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- V.
-Iv ) Conclusion First, there are several cask. design features that either'decreaseLthe likelihood of human error in preparing the cask for shipment.or minimize the effect of an error if one
.were committed. In summary, (1) the cask is shipped dry, '
precluding the development of steam pressures inside the cask that could produce a driving force capable of propelling radioactive gas out of the cask; (2) the cask is designed to carry more recently discharged -- and therefore hotter -- fuel than Surry's, providing a safety factor over and above the
()- original design safety factor of three; (3) the cask is
' designed to carry the maximum payload, enabling Virginia Power to reduce the number of shipments, and thus the amount of cask handling, required during a given shipping campaign; (4) the cask is designed so that the lid closure for the main cavity opening and two of the other three penetrations leading into the cask cavity have double seals, even though each individual seal adequately. meets NRC requirements; (S) the cask is designed to use resilient rubber-like sealing material rather than metallic seals that are more easily damaged, eliminating
,m
!) the need for more handling-during replacement; (6) the cask is simply designed, making it relatively easy to handle; and (7) the cask is designed to withstand extreme accident conditions.
Second,-the cask handling procedures Virginia Power
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v will implement make the likelihood of error in preparing the casks for shipment still more remote. These procedures are thorough rather than complex. They conservatively require checks and double checks. Thus, not only is a seal visually inspected, and then subjected to a leak test, it is also replaced annually, despite a five year shelf-life, whether or not it is deteriorated. It is then subjected to a still more demanding leak test. The drying test is also a verification of proper' installation of-the lid seals. For every step the operator performs, a supervisor must verify that it is done j3 correctly. Required quality control checkpoints provide still' V another-layer of assurance during the performance of the more important steps. These procedures were developed based on approximately 500 cask years' operating experience. The operating history of similarly designed casks attests to the cask design benefits and to the success of the operating procedures. .
These design features and handling proc..dures make insignificant the likelihood and effect of any human error in preparing casks for shipment.
O
..- Appendix 1 NAME: Paul N. McCreery EDUCATION: BS, Physics: Louisiana State University, 1948 Graduate studies in engineering and business.
POSITION: Manager, Aiken Operations, Transnuclear, Inc. ,
. (a~) EXPERIENCE:
'9/83fto present, Transnuclear, Inc. Aiken, South Carolina As Manager of Aiken Operations, he is responsible for field services of the Transnuclear, Inc. cask fleet. In this capacity he is responsible for the continuing recertification requirements (periodic testing, proper use in accordance with 10 CFR 71.87) of transport casks, spare parts control and delivery, maintenance of ~
ancillary equipment, and development of special equipment. He is Project Manager for the conceptual design of a system of high capacity, new generation casks for a DOE-sponsored project. He participates in training programs for users of the Transnuclear, Inc, casks, and the oversight of loadings and unloadings as a follow-up to the training programs.
2/78 to 8/83, Allied-General Nuclear Services, Barnwell, SC In the capacity.of Project Engineer he worked extensively with every model of commercial LWR spent fuel shipping cask currently f~N - certified by USNRC, plus three othet special purpose spent fuel V . casks and one cask which he designed and was built especially for -
studies in methods to improve cask handling techniques. .
Independent studies on cask fleet servicing were later extended under DOE contract to include more operations and advanced concepts. In each of these cask studies he made suggestions for improved handling techniques which were adopted by the casks' owners.
3/52 to 1/78, NL Industries.
3/52 to 2/70 Feed Materials Production Center, Fernald Ohio.
At this facility he held positions in the nuclear materials accountability department from Technologist to Department Head.
He also served as Department Head for Quality Assurance. Both departmental positions involved extensive work with procedure preparation, oversight and audits.
4/73 to 1/78 Barnwell Operations, Barnwell, SC.
(~T As Manager, Cask Transportation Services he was responsible for
\/ the cask fleet (NLI 1/2's, NLI 10/24's, MTR and AECL). to serve exclusively the Barnwell reprocessing plant. During this time the casks were used, under his direction, to transport spent fuel and non-fuel-bearing components throughout the US and from Canada into the US.
3/72 to 4/73 Fabrication Center, Wilmington, DE.
'As Manager of Administration he supervised Quality Assurance, Accoun' ting, Procurement and Data Processing. He worked closely with fabrication operations (spent fuel casks for GE, Navy, GA, !
! FFTF transfer cask, etc.). After later being transferred to I Barnwell Operations, he was on two ocassions temporarily reassigned to this facility to troubleshoot operational problems.
_(])
2/70 to 3/72 Fuels Fabrication Plant, Albany, NY.
As Technical Services Manager he had direct responsibility for two QA organizations (fuel, non-fuel), accountability and data processing.
PUBLICATIONS RELATED TO SPENT FUEL CASKS
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McCreery, P.N., et. al., "The Conceptual Design of a Spent Fuel Cask Fleet Servicing Facility", Allied-General Nuclear Services, AGNS-1040-1.5-48, September, 1978.
Anderson, R.T., McCreery, P.N., et.al. " Simulated LWR Spent Fuel Receiving and Handling", Allied-General Nuclear Services, i AGNS-1040-1.2-46.
McCreery, P.N. et. al.; " Operational Assessment of the NLI-1/2 Legal Weight Truck Spent Fuel Cask", Allied-General Nuclear Services, AGNS-1040-1,1-30, October, 1978.
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McCreery, P.N., et. al., " Interface Criteria for Shipping Casks and Fuel Handling Facilities", Allied General Nuclear Services, Y/OWI/SUB-78/1, January, 1979.
McCreery, P.N., " Advanced Cask Handling Studies", Allied-General Nuclear Services, AGNS-35900-1,1-49, October, 1979.
McCreery, P.N. and Watson, C.D., " Fleet Servicing Facilities for Servicing, Maintaining and Testing Rail and Truck, Radioactive Waste Transport Systems", joint publication of Oak Ridge Nati.onal
, Laboratory and Allied-General Nuclear Services, ORNL/Sub-79/13866/1 (AGNS-SPP-5), March, 1980. Presented as a L paper at the Berlin, W. Germany, PATRAM conference Nov., 1980.
McCreery, P.N., " Cask Handling Equipment Standardization *, Allied .
General Nuclear Services, AGNS-35900-1.1-106, October, 1980.
McCreery, P.N. " Operational Assessment of the Transnculear Transnuclear, Inc.-9 Truck Spent Fuel Shipping Cask",
(]) Allied-General Nuclear Services, AGNS-35900-1.1-157, November,
, 1981.
McCreery, P.N., et. al., ' Operational Assessment of the FSV-1 (HTGR) Spent Fuel Shipping Cask in Alternate Modes",
Allied-General Nuclear Services, AGNS-35900-1.1-157, November, 1981.
.s McCreery, P.N., et. al., " Spent Fusl Shipping and Cask Handling Studies in Wet and Dry Environments", Allied-General Nuclear Services,.AGNS-35900-1.1-184, September, 1982.
Anderson, R.T., McCreery, P.N.'and Maier, J.B., 'An Evaluation of Nuclear Dual-Purpose Casks for Extended Storage and Shipping
.( )
Usage in the Monitored Retrievable Storage Program *,
Allied-General Nuclear Services, Draft Report of Project 3123, October, 1982.
McCreery, P.N., " Development of Procedures for Cask Handling Demonstrations Using.REA and GNS Spent Fuel Storage Casks",
Allied-General Nuclear Services,.PNL/3120-1,0, January, 1983.
McCreery,.P.N., " Development of Procedures for Cask Handling Demonstrations Using REA and GNS Spent Fuel Storage Casks (Part 2)*, Allied-General Nuclear Services, AGNS-11033-4.1-11, July, 1983. -
RELATED INDUSTRIAL AND PROFESSIONAL ORGANIZATIONS .
Member at Large, ANSI N-14 Transportation Committee Chairman ANSI N14.27 ' Guide for Carrier and Shipper Responsibilities and Emergency Response Procedures for Highway Transportation Accidents Involving Truckload Quantities of
() Radioactive Materials.* 1985.
Member, ANS Past Sr. Member, ASQC -
Founding Member, INMM
/ct
- Ol77C
!6
^
I
m m ......... -------------.---..
a CERTIFICAT2 CP COMPi. LANCE PCR RADICACTIVE MATERIALS PACKAGES I l '* *** "
s nevision wwesa oncx444 ioenrisication =vueen e.
,e cen w , cars av een Appendix 2 1 9015 9 USA /9015/B( W 5 a paie4 mets U
- a. This certitter.se is itswee to certify tnst tne secaeging and contente caecneed in item S Deiow. meets tne sosticanie safety standeras set forte in Title 10. Coos l of Peceret Aegwistione Port M. Pecnaging of moeioactive Matenale for Transoort see Transoortation of macioactive Metenes under Certain Concitions." )
is conficate goes not roeneve tne consignor from comotience witn any roowerernent of tne regulations of tne U.S. Copertment of Transoortation or otner I asc4o6e requietory ageneses, inciwaing tne ;;.;- ec.: of any country tnrougn or into weten tne secasgo edi De transportes.
I
!1 2 rygti,igog easis or a sarerv *a.unia, eg,rgr;syc,xgegigegg=
4 Transnuclear, Inc. Transnuclear, Inc. application dated One North Broadway April 9,1980, as supplemented. h' i
t White Plains, NY 10601 t t
\
' l e.occxer w ween 71-9015 J
e CoNQitiCNS I This certihcate is conditional ison fulfilling tne requirernents of 10 CFR F art 71. se soclicacie, and tne condmone " ** * * *'P p f
> s. - . ?t l 9 (a) Packaging lf I !
l MAR 1 1 B85 (1) Model Nos.: TN-8 and TN-8L d' V , l (2) Description ;
, . _t _ ,
ii I
O Lead, steel and resin shielded irradiated fuel shipping casks. The casks approximates a right circular cylinder 1,718 mm in diameter and E 5,516 mm long. The cavity consists of three (3) stainless steel lg
[ sgJare pressure vessels welded to an end plate and a circular stepped g
top flange, separated by a T-shaped copper plate and surrounded with n pl l B4C + Cu plates. Each cavity is 230 x 230 mm and 4,280 mm long. The I li main shielding consists of 135 mm of lead, 26 m of steel and 150 mm I 11 of resin. A wet cement layer is located between the lead and the lI outer shell. Radial copper fins are welded to the outer shell and .j cover the surface of the cask between each end drum. The Model No. g i,i TN-8 has 150 rows of fins and the Model No. TN-8L has 104 rows of .i sl l fins. .I li :I I: The lid is a welded stainless steel shell containing lead and resin l
[ shields. The pressure vessels are closed and sealed by sixteen,1- i i.
1/4-inch diameter bolts and two silicone rubber or Viton 0-rings i, located within recessed grooves on the top flange. Each extremity of I I; the cask is surrounded by circular stainless steel drums reinforced by I Il radial gusset plates and filled with balsa wood. A disk shaped impact I 11 limiter, constructed of carbon steel and balsa wood is fastened to I each drum wi th four,1-1/4-inch bol ts. The vent and drain lines which l f'
g penetrate the inner cavity are eouipped with positive closures. In i si addition, all access ports are protected by the impact limiters. I l'
- i li .
II i!
11 :I I! l I! ,.
I .
I L' 11 al _ - _ - _ - _ _ _ - - - - - _ _ _
d U ; "U C#
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l ; ' * *~" "" conomons teenunuen) f I
Page 2 - Cartificata No. 9015 - Revision No. 9 - Occket No. 71-9015 %-
y b
- 5. (a) Packaging (continued)
O (2) Description (cont 4nued) 'l Trunnions are used for lifting and tie-down of the package. The casks ;
weigh approximately 3G,000 kg. I (3) Drawings l The Model No. TN-8 packaging is constructed in accordance with Transnuclear Orawing No. 9317.01, R tv . J. The Model No. TN-8L is '
!s eonstructed in accordance,with Iren~.iuclear Drawing No. 9317.138, W Rev. A. The materials';ot'constriscf. rf and welds shall be in accordance with Annex A, 6C to Chapter II .t,he $pplication. l (b) Contents ' (' l (1) Type and T'[1n o of material ' 5 '- !
I . ds ,
Irradiated-PWR uranium oxide fuel assemblies of" the following k I
(i) l specifications: ' .
l
= 'z '
li I
O Ee'i foan Cladding material w _;-
. . / . - ,-
Clad u0 Zr or S$ peiiets E
I . )%ximum initia?.0 content /assemblyt kg '
469 Maximum average inttfartT:235' I.l enrichment, w/o .
3.2 I lI . Maximum bundle cross. section...in 8.5 l i
- l Maxfmum active fuel;. length .in -~- - 144 g i Minimum cooling time, day 150 1
[
Maximum. weight / fuel assembly, kg 733; and j l Group I' fuel' assemblies j It ll il Initial fuel pin pressure at 100*F, psig 250 !!
Maximum average burnup, MWD /MTU 38,500; or :I IjI i f Group II fuel assemblies j 11 Maximum average burnup, MWD /MTU 36,000 g ll 11
.I As needed, appropriate I
I O (ii) Solid non-fissile irradiated hardware.
conponent spacers cust be used when leading irradiated hardware I
into the cask cavity to limit movement of the contents during i l accident condi tions of transport.
gl {
II II r i l -
I I
Il I -
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7._..... ... ... ........................... ......._.._
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genomen, ,,,,,,m }
Page 3 - Cartificate No. 9015 - Revision No. 9 - Occket No. 71-9015 l
- ll
- 5. (b) Cont.ents(continued)
O (2) neximum guantity of materiai ,er package ,
(1) For the contents described in Item 5(b)(1), Group I fuel assemblies: l I
Three PWR assemblies. The maximum decay heat load is not to I exceed 35.5 kilowatts per package and 12 kilowatts per assembly I for the Model No. TN-8 packaging and 23.7 kilowatts per package (
and 7.9 kilowatts per assembly for the Model No. TN-8L packaging. g I
(ii) For the contents described-4Qtem 5(b)(1), Group II fuel assemblies: 1
- EN D The 8~t maximum,$ecay Cb// I Three PWR asse6b11es. heat load and the maximum I free gasNotu'me are not to exceed the . limits listed in the table f below- s Q [ ,,
y
[
F perJssahbrly,DR$rHeat kw(,) MaximuiFreg Gas (NTP)(b) per Assembly, m
- r,s
- - {
N;-
/,
0.5 ^e N 0.186 i
y 1.0 I _ ;~ ~ ~ -
0.181 t r-O 3.0 c O.16i t
'- 5.0 . ..
0.147 r H 7.0 ' - 2 i~. , 'f:.- . 0.136 .
~
9.0 9.'.,
~ ' . .
0.128 [
_- {
Notes: (a }- Decay heat load per assembly must not t
+", b exceed- A9. kilowatts-for TN-8L packaging. l (b). ' NTP conditions are 25'c and one (1) bar. ji (i11) PUR ass'emblies may be shipped either with or without burnable poison rod thimble plug, or control rod assemblies. !f (iv) As needed, appropriate component spacers may be used in the cask cavity to properly position the fuel assemblies. J[
? :
(v) The maximum weight of the contents (fuel assemblies, caiponent- p spacers, inserts, irradiated hardware, etc.) nust not exceed [
2,200 kg. [
(c) Fissile Class III h Maximun number of packages per shipment One(1)
- 6. The cask cavity must be dry (no free water) when delivered to a carrier for trans po rt. For the contents described in Item 5(b)(1)(i), residual moisture
, must be promptly removed from the cask cavity by the methods described in Annex I to Chapter VIII of the Application and the cavity must be promptly backfilled L with 1.0 atm of helium, nitrogen, or argon gas. }
h c
L
________....... ..m ..~_...._~ - - m- m w.- m n,.w m ]
~
l U ^ "UCU" W'"
'.*" conomons toonunwe)
[ '
, Page 4 - Certificate No. 9015 - Revision No. 9 - Occket No. 71-9015 l n 2
- I 3-I I a
- 7. Known or suspected failed fuel assemblies (rods) and fuel with cladding defects "
greater than pin holes and hairline cracks are not authorizac. l Prior to each shipment, the ackage mst meet the tests and criteria specified !
for each shipment (operation in Chapter VIII of the Application, as amended 3
I May 3,1983 (Chapter 6.0, Operations Program). i ;
- 9. The package contents must be so limited that under nomal conditions of transport, l the total dose rates must not exceed 17 mrem /hr at one meter from the surface of a '
the package. t I
/ g I
- 10. Any system used for cooling down,the pat.tage,mst be provided with a pressure I e relief device set so that the Inartm0m pressurt (the contaiment vessel cannot exceed 7 atmospheres dur g the ' cool-down proces ./,,
- 11. The systems and components of each packaging must meet the periodic tests and 3 criteria specified ,% Chapter VIII of the Application. Each packaging that I -
I 1 fails to meet thesetri.teria must be withdrawn fran service until corrective 3
-=
action has been complete b ~; .: . . -
l
- 12. Repair and maint'enance of the packaging must be as described in Chapter VIII of a the Application. - ,,
- ~~ , .
.. ..- u . i . .
E d All valves, fitt'ings, seals an,d ral,taf day.icas must. be of the type, size,'model ,.
and manufacture. as indicated'.an the design drawings. The resin material must be of the specifications stated in Annex A'td~ Chapter II of the Application.
l E
- g -
~) . .: . .- .
Prior to first use,. each-packaging.',must meet.the acceptance tests and criteria 1
- 14. N specified in Chapter VIII-of thc. Application ias; amended.
I I
l
- 15. In accordance with Annex L to Chapter VIII. at periodic intervals not to exceed two years, the thennai perfomance of the cask must be analyzed to verify that j -
y the cask operation has not degraded below that which is licensed *. Following 3 H
the initial acceptance tests, the heat source may be that provided by the decay lI =
I heat from the loading of the package, provided that the heat source is equal to il
- I li at least 25t of the design heat load for the package. Each cask that fails to meet the thermal acceptance criteria given in Annex L of the Application nust be withdrawn from service until corrective action can be completed or the license j;gg _-
[d h
amended to limit the package to a lower heat load. ) -
'I -
l' !
I
- The tnermal perfomance test is not required at periodic intervals ;
11 when the maximum decay heat load per package does not exceed 25% i
! O of the des 4gn heat iced. i*
11 m 16. The package authorized by this certificate is hereby approved for use under the !-
y 11 general license provisions of 10 CFR 971.12.
\\
Expiration date: June 30, 1985.
j 17. ,
3 "
11 I .
i I
E _ - - - - - - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ __
- . _ _ . . ae n.n e m e m e e r c e r e r- e n c ecercrece-erecerc c.c = ,
u.
. ., genomong go,ermae; 'sn'".c *D W c' .
l I
I g
l Page 5 - Cartificate No. 9015 - Revision No. 9 - Docket No. 71-9015 I
3 3
. REFERENCES 5
Thsnuclear, Inc. application dated April 9,1980. l October 31, 1980; June 17, 1981; May 3, and 27, 1983; May 1 Supplements dated:
1984; and February 25, 1985.
llI I
FOR THE U.S. NUC1. EAR REGULATORY COMMISSION l I
I I
' 4 h.DCha list.%cDonald, i/ Chief l
y@- Transportation Cei-tification Branch Division of Fuel Cycle, and Material Safety, NHSS l
i I
A, ., .
I Dated: %09 "- W .
l
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~
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I
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l' l
,i,'j i
b .E ll
\k l if I 'I ll !!
I l O lI
- I l
I il I;
- I
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I il 4
ll !i Il il l1l ol l 1 l :)
[ -----__ - __ .
- fbg\
g- ,.
NUCLIAR REGULATORY COMMISSION UNITED STATIS waaMINeTON, D. C. 20006 , _
- Transportation Certification Branch Ao proval Record Q .
Model Nos. Ti-8 and TN-al Packages Docket No. 71-9015 r
By application dated February 25, 1985 Transnuclear, Inc. requested a revision to Certificate of Compliance No. 9015 to pennit the shipment of solid non-fissile, irradiated hardware.
The applicant would provide shoring, as needed, to limit movement of the shipment (accident conditions of transport must be contents considered) during'he
. proposed contents would be within the presently authorized weight, thennal heat, and radiation limits.
The additional contents have no effect on the package's ability to meet the requirements of 10 CFR Part 71.
O Charles E. IdacDona d Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, titSS, Date: MR 0 71985 t
4 4
S I
4 l
- O 2 -.-----,-,--,+,,m, v---,,~,-rw or m ,w _ n-n ,,v v e, w wwmw-w~,,,. en_..-,,_ . - - .--w--.~~-a,--------
O. O O .
i Hear ,
' Shock .
i -
Absorbing
- Pront Cover .
l Shock Lead i Absorbing -
C-I Cover -
P1 Outer .g Front Shel1 -Fins g._
l Cover F2 Drum-Resin , - r N'P
[,q * I' ew s i ' r q Q yl' )j.
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g 7 ,
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' ../ t " .- -31 Trunnion pi y..,/
i *X \) .
j h p '/ '
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p[.Lli d,N jlj -
i
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K
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[# $
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l/ - Body Fuel Compartment (1)
.- sl-j D :g-(
\j Impact Limiter A 4- _/. y p3 .
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'----- T r u n n i on i N. . A a2 1
l i -
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I.i d X-Impact Lietter . .
L I.i d - Hechtss /o ussets) f j l.ifting -
i f.ug ( 4 ) >
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! M CASK OVERVII54 '
221 Sim: 6-2 BY MS. GELMAN:
2 Q Mr. Pickworth, please state. your full name and' 3 address.
. -(]' - 4 A (Witness Pickworth) Joseph M. Pickworth, Portsmouth ,
5 Virginia.
6 Q Mr. Pickworth, are you familiar with a document 7 dated May'9th,.1985 entitled " Testimony of Joseph M. Pickworth" 8 consisting of five pages and one appendix?
9 A Yes, I am.
10 Q Was it prepared by you or under your supervision 11 and direction?
12 A Yes.
A
() 13 Q Do you have 'any corrections to this testimony?
14 A None.
15 Q Is the testimony, to the best of your knowledge, 16 true and correct?
17 A Yes, it is. .
18 Q Do you adopt it as your testimony?
19 A Yes, I do.
20 0 Mr. Chairman, I move the admission of the 21 testimony of Joseph M. Pickworth into evidence and request
() 22 that it be bound into the transcript.
23 JUDGE WOLFE: Any objection?
24 MR. GURREN: No objection from the staff.
Aco-Federal Reporters. Inc.
25 MS. GELMAN: I will hand the clerk three copies of
222 Sim 6-3 j Mr. Pickworth's testimony.
2 JUDGE WOLFE: This testimony of Joseph M. Pickworth 3 is incorporated into the record as if read.
4 (The testimony of Joseph M. Pickworth follows:)
5 6
7 8
9 10 11 12 -
rm,
\ _ -)
13 14 15 16 17 18 19 20 21 J 22 23 24 Ace-Federal Reporters, Inc.
25
m-May 9, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In Ihe.' Matter _Of )
)
VIRGINIA ELECTRIC AND )
POWER COMPANY ) Docket Nos. 50-338/339-OLA-1
. ~)
, (North Anna Power )
Station,cUnits l'and 2) )
TESTIMONY OF JOSEPH M. PICKWORTH I*
- f i
~
' Introduction My name is Joseph M. Pickworth. I-am the Refueling Senior Reactor- Operator for Virginia Power's Surry Power Station in Surry, Virginia.
I'am responsible for the total inventory of nuclear fuel (both new'and spent fuel) 'and any movement of such' fuel in or out of the :Surry Power Station, aus well as for overseeing the
-implementation of the handling procedures that pertain to such fuel 1 movement, which I helped develop. I have worked for
(}. Virginia Power since 1975, starting out as a Quality Control inspector,'and switching in 1979 to the Operations Department.
In.1982 I became involved in refueling operations, specifically
- with fuel test programs and fuel shipping programs. My resume
' is attached to this testimony an Appendix 1.
=
m.
-I have been asked to address that portion of Concerned j(]) ~ Citizens of Louisa County's (CCLC) Consolidated Contention 1 dealing with human error. -My testimony, in summary, is that Virginia Power. employees are trained to properly implement Surry's cask handling procedures, thereby minimizing the likelihood of any human error in preparing casks for shipment.
II.
Development of the Cask Handling Procedures The Surry cask handling procedures were developed after experience gained from handling two different spent fuel casks
-- the model NLI 1/2 National' Lead Industries cask and the model 8L Transnuclear cask, the cask to be used fog the Surry-to-North Anna Shipments.
In 1983, I participated in a cask handling exercise involving the National Lead cask, as well as in the actual shipment of a dozen fuel pins to the Battelle Laboratory using that cask. In addition, in August 1983 I went to the AGNS facility in Barnwell, South Carolina, along with several of my colleagues who will be participating in the upcoming Surry shipment. There we obtained both hands-on experience with the model 8L Transnuclear cask, and training from Transnuclear in the use of the cask. After this experience, we identified potential problems specific to cask handling at Surry. The Surry cask handling procedures were subsequently developed
5 .
+ 7..
6 >
using!(1) the National Lead and Transnuclear generic cask handling' procedures, (2) ~ the operating manual for the LTransnuclear model 8L cask, and (3) the hands-on experience gained with the Transnuclear and National Lead casks.
III.
The Training Program For Cask Handling As is evident from its training program for. cask handling, Virginia Power is committed to the safe handling of spent fuel at the Surry'and North Anna Power Stations. The employees that will be involved in shipping the.Surry. fuel have had seven hours of class room instruction in cask handling and have
.O become certified crane operators after completing an 80-hodr course in crane operation and rigging given by the Crane /MIT Operator School. These employees obtained the experience with -
the Transnuclear cask previously mentioned at Barnwell,-South Carolina. Additionally, these employees have gone through a
" dry run" (without fuel) that took place at Surry in November 1983. Finally, a refresher course will be given this summer, informing employees of any minor changes in procedures. I am confident that Virginia Power employees are properly trained to 11mplement the cask handling procedures and that the casks will
~
(
~ w- be prepared-for shipment without significant error.
o
~'
s ;.
IV.
The Quality Assurance Program at Surry Virginia Power's Quality Assurance Program is. involved in all integrity tests of the spent. fuel cavity including (1) drying tests to insure that the fuel remains dry; (2) the torquing of the bolts on the lid and other penetrations leading to the fuel cavity; (3) the testing of the pressure inside the fuel cavity; and (4).the testing of the "O-ring" seal on the cask lid and on all other penetrations into the fuel cavity.
Thus, whenever a step affecting safety is taken that requires that its performance be verified by readings of pressure,
-( ) torque, etc., these values are designated as "QC" holdpoints in the cask handling procedures and must be confirmed by a Quality Control inspector. ,
Additionally, after the cask is loaded onto the truck and ready to leave the site, the Quality Assurance team ensures (1) that the truck contains the proper placard identifying radioactive material in accordance with DOT and ANSI standards, (2) that the required radiation surveys are done, and (3) that inspections of the truck and the trailer are carried out.
These Quality Assurance checks provide added confidence
~N that the casks will be prepared for shipment without l (O significant error.
(
l t.
.-s- -
+
V. ,
Conclusion C; .
The Surry cask handling procedures were developed after significant experience handling spent fuel casks. Virginia Power. employees have been properly trained to implement these procedures, and Virginia Power's Quality Assurance Program provides an additional layer of confidence that the'se
-procedures will be properly implemented. These factors make it unlikely that any significant error will occur during the '
preparation of the casks for shipment from Surry to North Anna.
p.
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Appsndix 1 i s
JOSEPH M. PICKWORTH
~O v
EDUCATION Civilian: Youngstown University (3 years completed);
Tidewater Community College, Associate Degree in Science and Accounting Military: Military Equipment School POSITION Refueling. Senior Operator for Surry Power Station in Surry, Virginia.
EXPERIENCE Civilian: 1979 to present i Virginia Electric and Power Company (Virginia j"')
(_ : Power). As Refueling Senior Reactor Operator, I am responsible for the total inventory of nuclear fuel and any. movement of nuclear fuel in or out of the Surry Power Station. I joined the Operations Department-and obtained my
.- Senior-Reactor Operator-license in 1979. In 1982 I became involved with refueling opera-tions, including fuel' test programs and fuel shipping programs.
1975 to.1979 Virginia Power and Electric Company Quality
' Control Inspector.
Military: Electrician's Mate First Class, United States Navy. Eight years active service completed.
. My service experience included training of personnel; supervision of maintenance and-17~ repair of new systems and equipment; super-((_): vision of installation, tests and inspections of new equipment and systems; maintenance ~and operation of electrical power units and auxiliaries associated with conventional and nuclear power plants; history record mainte-nance of' electrical and mechanical systems and components; and developing procedures for quality control of maintenance / repair of nuclear power plants.
. . _ . . . _ _ _ . _ . ~ . - _ . _ . . _ . - _ . _ . . _ . _ . _ . _ . - ; . . _ _ . _ . _ .._.
223 Sim 6-4 j BY MS. GELMAN:
2 Q Mr. McCrerry, would you please breifly summarize 3 your testimony.
4 A (Witness McCreery) My testimony consists of 5 a description of a cask, some of its safety features and how 6 the cask is handled.
7 The cask is described in the cask overview shown 8 n the last page of my testimony. -Briefly,' starting from 9 the inside of the cask out, there are three pressure vessels 10 that are 90 inches square and about 165 inches long, each of ji which will hold.a pressurized water assembly, a fuel assembly.
12 These pressure vessels arc separated by boron
/'
(_) 13 carbide and copper plates for neutron boiling and heat transfer 14 They are surrounded by lead which in turn is surrounded by 15 one to two inches of steel.
16 Between the lead and the steel there is a layer 17 of wet cement. This serves the function of a thermal switch.
18 As long as the cask is not under fire incident conditions, 19 the wet cement.will conduct heat. If fire incident proportions 20 are applied to the outside the cement can become dry and 21 it will reduce the heat flow into the cask.
(
(,) 22 Beyond the steel shell there is a layer of resin 23 which acts as a neutron shield and through this resin and 24 extending on beyond the resin are heat dissipating fins.
Ace-Federal Reporters, Inc.
25 The cask has several penetrations into this l
l l
1
3 1
224 l Sim 6-5 1 ' primary cavity of pressure: vessel.- The main-penetration of 2 'cour'se is the lid itself which is sealed with two concentric
. m 3 '"O" rings, and within the. lid there are penetrations identified 4 as'"A" and "B". The "A" penetration is used in cask 5 operations for-doing_the vacuum drawing. Where a larger
~
6 access to the cask is required, then it would be accessible 7 !through the "B" connection.
8 The'"B" connection is-supplied with'a Hansen
'9 . quick disconnect' coupling, and this is"to permit the attachment' 10 of Ivarious instruments to the cask for reading out pressures
~
11 and 'for emiting nitrogen to the cask before . it is shipped. -
12 There is one other penetration at the bottom of 11 3 'the' cask which is used. It is called the drain valve, but 14 it is.used both to drain and fill the cask.
15 And there is identified a "D" opening, which is 16 not_ a penetration, into the cask cavity. It provides an.
p 17 opening between the "O" rings of the lid to enable tes ting. .
18 The "C"' opening also has a Hansen quick disconnect
-19 in it.
20 Each of these penetrations has been approved by_-
[.
21 NRC and with - the requirercent of only one sealing gasket.. Due
'22 _to the inhernet way the cask is operated, all but one of these 23 has a secondary seal that is as effective as the first. So 24 on all but one of the penetrations there is redundant sealing.
Am hp.mri, Inc.
25 In the event of an acciddent the cask is provided l
!1 L. .
1 l
l 225 l Sim 6-6 j with front and real shock absorbing covers, and each of the six trunnions on the cask, which are used to handle the cask, 2
there is provided an impact limiter.
3
/)
4 The cask tie-downs are not shown in this particular drawing, but they are shown very clearly in the photographs 5
that you have. I would mention of course that the cask tie-6 downs are not absolutely necessary to keep the cask in place 7
n the trailer. It will stay there without the cask tie-downs 8
9 unless the trailer is overturned.
10 S me f the safety features of the cask are that, jj first, it is shipped dry. That means with no water in the 12 cask. There is no water to turn to steam in the event of C 13 higher temperatures.
The cask was designed to handle fuel that is out 34 f the reactor for only about six months, and the fuel being 15 16 shipped from Surry will have been out of the reactor for five years.
17 The design capacity of the cask is that it will 18 handle fuel of much greater heat dissipation and much hotter 39 radioactively than this fuel that will be shipped. So it 20 has this inherent safety factor just because the fuel is older 21 v.
) than that for which the cask is designed.
22 As I mentioned, this truck cask carries three 23 24 PWR assemblies. This is the maximum payload that can be Ace-Federal Reporters, Inc.
carried by a truck with any cask of present design. The 25
1 l
226 Sim 6-7 1 only alternatie to- this would be to use casks carrying only 2 one assembly, which would be that you would have three times 3 3 as many shipments to make.
(J l4 Now I mentioned the fact that we have double seals 5 throughout the cask with one exception, and that these seals 6 are a rubber-like material as opposed to using a metallic 7 ' seal, ~ which is another option. The metallic seals can be 8 rather easily damaged and must be replaced if they are damaged.
9 Whereas, the rubber-like seals if they are deformed will tend 10 to' store their own geometry and still function effectively.
11 The cask is quite simply. designed making it easy-12 to handle, and of course, in accordance with NRC regulations,
)- 13 it is designed to be handled in extreme accident conditions.
14 The cask handling procedures cover every step 15 of the operation from the time the_ cask arrives at the site 16 until it leaves again. When the cask arrives at the site 17 the protective devices are first removed, the cask is taken 18 into a special work area, a skirt is placed around the cask 19 to protect the main . cooling fins that are on the surface of 20 it so that they will not be contaminated by pool water and 21 taken an excessively long time to decontaminate before shipment.
,R.
\ l' 22 Then the 16 bolts that hold the lid in place are 23 removed, the cask is filled with water and taken to the pool' 24 to be loaded.
Ace-Fedorol Reporters, Inc.
25 The lid is removed while the cask is under water,
=
i l
1 227 Sim'6-8 The- lid is lif ted out of the pool to give us an opportunity j
to closely inspect the gaskets in the lid and if there are 2
.1 any.defectives found they are replaced. '
3 V 4 The three assemblies will be loaded into the cask and the cask-lid is replaced again'while the cask is under 5
water. The cask will be lifted out of the water and four 6
bolts will be replaced in the lid and hand tightened for 7
the' journey from the pool to the work area.
8 Then another template described in the order 9
10 of: bolt tightening'is placed on the cask, and all 16 bolts j; are tightened to 290 foot-pounds with calibrated torque 4
12 wrenches. The water is drained from the cask and the leak-( 13 tightness of the lid is checked through the "D" opening.
.j4 Air is evacuated from the cask and the intervening
.f 15 m isture is eporated by the vacuum drying system. When the ask pressure inside reaches 20 millibars or less, the 16 j7 ten. minute. test is performed, and the pressure rises no m re than three millibars during this ten minutes, 18 j9 The cask is then considered to be dry and the 20 seals that are involved in the vacuum drying test are 21 functioning properly.
C-
-v 22 Then the cask is back-filled with nitrogen to 23 . Prevent oxidation of the fuel. It is back filled to one 24 atmosphere so thht there is no pressure differential across hFederal Reporters, Inc.
25 the seals.
l 228 Sim 6-9 1 Then the remaining penetrations are checked again 2 by vacuum leak-tightness checking.
,x
^
3 The skirt is removed and the cask is secured 4 on the trailer with its tie-downs. The protective devices 5 are added and security seals are added at each end to indicate 6 any tampering that might have taken place en route.
7 And these procedures are repeated at the other end 8 when the cask is unloaded, except for the fact that the final 9 leak testing on the seal is not perforned on the empty cask.
10 These procedures have been carefully. thought out. ,
11 They represent 500 years of operation.
They are made to 12 be quite detailed, but in terms that operators can readily
'/-
13 understand.
14 The operators are continuously checked by other 15 supervisors and, in addition, critical points such as 16 torquing and pressure readings are checked independently by 17 someone from the Quality Assurance organization.
18 And with the redundant type checks that are 19 inherent to this system, first the vacuum drying and then 20 the follow-up leak testing, any accident that might take 21 place that could cause any considerable harm would have to
/'~3 -
/ 22 be the result of a two or more unrelated and unlikely events 23 that would take place during these cask handling operations.
I 24 Q Mr. Pickworth, could you please briefly summarize l Ace-FWwol Reporters, loc. I 25 !
your testimony?
l
7 229 Sim 6-10 1 A (Witness Pickworth) Well, one, the Virginia 2 Power employees that are involved in handling the shipping l
_ 3 casks have been trained in procedures as described by l l
l Such procedures have been approved by Vepco
~
4 Mr. MCcreery. I 5 and will'be utilized. 1 6 These procedures are based on previous exercises 7 using both the'transnuclear cask and a similar cask, a 8 National Lead cask.
9 Exercises for the National Lead cask were 10 conducted at Surry. Actual fuel shipments have been conducted 11 at Surry using the National Lead cask. The Transnuclear 12 cask exercises have been conducted both at North Anna -and rn
(_) 13 the Surry Power Stations, and an initial exercise has been 14 conducted at the Barnwell, South Carolina facility.
15 All of these exercises were in attendance by the 16 people who will be handling the casks for any shipments 17 from Surry.
18 MS. GELMAN: We are ready for cross-examination, 19 Judge.
20 JUDGE WOLFE: Mr. Dougherty.
21 ' CROSS-EXAMINATION'
~
22 ' BY MR.- DOUGHERTY: _
23 Q Mr. McCrerry, the recent change in your testimony 24 arouses my interest. Unfortunately, I didn't hear exactly Ace Federal R'eporters, Inc.
25 what you had to say what the change in the testimony was, and
230 Sim'6-11 1
-I would-like.to ask you.a couple of questions about it.
2 This incident occurred at which reactor?
'3 g- (Witness'McCreery) Oyster Creek, New Jersey.
O d 4
-0 And when did it happen?
5 A' April 30th of this year.-
6
'Q Now, as I understand,'shipm nts of spen,t. fuel 7 are'now being made from-Morris' to Oyster Creek; is that 8 correct?
. 9 g No, it'is not.
10 Q Are shipments being made to Oyster Creek?
II A- Yes, they are.
12 '
Q- Where are they coming from?
13' A West Valley, New York.
'I4 Q I-wonder if you~would describe again for us 15 what' happened.
l0 A When the cask is filled with water prior to
'I7 putting it into the' pool, and this is done because if you i
-18 don't fill it with water a large bubble of air will come up-possibly causing some-airborne contamination which is 20
{} .to be avoided.
2I When the cask is filled with water, they observe 22 the overflow point and stop filling at that point. And for l .
23 ~
p this ' purpose they use a sectional transparent hose tubing, l 24 and the transparent hose which they were using had become Ace-Federal lleporters, Inc.
clouded. So they replaced it with a new section. .
It is l
o l- - - . . . . _ - . . _ _ _ _ . _ _ _ _ , , _ . _ . ,. . _ _ . . . - - - - . , , _ _ - _ - , _ . . - - _ - _ _ _ _ _ - . . . , . - --
231 Sim 6-12 I not-Chicago fitting, but it is a Chicago type fitting, which 2 is'a quick' cup and twist connector. And they added a gasket 3 similar to that used in a garden hose. The gaskets were c
lf3 V 4 not in 'this particular hose section. So as the water 5 overflowed from the' cask it came through this hose section.
6 It created a little water out through these 7 connections, and since this takes place at the top of the 8 cask, which is roughly 16 or 17 feet high, the water dripped 9 down'on the people who were working on .the bottom of the 10 cask.
'II Q -How much water are we talking about?
I2 A Less than a quart.
O 'a o And you seid ehee ehe estimeeed occuvee1one1 I4 exposure was what?
15 A The maximum exposure-to the skin was 2.5 ,MR.
16 There was no internal contamination.
17 0 You indicated that the procedure that the
~18 employees were then involved in was not covered by the cask 19 . handling procedures.
20 g- This would be a station procedure for making up 21 hoses. The cask handling procedure has an attachment at 22 the top of the cask to which this hose is connected.
23 Q I take it then that there are a number of 24 activities involved in unloading and reloading casks that Ace-Fedorol Reporters, Inc.
25 are not covered by the written cask handling procedures;
4 232 Sim 6 _j is that right?
2 A "*11' quality Procedures are separate procedures.
3 There are many, many administrative procedures that are
~(~)
'~' documented at the beginning.
4 For instance, the Oyster 5
Creek procedures, they must list 50 administrative procedures 1
6 that are to be considered when cask unloading operations are 7 taking place.
8 Q: Thank you. I would like to get back to the 9 same sentence on page 14 of your testimony. You changed 10 it by deleting 'the' words "to my knowledge" and substituting 11 the words "with one exception." That sentence now reads 12 "With one exception, there have been no instances of human L() 13 error- of any consequence associated with any of these j4 cask operations."
15 A Perhaps-that should better read "To my knowledge, 16 with one exception, there have been on instances. . .
j7 'Q Could you tell me what you mean by the term 18 "these cask operations"?
19 A In this particular sentence it means the 20 activities of the Transnuclear cask and some activities of 21 some of the other spent fuel shipping casks in this country n
- () 22 with which I have been associated with in the past.
23 Q So are you referring to the entire history of 24 spent fuel shipping in casks, or just ---
Ace-Fedorol Reporters, Inc.
25 A I am referring to that part with which I am I
233' 3-14 1 ' familiar.
2 Q And what fraction of the total history of 3 shipping are you familiar with! roughly?
f)/
4 A' Oh, roughly half.
5 Q. Can you tell me what you mean by the term 6 " human error of any consequene"?. I wonder if what you mean 7 _is human errors of any consequence to you or of any
.8 consequence to a utility or consequence to the public, or 9 just what were you getting at with that term?
10 A Of any consequence to_those primarily involved
~11 which in turn would indicate that if there was no consequence 12 to those people that the consequence would not extend beyond
-f 3 ,3j 13 those people. And by consequences there, it was based on
'14 the fact that whatever contamination they might have received, 15 it was readily removed and it was in very small amounts.
16 Q I am not sure I understand. Are you talking 17 about incidents involving exposures that were subsequently 18 remedied?
19 A Yes.
-20 Q I would like to talk for a minute about human 21 errors of little consequence, as you make this distinction.
f
(,) 22 How many instances are you familiar with in which there have 23 been an incidence of-human error in cask handling in which 24 there may not have been significant occupational exposure, AceFederal Reporters, Inc.
25 or, as you put it, an exposure with consequences?
i 234 Sim 6--15 A- There are:very:few-that'I-know of,that are of n - hsequen e.. >They probably would be retained in my 2
memory.
-h 4 Q Wouldn'6 you say: tho~ ugh that some~of'these: incident s
~
are nevertheless relevant to our examination of this issue?
5 A No, I would not.
6
.Q Wouldn'.t you think that if there was a demonstrat ad 7
. history of failure _to properly seal casks, for example, and 8
that'to date, because of the relatively low number of ship-9 ments those mistakes had not resulted in substantial human 10 jj exposures, . thatEthat. would- be the kind of information that w uld be relevant to our' contention?
12 A If.there had been a demonstrated signficance, 13 .
.j4 but there: hasn' t been.
.Q Are.y u aware f any instan es in which utility l 15 Personnel or. shipping.' personnel have failed to comply with
.16 j7 the required cask h'andling procedures despite the existence jg of any adverse effects or consequences?
j9 A When a station begins'using one of these casks,.
20 Transnuclear provides personnel, such as myself, to observe.
21 theifirst four or five or six shipments, and during this time 22 we . call to their attention any misinterpretation that might 23 be made of the instructions and work to improve the clarity 24 of the instructions during this period.
As. w hporem, Inc.
25 And sometimes very minor incidences, such as
235 Sim 6-16 1 tightening the bolts out of sequence, has been observed, yes.
2 Q It sounds like these incidences aren't that 3 rare.
k_) 4 A They are rare compared to the number of 5 operations they do.
6 Q When you used the phrase "to my knowledge, 7 there have been no instances of human error," does that 8 imply that you have conducted a survey of utility practices 9 or accident histories?
10 A I am quite familiar with many of the reactor 11 sites in this country and a few in Europe, I have contacts .
-12 at other reactor sites and I have had a chance to observe I'l 13 operations at many reactor sites.
V 14 Q But you haven' t made it a point of trying to 15 contact utilities or shippers to ask what the frequency 16 -or history of cask handling errors has been?
17 A Not formally, no.
18 Q Do you know if such studies have ever been done?
19 or taken?
20 A No, I don't.
21 Q Is it fair to say that when it comes to the 22 history of cask handling errors generally that you are more
(
23 less ignorant on the statistical record?
24 A On the basis of statistical variation or limits Ace-Fedorol Reporters. Inc.
25 of error, I would have to plead ignorance, but those of us
1 236 6 m 6117 involved 'in this type-of work have a fairly free exchange l1
.2 of information. We don't try to'h'ide'anything from each
(
3 other'that-might-be detrimental to the industry.
i
() L4 Q Well, thank you very much. I would like to 5 talk about human errors in transportation of radioactive 6 materials-that pose somewhat less of'a hazard than spent fuel 7 shipments, 'for example, if employees failed to seal the 8 covers on 55 gallon drums of yellow cake or low-level waste 4
9 or something. Are you-. aware of any incidents involving human.
10 error in those kinds of sh'ipments?.
.11 .A I am not involved in those kinds of shipments.
I Are you involved with shipments of fresh nudlear 12 O' P; 13 fuel?
u 14 A No.
15 Q Are you aware of the current NRC and utility 16 Projections as to the increasing number of spent fuel 17- . shipments that are expected over the next decade or so?
18 A Yes, I am..
19 0 Would you say that if this increase is borne out
~
20 that _we are likely to have more accidents or more incidents 21 of human error or less?
L
( 22 A Oh, I am certain we will in proportion to the 23 number'of shipments.
24 MR. DOUGHERTY: I have no further questions, hFederal Reporters, Inc.
25 Judge.
237 LSim 6-18; .j JUDGE WOLFE: Mr. McGurren.
2 CROSS-EXAMINATION 3 BY MR. McGURREN:
p)
(_ 4 Q ter.~McCrerry, would you personally, please, 5 turn to page 14 of your testimony?
6 A (Witness McCreery) All right.
7 Q I just have a few questions about procedures. .
8 On page 14 under the heading " Cask Handling 9 Procedures" you go on for several.pages through 16 and in 10 the bottom paragraph you say " operating procedure." Are 11 we talking about the same types of procedures here?
12 -A Yes, cask handling and operating procedures.
()I 13 Q Are - these the procedures that are -identified 14 in Licensee's Exhibits 1 and 2?
15 A I b'elieve so.
16 Q Let me just make sure that we are talking about 17 the same thing.
18 I am showing the witness, Your Honor, Licensee's 19 Exhibits 1 and 2.
20 (Pause.)
21 WITNESS McCRERRY: Yes, they appear to be, i
- f'T 22 BY MR. McGURREN:
-V 23 Q And these procedures were developed by who?
?
c 24 A :(Witness McCreery) When a cask licensee submits W.dwat it.portes, lac.
25 a cask to the NRC for approval, it is accompanied by a generic l
l l
238
.Sim 6-19 j operating procedure, which is a part of the safety analysis 2
freport. When a station ~uses one of these casks, they1are 3 given a copy of this _ generic procedure from which they write
} 4 their own procedure making'it site specific. Then we in turn 5 review that procedure of the site to make sure that it does 6 not violate Jin any way the . generic procedure before the
.7 . procedure can be put into effect' at the site.
8 Q- All right._ So as I understand it, Licensee's 9 . Exhibits 1 and 2 represent what you have described in your 10 testimony as procedures which are not, as you state, inconsis-11 tent with "a generic procedure"?
12 A That is correct.
f() 13 Q Now a generic procedure I think~you reference 14 oon page' 17, about midway down. the - page; is that correct?
You say "A generic operating procedure _has been approved by
~
15 16 the NRC?
17 A Yes.
18 -Q.
All right. Now what form does that NRC approval ~
19 of that generic operating procedure take?
. 20 A A certificate of compliance. for the cask.
'21 -Q- I don't know, but tell me if you are familiar or
'22 not.. What is the certificate of compliance that is relevant
)
23 to-this particular TN-8L cask?
24 JL. It is a part of the attachment to my testimony.-
m sepwien, Inc.
25 It is Certificate of Compliance No. 9015, Revision 9, and pndcSim it is dated March lith, 1985.
'JoeEfols-
7-1-W21 239 1 CROSS EXAMINATION l
BY MR. McGURREN: ;(Continuing)
'l6- l
- 2
, 3. O I'have a questions about the TNAL casts. I take d
~ '
4 Lit that TN stands for Trans-Nuclear, is that correct?
5 A (Witness McCurdy) That is correct.
6 Q .Can you tell me how many of these TNALs are in I 7 the. United States?
8 A There are two in the United States, i
9 Q Could you tell me how many you would use for ,
10 this proposal that we are discussing here?
11 ! A Either one or two, depending on the shipping t
12 schedule.
13 -Q Where were these casts manufactured?
14 [ A They were manufactured in Lyon, France.
15 Q Do you have any idea of expected service life 16 ' of the TNAL cast?
.17 A I would estimate 20 years.- ,
181 Q Could you tell me who designed the TNAL cast?
If
.. p
'19 3 A It was designed by the TN. Paris office, but I 20 can't tell you who the designers were.
.il ; ..
Q The TNAL cast, my question concerns whether a O. ..-
J22 l particular type of trailer is required for the use of the TNAL?
23 ! A We use a special trailer for it. One designed --
'24 built into the trailer.
Am-FWwd Reorms. w. j 25 Q How many of those are there? ;
I I
L 1 : ,.
7-2-W21 240 s
s 1 A How many tr ailers?
2 Q That is correct?
73 3 A I think there are three right now. l u 4 MR. McGURREN: Your Hcncr, that is all the Staff 5 has.
6 JUDGE WOLFE: Redirect, Ms. Gelman?
7 MS. GELMAN: Not at this time, Your Honor. i l
8 JUDGE WOLFE: Are we going to proceed to Board i 9 questions?
I I
XXXXX 10 BOARD EXAMINATION 11 BY JUDGE FERGUSON:
i 12 ; Q Mr. McCurdy, let me just get you to clarify 3/
13 b something for me. In response a question Mr. Dougherty asked 14 ' you, your response was, I think, essentially that you are aware 15 of roughly one-half of something, and I missed the something.
16 ' A That was the total spent fuel transportation 37 activities that have taken place in the United States.
Q Could you tell us why you are unaware of that 18l ;l
!9 one half,-- the one half you are aware of versus the one half 20 that you are not aware of.
21 , A We have competitors in this business, Nuclear A l
-tsJ Assurance Corporation, General Electric, and at one time 22 l 23 Westinghouse.
24 And there are some limits to the amount of ,
Am FWwd Rgertws. loc 25 information that is exchanged, all four companies in the spent li
7-3-W21 241 i fuel. ,
2 Q But I think you later testified that there is 3 free exchange between persons involved in businesses of this ;
i \
4 kind, is that correct?
5 A I feel there is a fairly free exchange of f i 6 information. Not of incidentals, but of anything important.
7 Q So, would it be your testimony that although 8 you don't know one hundred percent of all of the transporation 9 events, you are familiar with one half, and one half that you 10 are not familiar with are not significant? -
I' 11 ! A I wouldn't say they are not significant. They 12 " were performed by other companies and I am simply not aware of g
13 what transpired in those shipments.
la O Would you feel comfortable to say that nothing --
15 maybe I shouldn't testify for you -- tell me what you would 16 say about those?
- 7 Characterize the one-half that you are not 18 , familiar with; that is why are you not familiar with them other 19 than the fact that they were done by someone else?
l 20 A I think that would be the main reason I am not I
21 ] familiar with them because they were done by somebody else.
/~ ) d k/ 22 h Q What I am trying to get at, Mr. McCreery,is whether 23 or not there was anything that occurred in those one-half of the 24 total shipments that you are unaware of that we should know Am-Feded Reporters, Inc.
25 about?
7-4-W21 242 1
- A Certainly not that I am aware of.
2 Q Let me turn to you, Mr. Pickworth, for a moment.
3 In looking at --
(~/)
\- JUDGE WOLFE: When you said, Mr. Dougherty, that 4
5 you had completed your cross examination, that was just of
^
6 Mr. McCreery or did you mean that you were finished with your 7
cross examination of both men?
~
8 MR. DOUGHERTY: I have no questions of Mr.
9 Pickworth.
10 JUDGE WOLFE: No questions.
11 , BY JUDGE FERGUSON: (Continuing)
I 12 ) Q Turning to you, Mr. Pickworth, let me ask you to it
()
, 33 look to page 3 of your prepared testimony, and will you clarify
~
.y for me what you mean by the last sentence on page 3, where you 15 state I am confident that Virginia Power employees are properly 16 " trained to implement the cask handling procedures and that 17 cask will be prepared for shipment without significant error.
18 ' I am focusina on the last three words; what do 0
19 you mean by, 'without significant error?'
i
' 20 - A (Witness Pickworth) That'all tasks required by 21 i ! the engineering procedure will be accomplished. Would be O 22 1 verified.
I a
Thee a11 hee 1th ghrsics asgeces within the rea1m
'l of the health physics department of VEPCO requirements are 23
- 24 satisfied.
Aca-Federd Reporters, Inc.
25 In that respect, there should not, or will not, be 1
[' f !
243 7-5-Wali 1 -a significant error in a shipment, or any shipment.
2 Q The thing that is unclear is based on what you have 13 just replied. It seems to me that there will-be no error, but
,4
~
this statement'says, 'without significant error. ' And that-5 is'wh'at-I am unclear about.
6 Can you help me? Will there be an error? Or is ,
'i 7 .there'a-possibility of errors? i 8 A Not within the realm of the handling procedures ,
9 of the cask, no.
.10 Q Well, then, clarify what you'mean by the last 11 three words in that sentence?
!) -
A The. procedures that we have generated that-
- 12 ]
c ' 13 ' : reflect. the. generic procedures of Trans-Nuclear give us an
- 14 ' assurance, and its assurance is depicted in the procedures 15? Eby having the quality assurance function of what we are doing, 16i! that we do ship something that meets all those requirements,-
~
17J and thus by Trans-Nuc' lear saying that these tests provides i
' 18 ; an integral casi, no significant error would result in
. b 19 I satisfying the requirements.
1 i
20 O Errors are possible, but~ you say they are not 21 j . significant, is that another.way of rephrasing it?
_i 22 -A That is correct.
' 23 ~ Q On that same page, you refer to you,r operators
.24 receiving training by Cranes /MIT Operator School. What is me.-red.co n.oorters, inc.
25 a Crane /MIT Operator' School?
7-6-W21 244 s ,.
i A. Crans/MIT Operator School is a company that i
2 trains operators, crane inspections, et cetera.
3 They are hired by VEPCO to do crane inspections, !
4 and to do crane' training. They have an eighty hour course 5 which meets ' the certification requirements of ANSE standards, I 6 I believe.
7 I am not sure of the specifics, but they do 8 Provide what they call an eighty. hour certified course. !
9 Q Are you familiar with the contents of that [
10 course?
11 A o not the specifics of the course.
N, 12 ' O -DO.you know if the course contains any training
. 13 in the understanding of radioactivity?
ja ' A .That is not included in the crane operators course.
15 0 I believe- your testimony suggests that you are-16 responsible for these operators. Could you tell us what kind
_ :7 ' of instructions are given to the operators as regards what isy radioactivity is and its significance?
a il 19 A First off, all employees go through a general i
~
20 ' employee training program which gives a view of what radio-21 !! activity-is ---what its effects are.
Is/ 22 This program is a continuing thing. It is not 1
23 like a one shot deal. Every year you go through what we call a-24 general employee qualification program.
hen-Federd Reporters, Inc.
25 Beyond that, we operate with health physics i l-l l.
7-7-Wal 245 i
)
i i
i department, and any radioactive-type work is covered by what ,
i 2 we call a Radioactive Worker Permit, where the health !
3 physics actual involvement is incurred. I
/_
' )
"/
4 In this case, both those apply. The fact that 5 we have'a general training, retraining the RWP and the health .
6 physics involvement.
7 Q Thank you for that. I think that is important 8l to include in the record at this particular time.
I 9' I have nothing further.
10 A Yes, sir.
JUDGE WOLFE: All right. Before we take our 11 { ,
12 mid-morning recess, are there any individuals in the audience o
(_) 13 who wish to make a limited appearance statement?
i1 (No response.)
15 JUDGE WOLFE: All right. We will recess now 16 ' until 11:15. Yes, 11:15.
- 7 (Short recess taken.)
18 JUDGE WOLFE: All right. We are back on the 19 record. The Board has no other questions of the two witnesses.
l 20 l Do you have any cross examination in light of the Board 21 j questions -- based upon the Board's questions, Mr. Doughtety.
/m \
(,.) 22l MR. DOUGHERTY: No, I don't, Judge.
H 23 JUDGE WOLFE: Mr. McGurren?
24 MR. McGURREN: No questions, Your Honor.
Ace-FederJ Reporters, Inc.
25 JUDGE WOLFE: Anything, Ms. Gelman?
7-8-Wnl - 246' i i
1 ES. GELMAN: No, Your Honor. j 2 JUDGE ~WOLFE: All right. The two witnesses are
- '3 excused. Are they to be excused permanently?
(.
~
4 MS. GELMAN: Yes, sir.
5 (PANEL STANDS ASIDE.)
6 JUDGE WOLFE: Are you ready to call the next 7 witness?
g MR. MAUPIN: We call Marvin L. Smith, please.
-9 JUDGE WOLFE: Mr. Smith?
10 Whereupon, 11 MARVIN L. SMITH, 12 !'l; was called as a witness on behalf of the Applicant, and being
- .i 13 first duly sworn, testified as follows:
XXXX INDEX 1.1 DIRECT EXAMINATION 15 BY MR. MAUPIN:
16 Q Mr. Smith, will you state your name and your
- 7- residence -- address for the Board, please?
( 18 A Marvin L. Smith, 5707 L'illview Drive, Mechanicsville, i 0 l 19 ' _ Virginia.
I. !
20 l Q Mr. Smith, I have here a document -- typewritten
! 21 document entitled, Testimony of Marvin L. Smith (I). The i
i 22 ! title is followed by (1) in parenthesis. It is dated May 9, l
l- 23 1985.
24 It consists of 19 pages, and have four appendices Ecs-Feder:;5 Reporters, Inc.
25 attached to it. Have you reviewed this document?
I i
7-9-Wal 247
_- j 'A Yes.
2 0 Was it. prepared by you or under your supervision l
l 3 and direction? '
(). 4 A Yes.
5 Q Is it true and correct to the best of your knowledge 1
6 and belief? !
7 A' Yes, it is.
8 Q Do you adopt it as your testimony in.this :
9 proceeding?- ,
i-A Yes, I do. !
10 ,
11 f Q Judge Wolfe, I move the admission into evidence 12 h .of the testimony of Marvil'L. Smith, and ask that you instruct-l 13 that-it be bound into the record at this point as if read?
14 JUDGE WOLFE: Any objection?
15 MR. McGURREN: No objection.
16 MR. DOUGHERTY: No objection.
- 7 JUDGE WOLFE
- The testimony of Marvin L. Smith, 18 that 'was Roman I?
l d I!
19 ~ MR. MAUPIN: Roman I.
j' is o
20 i JUDGE WOLFE: Roman I is incorporated:-into the l
r
~ 21 !L . record as if read.
XX DEX 22 (Document follows.)
e 23 i
24 p-Fenero neporters, Inc.
L 25 l
y lg May 9, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD
.In the Matter of )
)
VIRGINIA ELECTRIC AND POWER ) Docket Nos. 50-338/339-OLA-1 COMPANY )
)
(North Anna Power Station, )
Units 1 and 2) )
TESTIMONY OF MARVIN L. SMITH (I)
I.
Introduction My-name is Marvin L. . Smith. I am a Supervisor, Nuclear of g Engineering for Virginia Electric and Power Company (Virginia G Power). In my present position, I am responsible for: (a) super-vising the Nuclear Systems Analysis group responsible for radwaste projects engineering support, coordination of ALARA and ALARA analysis for engineering, radiation shielding analysis, and reli-ability analysis, (b) managing the Virginia Power / Department of Energy / Electric Power Research Institute Cooperative Agreement Program, described below, on dry cask storage of spent nuclear fuel, (c) serving as Virginia Power's representative to the Edison Electric Institute-sponsored Utility. Nuclear Waste Management Group (UNWMG) high level waste working group, and (d) chairing
() the Electric Power Research Institute (EPRI) external fuel cycle subcommittee, which funds research on nuclear waste issues.
I have been involved in the development and implementation of Virginia Power's plans for interim spent fuel storage since S
.r- y,
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- 3 [' . l [ s s .;
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1981. 1I'am-currently responsible for the' coordination and
. implementation of VirginiY' Power's efforts to provide for interim h storage of its spent" fuel. This requires ~ staying abreast-of our
- need for additional space, including when such sp3ce must be available, and the alternatives Virginia Power has;,to satisfy those needs.. My resume ls atk: ached to this testimony as Appendix
' l. gs In the testimony that follows, I will describe.the current status of spent fuel' storage space in the Surry Power Station spent fuel pool, Virginia Power's plans for the use of dry casks to, store spent fuel, the comparative costs of dry cask storage and.Surry-to-North Anna fuel shipments, and the environmental-
. effects of each alternative. I will also explain why Virginia
.p. Power believes that it is essential to have the authority to V
store Surry fuel at North Anna,'which we seek in t.his proceeding, even if it also receives permission to' operate a" dry cask facility at Surry.
II.
Loss of Full Core Reserve at Surrv A. Storage space in the Surry spent fuel pool ;
Appendix 2 to this testimony sets out the number of spent i
. fuel assemblies currently stored in.the Surry and North Anna
- spent fuel pools and the projected increases in spent fuel d - storage needs through 2005. As indicated '.n this Appendix, Virginia Power will have 886 fuel assemblies (one space is occupied by a canister of fuel rods rather than an intact asserbly) stored in the Surry spent fuel pool at the end of 1985.
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Thisfis ~158 fuel assemblies less than the total capacity - 1044 fuel assemblies 'of-the Surry spent fuel pool racks.
~ Number of spaces required for a' full core discharge
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]. B.
Each of the two- Surry reactor . cores contains 157. fuel assem-
.blies. Thus,11f the reactor core from either Surry unit must be discharged in. order to perform inspections or maintenance activ-
- ities, 157 spaces must be.available to store the spent fuel. We call these 157 spaces " full' core reserve.'"
C. Importance of maintaining full core reserve Virginia Power has had to use full core reserve'at Surry in ,
, the past for steam generator replacement, in-service inspections ,
. and replacement of control rod guide tub.es. If we have to remove a full core in the future in order to perform work that is essen-l) tial to continued operation, and if the full core reserve spaces are not available in the Surry spent fuel pool, an extended,
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- expensive outage will result. Such an outage would require the i purchase of replacement power at a cost of approximately $300,000 i . per day.for one Surry unit.- .Th e outage:would continue until g
arrangements could be made to provide increased storage capacity.
- Prudence, therefore, requires that we make _ every reasonable effort to maintain full core reserve.
The importance of maintaining full core reserve is borne cut Eby a recent-Nuclear Regulatory Commission (NRC) finding. Section s .
~ 135 (b) (2) of the Nuclear Waste Policy Act of 1982 requires NRC to l : o determine whether maintenance of full core reserve is necessary for continued orderly operation of civilian nuclear power plants.
The~ Commission recently published its finding.on this issue in 4
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the Federal Register (Volume 50, No. 28, Pages 5548 to 5567).
The Commissicn reached a generic finding that maintenance of full core reserve is necessary for continued, orderly operation of a
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nuclear power plant. This finding was based on economics and prudent management. NRC cited estimated costs of $360,000 to
$650,000 per day for replacement power costs.
-D. Outage Schedule for Surry on April 1, 1985, the Comp'any published a new three-year cutage schedule for its nuclear units. This schedule, which is
= Appendix 3 to this testimony, indica.tes that Virginia Power currently plans to refuel Surry Unit 1 on July 5, 1986. I should explain that this July 5, 1986, date assumes that Surry Unit 1 will be operated beyond its normal end of cycle date in a " coast-
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,r~k ldown" mode. This extended operation period has been planned in order to provide a three-week interval between the North. Anna Unit 2 refueling outage - scheduled to end June 12, 1986 - and the beginning of the Surry Unit 1-outage. This interval, in turn, is desirable because certain repairs required during the North. Anna Unit 2 outage could extend that outage, and the Company wants to avoid having North Anna Unit 2 and Surry Unit 1 off line at the same time. It is important to recognize, however, that if Surry Unit I were to operate at a higher than anticipated capacity fLccor prior to the 1986 outage er if an unplanned shutdown occurred during "coastdown," the refueling
. outage now scheduled for July 5, 1986 could start several weeks before that date.
w 5-We plan to discharge 56 fuel. assemblies during the 1986 Surry
- Unit l' outage, which would lea've only 102 spaces (158 minus 56)
() : in the Surry pool.
102); short of full core reserve.
This would be 55 fuel assemblies (157 minus Thus, in order to maintain full
- core reserve,,at least 55 fuel assemblies must be removed-from the;surry spent fuel pool and. stored elsewhere by not later than the end of the 1986 Surry' Unit 1. refueling outage. As I shall
- explain in the following section, these 55 assemblies actually need to'be removed before the Surry Unit 1 1986 outage begins.
s E. Shipping Windows
= Virginia Power prefers to avoid transshipping spent ~ fuel
. between Surry-and North Anna while a-refueling cutage is in pro-gress at either Station. Refueling outages are periods of inten-(); sive activity at a nuclear power. station,-and'any activity that
- may increase the length of the outage is avoided in order--to ,
minimize the outage duration and the replacement power costs. .
Shipment of spent fuel-involves use of facilities in the spent fuel pool that are also needed during outages for. core offloading and onloading. In addition, some of the personnel required for
' spent fuel shipments would have other conflicting responsibilities i-during a refueling outage. As Appendix'3 shows, outages are sched-I- . uled for North Anna Unit 1 for the period November 1 through Decem-ber 19, 1985, and for North Anna Unit 2 for the period April 25 t through June 12, 1986.
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h L in addition, Virginia Power would prefer to avoid planning p
for spent fuel shipments during the period from mid-December
- through February because of tha higher probability that bad
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L weather would result in delays in the shipment of spent fuel.
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ThisLwould' result in increased cask lease charges and personnel Costs.
)
In summary, Virginia Power needs to remove at'least 55 fuel assemblies-from the Surry spent fuel pool before the-1986 Surry
' Unit i refueling. The preferred windows for-transshipment are limited to ' Septe.nber and ' October,1985 and March and April,1986.
III.
Virginia Power's Commitment to Dry Cask Sterage
.A. Background In 1979, when it was apparent that additional space would have to be provided for'the Surry Power Station spent fuel,'Vir -
fginia Power undertook a comprehensive study of its spent fuel g- storage options. Among other things, we assessed the possibility of storing spent fuel in large metal casks (dry casks! that would i- be stored on site at the Surry Power Station. At that time it was'cl'ar e that-Virginia Power could not rely on dry casks as its principal option.- These casks had not been licensed anywhere for the storage of spent fuel and were only in the early stages of development in Germany. It was equally clear, however, that dry
' casks offered promise for the future.
-Thus, while Virginia Power chose as its principal option the
, expansion of fuel pool storage capacity at North Anna Units 1 and ,
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~2 and the transshipment of up to 500 Surry spent fuel assemblies to North Anna, it also continued to pursue dry cask storage. By (f
1982, dry cask storage had become a more realistic alternative.
i considerable development work on this option was being performed L
! in a number of countries, and a basis existed to develop a I'
7-facility design and' license application for dry cask storage at Surry.- In the following two sections of this testimony, I will 6 describe 'the status of our dry cask efforts.
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B. - License application for dry cask storage In October 1982, Virginia Power' submitted to NRC a license
- application'under 10 C.F.R. Part 72 for a' dry cask storage facil :
ity at the Surry Power-Station. A conceptual sketch of this facility is provided in Appendix 4. The' facility consists of
- concrete pads and security facilities, which will be built by Virginia Power, and dry storage casks, which will be-purchased
- from cask vendors.
'The license application describes the facility and incorpo-rates'by reference the topical report for the GNSI CASTOR-V/21 O cask. Virginia. Power has answered all of the questions received
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from NRC on its license application except for a request dated
- March 7,1985, 'to have additional information provided by GNSI
= (the cask vendor) on shielding analyses for the CASTOR-V/21 cask.
The NRC Staff issued its Environmental Assessment of the proposed dry cask storage facility on April 12, 1985. The Envi-ronmental Assessment concluded that the proposed facility will have no significant effect on the environment and that no Environ-mental Impact Statement is required. On April 10, 1985, Virginia Power requested permission from NRC to begin construction of the dry cask ' facility at Surry (the concrete pads and security facili-ties). Virginia Power estimates that approximately 10 months l -will be required to build the dry cask facility.
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-If. Virginia-Power receives an early construction authorization
' from NRC,: and a conditional use permit from Surry County, construc-j [ tion could'begin as.early as June 1985. In that case, the dry
- cask facility-could be ready for operation as soon as April 1986.
'If we must await issuance of the license before beginning construc-
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tion and-issuance occurs in September, work would begin in late September or. October and the facility could'be ready in August 1986.
. Virginia Power has also ordered the first CASTOR-V/21 storage caskLfor use in the dry ' cask facility.
t The cask, which will hold 21.' assemblies, is scheduled for. delivery in November 1985.. We plan!to order additional casks, which are expected to have a lead time of 11 months, during May, 1985. We-will continue to order
' additional casks for-Surry as often as necessary to maintain full LO core reserve in the Serrr fue1 roo1.
Once'the facility is completed, the first cask is delivered, andpersonneltrainingisfinished,the25assembliescouldbe
' loaded into th'e cask in about a week.
. (L The-Cooperative Agreement Program with DOE The Nuclear Waste Policy Act of 1982 authorized the Depart-
' ment of Energy to enter into cooperative agreements with the utilityfindustry to develop alternative technologies for interim
. storage of spent nuclear fuel. Virginia Power proposed to DOE in September 1983.aLprogram to develop dry cask storage. Virginia fm Power and-DOE signed a Cooperative Agreement (DE-FC06-84RL10531)
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on March 29, 1984, to conduct a dry cask storage demenstration
- program.
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The program consists'of (a) a NRC-licensed. demonstration at N the Surry. Power Station, using the facility described in the pre-(}- ceding section of this testimony, and (b) research and develop-Lment activities to be conducted by DOE at a Federal site. DOE has assisted Virginia Power in responding to the questions proposed by NRC with respect to its dry cask facility license
- application'and has selected a facility at the Idaho National
-Engineering Laboratory (INEL) as the Federal site for conduct of its research and development activities under the program.
Pursuant to the Cooperative Agreement, Virginia Power has ordered'two storage casks for delivery to the Federal site, a CASTOR-V/21 cask from GNSI (capacity =- 21 assemblies) , which was delivered in December 1984, and a MC10 cask from Westinghouse
.[f- Electric' Corporation (capacity = 24 assemblies) , which is sched-uled for delivery in February 1986. Virginia' Power is now in the process of ordering another cask, this one from Transnuclear, Inc. -(capacity = 24 assemblies) . This cask is being fabricated I in Japan-and should be available for delivery to INEL in September 1985.
The Cooperative Agreement provides that th'e DOE will test up
( to four casks at the Federal site using spent fuel provided by l-Virginia Power from Surry. Two casks will be tested using
! " intact" fuel and two using " consolidated" spent fuel. A fuel
-assembly is " intact" if it is stored in the form in which it is
( removed from the reactor. Fuel assemblies are " consolidated" by removing th,e individual fuel pins from the grid structures used to make up assemblies and storing the pins side by side in cans.
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With consolidation, the fuel pins frcm two assemblies can be stored in the storage space that would be occupied by one intact fuel assembly. The second and third casks delivered to the Federal facility will probably be loaded with intact assemblies M initially and with consolidated fuel at a later date. (
DOE will accept title to this fuel at Earry, transport it to _
INEL and thereafter be . responsible for it'.s storage and disposal. [
The testing of consolidated spent fuel e.t the Federal site will require DOE to consolidate fuel at INEL.
Virgihia Power is, of course, responsible under the Coopera-
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tive Agreement for the licensed facility at Surry. We will use five storage casks at Surry in performing our obl.igations under 5
the Cooperative Agreement Program.
O oos t caea= tea to best= receivt=s surrv ve== zue1 cor the i CASTOR-V/21 cask in July 1985. Shipment of this spent fuel will _
require approximately two months. Shipment of spent fuel for the n
second cask at INEL could begin in October 1985 and is also esti- _1 mated to require about two months. If this program is completed ;
on schedule, the number of assemblies that must be removed from f
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the Surry spent fuel pool will be reduced by 45 fuel assemblies (21 assemblies in the CASTOR-V/21 cask and 24 in the Transnuclear 2 cask). These steps alone would leave us 10 spaces (55 minus 45) }'
short of full core reserve after the 1986 refueling at Surry Unit .
o 1
The shipment of spent fuel for the Westinghouse cask will be z
scheduled for 1986. These shipments could begin in March or 7i April of 1986. If these shipments can be carried out before the '.
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3.,
Surry Unit 1 refueling outage in 1986, full core reserve would be assured, without.any shipments to North Anna, for the period immediately following the Surry Unit 1 outage and until the Octo-
' V)je' -
ber 17, 1986 outage at-Surry-Unit 2.
D. : Virginia Power's commitment to use dry cask ~ storage Virginia Power has agreed with Louisa County to pursue the
' licensing and use of dry cask storage as vigorously and swiftly as it reasonably can. We are committed to use dry cask storage when it becomes available and to forego transshipping to the extent
.possible. The agreement provides, however, that if shipment of Surry fuel to North Anna is the only way to avoid the loss of full core reserve a : Surry at any given outage, then we may ship up to'130 assemblies. And if, contrary to our expectations, dry
' cask storage remains unavailable to us after we have shipped 130
.(} assemblies, the County and Virginia Power are to negotiate in an -
effort to agree on an. additional number of assemblies that may be shipped if necessary to avoid loss of full core reserve.
IV.
Comparative Costs A. Estimated costs of~ transshipment CostsLincurred to date for transshipment amount to S886,000.
This includes the cost of the lawsuit challenging a Louisa County ordinance that prohibited storage of Surry spent fuel at North i
y Anna, public .nformation presentations on transshipment,
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including a seminar prepared by Virginia Power in cooperation with the State of Virginia for emergency response personnel, i
n 4
preparation for this proceeding and equipment and training required t'o handle the TN-8L. shipping cask at North Anna.
3 Virginia-Power anticipates additional costs for transshipment
'in 1985 of_approximately.$235,000 in connection with this proceed-
'ing,:a study by the Virginia Department of Emergency Services on Troute alternatives, and security equipment required for spent Ifuel shipments.
Costs for the actual transshipment of spent fuel from Surry to North Anna,are estimated at-approximately $15/kgU. (Unit-costs are frequently expressed in -terms .of S/kgU or dollars per kilogram of uranium in the fuel. There are 460 kilograms.of uranium in each fuel assembly.) This cost will be in addition to-
'the " start up" costs discussed above. Thus, if'500 spent fuel assemblies were tra.nsshipped to North Anna, the estimated costs
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p for the_ shipments, including start up, would be $4.57 million.
As I have said,.the amount-of transshipment required, if any, t
l will depend on the progress we make on the dry cask storage program.
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.B.- -Estimated costs of dry cask storage 4
Virginia Power's estimated costs for participation in-the I dry cask storage Cooperative Agreement Program discussed above is
- S20.6_million. Virginia Power will pay all costs for the
~ facility-at the Surry Power Station, for the casks that will be tested at the Federal site, and for shipping Surry spent fuel to L the Federal site. DOE and EPRI are expected to pay for all l-
- testing activities at the Federal site, including consolidating f
5
the_ spent. fuel and storing it'after conclusion of the Program and
~until a repository is available.
Beyond the DOE Cooperative Agreement Program, which will
(} T involve five casks at Surry, Virginia Power will continue to use dry cask storage at Surry to provide for storage of Surry spent fuel until.a repository is available.
The costs of providing dry cask storage at Surry, once the facility is licensed and built, consists primarily of the price of the casks. We have received bids from several cask vendors; the prices quoted range from about $70 to $90 per kgU of fuel stored intact. If storage had to be provided for the remaining operating life of the Surry Power Station, which is 23 years, we estimate that the cost of storage would be approximately $41.9
() 'million in addition to the costs of the DOE Program. If the Fed-eral repository should begin accepting spent fuel in 1998 at the rate at which it is generated at Surry, the estimated additional cost of storage would be about $22.1 million. The cost of storage casks for the 500 spent-fuel assemblies that are the subject of this proceeding would be about $18.4 million.
There may be a basis for decreasing these sums. As I testi-fied earlier, one purpose of the DOE Program will be to test the storage of consolidated fuel in dry casks. If consolidated stor-age proves to be feasible and the cost of consolidating fuel from two casks proves to be less than the cost of a second cask, Virginia Power will store consolidated spent fuel at its surry dry cask facility. For example, some estimates of the cost of consolidation are in the range of S25 per kgU. If this estimate
.. .. _-_-_____-_-___________________-____J
-proved to be correct, the cost of consolidated storage would be S 60 .1a) S70.per kgU ((h x S70) + S25 to ( x $90) + S25)).
] l To summarize my testimony to this point, the near-term cost N_/ .
of-shipping 500 assemblies from Surry to North Anna would be about $4.57 million. The costs of dry casks to store the same assembl'ies in dry casks would-be about $18.4 million for intact fuel, a sum that could be decreased to some extent if consolidation proves economic.
Of course, if we ship Surry fuel to the North Anna pool, we will decrease on a one-for-one basis the number of spaces available for North Anna fuel. Since North Anna's spent fuel pool, once reracked with neutron-absorbing-racks, will have only enough space to last until approximately 1998 if no Surry fuel is O(_/ transshipped, additional storage capacity would likely be required at North Anna in the future if a significant number of Surry assemblies were transshipped there. We might provide this additional storage, necessitated by the presence of the Surry fuel at North Anna, in one of two ways. First, the' North Anna pool has been designed to accommodate consolidated fuel in the fuel racks. If consolidation were indeed to cost $25 per kgU, the total cost of storing consolidated fuel, and thus replacing the space occupied by Surry fuel, would be $50 per kgU (since two assemblies are consolidated to make one additional space avail-able). We add to this the $15 per kgU for transshipping the Surry fuel to North Anna in the first place for a total cost of approximately $65 per kgU. This is similar to the cost of dry his brauni n r ii
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cask ' storage '(S70-S90 per kgU intact and .S60-S70 per kgU consolidated).
.Second, if consolidation -proved to be uneconomic, we could
- (~%[' c place dryJcasks at North Anna,.in which event the ultimate cost for shipping the Surry. fuel to North Anna would be the $70-$90
-per kgU for the~ casks plus the $15 per kgU for shipping. This, of course, is higher than the cost of retaining.the Surry fuel.at Surry in' dry casks. But it is important to emphasize that if Surry fuel is shipped to North Anna, thus displacing North Anna spent fuel, the preempted space in the North' Anna pool will not
.have to be replaced - and the expenditures will-not have to be made - for perhaps 10 years. Storing the fuel in dry casks at Surry, however, requires substantial outlays now. In addition,
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some observers have estimated the cost of consolidation at $10 per kgU. At that level, transshipment of Surry fuel to North Anna and consolidation in the spent fuel pool there would be sig-
-nificantly less costly than dry cask storage at Surry.
The foregoing cost analysis'does not consider the costs al-ready expended to provide the spent fuel pool and fuel racks at
' North' Anna. These costs represent investments already made by Virginia Power to provide facilities required for its operations.
In determining the best alternative for insuring the continued
-operation of Surry and North Anna in the future, sunk costs for construction of facilities should not be considered.
.O O
. i V.
Comparative Environmental Effects The radiological and non-radiological environmental effects of transportation of spent fuel are examined in WASH-1238, "Envi-ronmental Survey of Transportation of Radioactive Materials To and From Nuclear Power Plants," December 1982, and in Supplement 1, NUREG-75/038, April 1975. For use in licensing proceedings, these effects are summarized in Summary Table S-4, " Environmental Impact of Transportation of Fuel and Waste To and From One Light-Water-Cooled Nuclear Power Reactor."
The following is a comparison of (a) - the key parameters used in WASH-1238 for calculation of environmental effects through the
. use . of. Table S-4 with (b) the parameters for the proposed shipments from Surry to North Anna.
Factor of Reduction in Radiological-Parameter WASH-1238 Transshipment Impact Shipments / 120 40 3 Year for Two Reactors cooling Time 150 days 730-3,650 days 2.5-10 From Discharge to Shipment Shipment 1,000 miles 160 miles 6 Distance and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 4h hours Duration A comparison of the parameters for the proposed shipments from Surry to North Anna with the assumptions used in WASH-1238 reveals that the effects of the proposed shipmants from Surry to
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North Anna would be well.below the postulated _ effects set out in Table S-4. .NRC has concluded that these effects are insignificant.
The effects of' sabotage, of course, are not reflected in Table
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S-4, but, - as the testimony of Mr. Jefferson in this proceeding
-indicates, those' effects are insignificant. 'In short, the overall
. environmental effects of the proposed shipments from Surry to
-North Anna will be negligible.
Insofar as the use of dry cask storage is concerned,'NRC has completed.its environmental review of the proposed Surry-Indepen-
' dent Spent Fuel Storage Installation described earlier in this testimony. -The results are set out in " Environmental Assessment
'(EA) Related to the Construction and-Operation of the Surry Dry Cask Independent Spent Fuel Storage Installation," published
'() April 12, 1985. The NRC's Environmental' Assessment concludes that (a) ~ no significant construction impacts are anticipated, (b) the radiological effects from the operation of the proposed facil-ity would fall within the scope of the. effects associated with the existing' reactor operations,.and (c) no significant non-radio-logical impacts are expected during operation of the facility.
Thus, the environmental effects of both shipping and. dry cask storage are negligible. .
VI.
Authorization to Store Surry Fuel at North Anna is Essential As this testimony shows, the combination of (a) shipments to
.() a Federal facility for dry cask storage research and (b) operation of our own licensed dry cask storage facility at Surry may reduce
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or eliminate for'now the need.to transship Surry fuel ~to North Anna. Virginia Power hopes it does. Dry cask storage is our i
/~% preferred alternative; if both transshipment and dry cask-storage
- L) were'available,^ Virginia Power would use dry casks for interim storage of Surry spent fuel.-
Nevertheless,-Virginia Power still needs the authorization-
_ required for transshipment. First, of, course, is-the fact that-Virginia Power does not yet have a license for dry cask storage.
'Although it is possible that a license'may be granted in time to allow completion of a dry cask facility at Surry before full core reserve'is lost, this is not assured.
In addition, if for any reason dry casks, once authorized, 7
.could not be acquired on a timely basis, or-if NRC should withdraw 1
( ): the authorization to use dry casks for reasons that we do not now -
anticipate, we might be faced with a loss of full core reserve shortly thereafter. _It would be too late at that point to go back and start over on a proceeding, such as this one, seeking authorization to store 'Surry fuel at North Anna. Thus, prudence requires that we have more than one interim spent fuel storage option available.
E Finally, the Nuclear -Waste Policy Act of 1982, in S 111(a) (5) ,
explicitly makes utilities primarily responsible for interim stor-age of spent nuclear fuel until a Federal repository is available.
The Act provides for limited Federal interim storage for utilities, but only if they are unable to provide their own storage through the use of transshipment, dry casks and new fuel pools. Indeed, utilities are required by 10 C.F.R. Part 53 to demonstrate to NRC t
- that they have," diligently" pursued these options _before they can qualify to use Federal interim storage. In the unlikely event-that both dry cask storage'and transshipment were unavailable to
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us, we would have to use : Federal interim storage. We could only-qualify if we could-show that we had pursued diligentlyfthe autho-rization we seek in this proceeding. While Federal interim storage might be very expensive '(estimates have placed the cost as high as $600_per kgU), it would still be preferable to shutdown of the Surry Power Station at a cost of up to $300 million per year in replacement power costs.
VII.
Summary .
7 In short, Virginia Power is using its best efforts to license-and_use' dry casks for additional spent fuel storage space as quick-ly as possible. We are committed to doing so. To the extent we.
can do so and still maintain full core reserve at Surry, we.will
- avoid shipping any Surry fuel to North Anna. Still, we believe
~it :is incumbent upon us, in terms of both prudent operating prac-tice and the requirements of 10 C.F.R. Part 53, to secure approval
' to store 500 spent fuel assemblies from Surry at North Anna.
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I,"'+'T, Appendix 1 Marvin L.lSmith:
Supervisor,5 Nuclear Engineering
' Power-Station Engineering.
JEducation-1972 B.S. Physics, Virginia Polytechnic Institute and_ State University.
1973 M.S. Nuclear Engineering, Virginia Polytechnic and State University Experience
.1973'-'Present Virginia Electric and Power Company Richmond, Virginia 1983 - Present Engineering'and Construction Program Manager for Vepco/ DOE /EPRI Cooperative ~ Agreement Program.
on' dry cask spent fuel storage.
1982 - 1983- Nuclear Engineering Group, Power Station Engineering, Supervisor of the grou responsible for.
engineering on spent f al projects ,. low level radwaste processing systems, ALARA and radiation protection analysis. Proj ects -
have included design of both dry . cask and pool Independent Spent Fuei Storage Installations, raracking the North Anna.
Units 1 and 2 Spent ' Fuel Pool, Licensing Storage of'Surry Spent Fuel at North Anna, design of low level radwaste processing systems, mad shielding design for the Post Accident Sampling System. Developed Vepco plan for internal spent' fuel storage.
1981 1982 Nuclear Operations Department Supervisor of group responsible 'for coordina-tion of all capital improvement proj ects for the North Anna Power Station. In addition, provided coordination for all spent fuel related projects for Vepco.
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1978 - 1981- Fuel Resources Department Supervisor of group responsible for development and implementation of analytical engineering a(d'V models for reload. nuclear core design and safety analysis. In' addition, served as Technical Manager for the Vepco/ DOE Program for demonstra-tion of extended fuel burnup. Developed, improved reload core ' designs utilizing both 18 month reload cycles and low neutron leakage core designs, and worked on-EPRI task force involved with development of the .RETRAN system safety analysis computer code'.
1973 - 1981- Fuel Resources Department Engineer responsible for development of Vepco
. reload core analysis models. Developed a version-of the PDQ07 computer code which provided Thermal / -
Hydraulic feedback, improved computer and user efficiency. Wrote topical report used to obtain NRC approval for this computer code. Designed first 18 month reload core used by a commercial-United States PWR..
O >=811c cio -
M. L. Smith and M. L. Bowling, "Vepco Interim Spent Fuel Storage Program", presented at ANS topical meeting in'Savanah, Georgia in October, .1982 and at the Atomic Industrial- Annual Fuel Cycle Conference in March, 1983'in Kansas City, Missouri M. L. Smith, C. B. Franklin. T. W. Schleicher, " Extended Burnup and Extended Cycle Design," TANSAO 34 1-899 (1980), page 389.
M. L. Smith, "The PDQ07 Discrete Model," VEP-FRD-19, (Vepco topical.
report submitted to the NRC), July,1976.
M. L. Smith and H. S. McKay, "Onsite Storage of Spent Nuclear Fuel in Metalic Spent Fuel Storage Casks," presented at international Meeting on Spent Fuel Storage in Toronto, Ontario in October, 1984.
o t .
I l
. , _ , , , . . _ . . . . - . . _ - , _ , _ . _ _ _ . - . , . . _ _ , . . _ _ _ . . . . _ _ . . _ . _ _ _ . . . _ _ _ . , _ . ~ . , . _ . _ . . , - , . . _ . _ _ _
Appendix 2 SPENT FUEL POOL INVENTORY UPDATE AND FUTURE ESTIMATES BASED ON FUEL MANAGEMENT SCHEME 253
( Yearly Surry Assy 1 Yearly M Anna Assy l Combined
-Yoar 51 52 Total Dis. I M1 M2 Total Dis. 1 Inventory i I I I 1974 84 84 84 l l 84 t1975 16 84 100 184 I i 184 1976 84 '24 108 292 l l 292 1977 -
80 80 -372 l l 372 1978 64 -
64 436 I i 436 1979 -
64 64 500 1 52 52 52 1 532 1980' 76 -
76 576 I 64 64 116 1 692 1981 -
68 68 644 l - -
116 1 760 1982 - - -
644 1 69 52 121 237 l 881 1983 64 61 125 769 l -
56 56 293 l 1062 1984 56 -
56 825 1 68 64 132 425 1 1250 1985 1* 60 61 886 1 56 -
56 481 1 1367 1986 56 '
60 116 1002 (1) 1 -
64 64 545 l 1547
. 1987 - -
0 1002 1 68 68 136 681 l 1683
'1988 60 60 120 1122 (2) 1 68 -
68 749 l 1871
~1989 60 60 120 1242 l -
68- 68 817 l 2059 0 1242 1 68 68 136 953 1 2195
{~1990 1991 60 60 120 1362 1 68 -
68 1021 1 2383 1992 60 60 120 1482 l -
68 68 1089 l 2571
'1993 - -
0 1482 1 68 68 136 1225 1 2707 1994 60 60 120 1602 1 68 -
68 1293 l 2895 1995- 60 60 120 1722 1 -
68 68 1361 1 3083 1996 ' - -
0 1722 1 68 68 136- 1497 (2) 1 3219
'1997 60 60 120 1842 1 68 -
68 1565 1 3407 1998 60 60 120 1962 1 -
68 68 1633 (1) l 3595 1999 - -
0 1962 1 68 68 136 1769 1 3731 2000 60 60 120 2082 1 68 -
68 1837 1 3919
'2001 60 60 120 2202 1 68- 68 1905 1 4107 2002 - -
0 2202 1 68 68 136 2041 1 4243 2003 60 60 120 2322 1 68 -
68 2109 I 4431 2004 60- 60 120 2442 l -
68 68 2177 1 4619 2005 - -
0 2442 1 68 68 136 2313 1 4755 (8) This is not a fuel assembly but rather the can to hold fuel rods l removed from assemblies during the reconstitution program for 1985.
c,(1) Loss of full core discharge capability, no transshipment, no dry cask-storage, raracking at North Anna p
() (2) Loss of full core discharge capability, 130 transshipped to North Anna, no dry cask storage, raracking at North Anna.
I .Aosumptions: 1. The raracking to be completed at North Anna.
- 2. Pool capacities surry -
1044 assemblies North Anna - 1737 assemblies (zeracked)
Revision 85-2 Mcrch 25. 1985 Appendix 3 THREE YEAR FORECAST !
1985-1987 OUTAGE SCHEDULE 'l UNIT REASON OFF LINE ON LINE OUTAGE DAYS YEAR 11-01-85 12-19-85 48 1985 (1) N. Anna 1 Refueling N. Anna 2 No Scheduled Outages O (2) Surry 1 Snubber / Maintenance 6-28-85 7-08-85 10 3-20-85 6-15-85 87 .
Surry 2 Refueling 10-14-85 10 (3) Surry 2- Snubber / Maintenance 10-04-85 1986 N. Anna 1 No Scheduled Outages ,
4-25-86 6-12-86 48 Refueling-(4) N. Anna 2 4 7-05-86 8-22-86 48 Surry ,1 Refueling 3-28-86 4-07-86 10 (5) Surry 2 Snubber / Maintenance 12-14-86 58 (6) Surry 2 Refueling 10-17-86 5-01-87 7-15-87 75 1987-(7) N. Anna 1 Refueling 9-18-87 11-05-87 48 N. Anna 2 Refueling Surry 1 No Scheduled Outages Surry 2 No Scheduled Outages .
~
g NOTES:
(1) - Snubber testing must be performed between 6-19-85 and 12-19-85.
(2) - Snubber testing must be performed between 4-30-85 and 7-31-85.
(3) - Snubber testing must be performed between approximately 9-18-85 and 11-19-85. .
(4) - Snubber testing must be performed between 12-17-85 and 9-17-86.
(5) - Snubber testing must be performed between approximately 3-01-86 and 6-01-86.
(6) - Snubber testing must be performed between approximately 12-12-86 and 6-13-87. Outage length extended to 58 days due to reactor guide tube split-pin replacement.
(7) - Snubber testing must be performed between approximately 2-2-87
,. and 11-3-87. Outage length extended to 75 days due to 10-year inservice inspection.
I
. e
_ . . _ . . . _ _ _ . . . . _ _ _ - - .. _ . _ _ _ . . _ . _ _ _ . . . . ~ _ . . _ . _ _ . - - _ - - _ _ _ _ -
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SURRY POWER STATION .
DRY CASK INDEPENDENT SPENT FUEL STORAGE INSTALLATION i
4 c
248
~
2 7 Wal k
< 1 JUDGE WOLFE: And for those who do not understand 2 it, when;I say that the written testimony is incorporated i 3 into.the record as if read, that means that the witness is 4 ;saving everyone time by having prepared what otherwise would l
-5 ha've:been his oral testimony, and that is incorporated into l-6 Jthe ' record 'as if! read and it is oral evidence in the case.
7 -All right. i-DIRECT EXAMINATION XXX INDEX- 8
.9 BY MR. MAUPIN: ,
10 Q .Mr. Smith, will you.please summarize for the
- ~l 11 ! Board the testimony.that has just been put into evidence?
c.
12j A Yes. In that testimony, I discuss first the 13 l subject of the loss of full core reserve at the Surry Power 4
11 station. .
1 2
15 ' The Surry Power Station is currently in a fueling-16' .
outage. At the conclusion-of this refueling outage, we will 17 ' have 159 spaces available in the Surry Units-1 and 2 spent fuel 18 ;I pool for storage- of spent fuel for the Surry Power Station.
d 19 L The two Surry units share a common spent fuel t'
20
- pool, each Surry Unit full core consists of 157 fuel assemblies.
21 j Therefore, at the conclusion of this outage there 22 will be two assemblies in excess of what is required for a full
,. 1
! 23 ]. core ~ discharge.
- 24 The outage schedule for the Surry Units-1 and 2 is Ase Federd Reporters, Inc.
25 attached to my testimony, and is shown in that outage schedule,
! -. t
.._ - - - . . . _ . . . - . . . _ , _ . _ . . _ . . , _ _ , . . _ . . _ _ . _ _ _ ..._.m.-.__,.._,_...... . --- ,. _ - _ .~,
7-ll-W:21 249 !
I and the next refueling plan in Surry is July 1986.
t 2 At that refueling, the current plans are that
,s- 3 56 field assemblies would be replaced in the reactor core. ,
! l
\_/
4 Prior to that refueling, there is a program to do what is 5 called fuel reconstitution at Surry, where some fuel assembliesi 6 are repaired by removing damaged fuel rods. !
7 That process will take up one additional space 8 in the spent , fuel pool, so with a discharge of 56 assemblies 9 it leaves us with the necessity of removing 55 assemblies 10 from the spent fuel pool prior to that outage in order to i
11 l maintain the fuel core reserve. .
12 i VEPCO has been pursuing several options over ey .
kJ 13 a period of years to provide increased capacity for spent 14 fuel storage at the Surry Power Station.
15 I would like to discuss now the dry cask storage 16 program that we have at the Surry Power Station. The dry
- 7 cask storage, just briefly summarized, the licensing status 18 of this, applied for dry cask for a license under 10 CFR Part i
19 72, for dry cask facility, in October 1982.
20 Since that time, we have been responding to NRC l
21 questions on the license application. We have also been T^3' 1
/ 22 working with Vendors who would provide the dry cask to obtain
- i 23 j approval from the NRC for the cask to be used at the facility.
I 24 In April of this year, the NRC issued its primeval assessment Acs Feierd Reporters, Inc.
25 for our proposed facility, along with a proposed finding of
P-12-W:::1 250 1 most significant impact.
i 2 We have subsequently requested permission to begin c s, 3 construction of this facility, and are awaiting a response from; 4 the NRC on that request.
5 In addition to the licensed facility at Surry, we i 6 have also entered into an agreement with the U. S. Department 7 of Energy for what is referred to as a corporative agreement 8 program for the demonstation of the dry cask storage.
9 As part of this agreement program, we will be 10 testing these casks at a fede::al facility in Idaho. The 1,1 first cask that we propose to test there has been delivered, 12 ' and is presently in the process of being prepared for a dry
-J 13 run, and fuel would subsequently b'e shipped from Surry to 14 Idaho for testing in this cask.
15 In addition, we have ordered another cask for 16 delivery early next year and are in the process of negotiating il for a third cask that will be delivered in September.
18 In terms of the comparative cost of the options 10 that we have evaluated, we have looked at the cost of trans-20 ] shipment, the expressed cost in terms of dollars per kilogram 21 of uranium contained in the fuel. It is, again, a pricing zm a
'uJ 22 9 that is quite often used for comparative cost purposes.
It 23 [ , The trans-shipment we estimate would cost 24 approximately fifteen dollars per kilogram, in addition to AmfeJerd i'eporters, Inc.
25 certain costs associated with establishing the program to
7-13-Walf 251 1 ' allow us - to trans-ship. fuel.
i 2 The dry cask, we have received tests for casks for ;
I p 3 - .from a number of vendors, and we estimate a cost per G
~
4 kilogram per dry cask storage of approximately 70 to 90 dollars 5 Per kilogram.
6 The trans-shipment of fuel from Surry to North l
7 Anna would use up the space that is presently available, or i
8 will become available at North Anna. With the re-racking scheduled 9 - at - North Anna Power Station this summer -- with that re-racking i
10' -- we will have sufficient storage capacity at North Anna 11 ! to store North Anna fuel through about the year 1998.
12 ; With the Federal depository not projected to' be
[^
' V) '
13 available until 1988, any trans-shipment to North Anna would ta be using space that we would at some future date have to provide 15 additional capacity for.
.lo In the case of North Anna, the studies that we have
- 7 done to date to show shipping is possible of that unit, to use is ; what .is called fuel consolidation, where the fuel rods are to removed from the fuel assembly and placed in a canister, two 20 [ fuel assemblies occupying the single storage location.
11 21 j We estimate a cost of this option of around 25 l
k'Tl 22 dollars per kilogram. There have been studies that predict li 23 h a cost as low as 10 dollars a kilogram for the storage, but it 4
24 has not been done on a scale yet that would demonstrate Ass-Faford Reporters, Inc. '
25 . conclusively where the cost is in that range.
7-14-Wdl 252
--) Therefore, the cos't of trans-shipment and dry cask ;
-2 ' storage, even if -you. include : the additional cost of. consoli-r 3 dation with the trans-shipment cost, you will find that the ,
4 ~ cost:of trans-shipment is about the same, or slightly less 5 than the cost of dry cask ' storage.
6 It should also be noted h at-in the case of trans !
-7 shipmen't , the' cost for the consolidation component, that would- .
t 8 not. be incurred for a number of years, ' depending upon how l 9 much fuel was trans-shipped, as to when it would need to be 10 consolidated.
11 I also looked at the comparative environmental
~ :
12 i effects that were found by 'the NRC
- studies of the two different 3
13 Y proposed options, both trans-shipment and the dry cask storageo.
b 14 Both cases, a finding of no significant impact 15 was-reached and both options we think are acceptable from
' 16 " an environmental perspective.
U' We feel we must pursue the authorization to store 18 L the Surry fuel at North Anna, even though we do'now believe n
d 10 that dry cask storage is our preferred alternative. We have E
20 ' stated that it is our preferred alternative in the licensing i
21j application for the dry cask facility at Surry,.but that option i
22j is not yet licensed.
23 i We cannot, at this point in time, be guaranteed 24 that it would be. We certainly hope that it will be, but we ham Federd Reporters, Inc.
25 certainly have no guarantees that that vould be the case.
1 i
.m . _ - . _ . . . _ , _ - . - , _ - . - . _ _ . . . . . , _ _ . _ . _ _ _ _ . _ , . _ . _ , _ _ _ . - . _ , . _ , , . . . _ , - . _ . . . _ . . _
c-7-15-W51 -
253- .I 1 ,
In. addition,-we have' looked at the. requirements p 2 under-10:CFR Part 73 -- excuse me,-Part 53, for Federal interim 3 source -- Federal interim storage is an; option.under the 4 Nuclear Base Policy Act that will be-available to you until 5 -- if'they.are unable to provide for their own storage of' spent 6 fuel. !
7 Certainly, Federal storage is the'last option we y-
'8 _ would want for the Surry Power Station. However, with the
~
'9 predicted cost in terms of replacement power cost at one of
'10 the Surry Units, that it could not be able to be operated,
, 11 we' estimate it is 300,000 dollars per day or more per unit.
.. 12 l :We feel that we must have $ptions ~available. Part
- h li 13 " 53 would require us to be diligently, pursu,in,g several options g
14 I including both trans-shipment and dry storage, and we feel
-> 15 U that we thust be able to ass ime both of those options at 3 ' '
16 this time.
, 1 17 ' MR. MAUPIN: Judge Wolfe, that completes our 18 L direct presentation.
1 h
19 i. JUDGE WOLFE: Mr. Dougherty?
7' ti l 20 f MR. DOUGHERTY: Yes, Judge.
XXX INDEX 2I h CROSS EXAMINATION EO --
22 BY MR. DOUGHERTY:
l 23 Q Mr. Smith, I am in sort of a tough spot here, i'
24 and the reason is that all the other parties have all the l
yr.nor:s e swrwes.
Inc.
25 What the text book says in experts'and we don't have any.
t
.s - !
4 7-16-Wni <
254
.1 ' this . kind of circumstance is for me : to make you my witness, 2 and to get from you your authoratative view, so that'is what (q 3 I .am going to do is, ask you -a number of questions.
LJ - t . .
4 You statee---
5 JUDGE WOLFE: May I inject something here, Mr.
6 Dougherty? The audience or spectators may -not know, but I i
7 would have the audience'know that all parties certainly may i 8 ' cal'1 expert witnesses.
,. r !
9 LIn this case, we were advised that Concerned 10 Citizens would be calling an expert witness. This was more
~11 than agreeable with the Court, because we want a full and l
i l 12 ! complete record. l k -
-l 13 h . Howsoever, a few days beforE the hearing began I
14 ! we were advised that concerned Citizens, for whatever reason, -
15 +' and I am not interested in the reason, had decided that they i6 0 would not call their own witness. That is the reason why 17 .a witness representing Concerned Citizens is not in the i
18 l' courtroom today.
1 i
19 l All-right, Mr. Dougherty.
.I 20 l MR. DO IGHERTY : - Thank you, Judge.
i 21 y BY MR. DOUGHERTY: (Continuing) 22 Q At .page 8 of your testimony, you state that 23 -CASTOR -- N-21 CASTOR is now scheduled for delivery to Surry 24 in November of this year, is that right?
A .rmns noww.. ix.
j 25 A~ Yes, that is correct.
i
7-17-W21 j 255 1 l 1 Q You also state on Page 8 -- why don't I read the i'
2 sentence. It is the last sentence in the first paragraph.
, 3 3 Strike that. The second paragraph sentence: We plan to order i
( ! ,
4 additional casks, which are expected to have a lead time of !
5 11 months, during May 1985, i 6 It is now May of 1985. Have you ordered those 7 casks?
8 A When I left the office, the letter was expected ,
9 to go out either late yesterday or today.
10 Q I see. How many cashs do you expect to order?
11 A Four.
12 Q And these are the same casks -- the V-21, with
(' ') a V 13 i! a capacity of 21 fuel assemblies?
14 " A Yes, that is correct.
15 Q And you still expect the lead time to be 11 months?
16 A The lead time for the first cask would be around J' 10 to 11 months from the date of the order.
18 Q The first of these four?
.!i 10 A The first of these four.
n 20 Q The first of the four.
I 21 ] A The other casks would follow at intervals of about x
-' 22 one month apart from the first cask.
23 They could not all be - manufactured in a 11 month 24 period.
' Ace Fejerd Reporters, tric.
25 g I understand. So -- well, let me ask you another t
. ..- . . - . . _ . - .-_ - . - . . . .-- ~ . - . _ - . - .
7-18-W31 256 <
1 .
],
I~
~1 . question. j 2 On page 8, you state that if Virginia Power !.
t .
i- i
%- 3 receives an early construction authorization from the NRC
- 4 -for the dry cask storage facility, you might have that 5 ' facility. ready for operation by perhaps as early as April l 6 .of next year, 1986. Is that right? !
. [
7 A That is correct.
i 8 Q And if that were to happen, then you would then 9 . be; able to prevent the loss of full, core reserve at Surry ,
l-
-10 'with a July86 refueling, is that correct? l 11 A That is correct.
l . i
'- 'I would.like to talk next about the Cooperative
~ 12 i Q !
'O 13 , Agreement between Department of Energy..and Virginia Power.
~
b '14 On page~9 of your testimony, you state that f i' 15 p CASTOR-V-21 casks arrived at the Idaho National Engineering d
16 Lab in December of last year, is that correct?
^
- 7 '
'A. -Yes'. . ,
i i
18 ', Q And you state that you expect Trans-Nuclear cask, l'
19 ' with a capacity of 24 ass,emblies, to arrive in-September of :
l .
20 { this year, Westinghouse cask with the same capacity to arrive l
' 21 ' in February 19867 t
C.' 22 A That 'is the current schedule for those, yes.
, 23 Q .Now, if the current plan holds, do you expect to 4
24 beishipping assemblies to be used to fill the cask in July pe-Fwwo nowwei.:=.
25 of-this' year? !
i
+. ,
- 7-19-W21 - 257 1 ~A Some time this summer, yes. '
2 Q And you expect that process to take how long?
~
3 A Approximately tw'o months.
End 7. 4
!SusT fois.
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7 4
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A 25 t
. - - - - , . , . , - . ,.--,.-n--, , . . - , , - - - , -,.---n ,- --. nn - . . - , -
258
- 8-1-Suet j Q Now, if the Transnuclear cask is received out there 2
on schedule, do you expect to be shipping spent fuel for that 3 cask this Fall?
/ )
A
~
4 Yes.
5 0 And if the Westinghouse cask is received on 6 schedule, you will be expecting to ship spent fuel for that 7
cask next Spring?
8 A Yes. According to the existing schedule, yes.
9 Q So, it's also possible if the scenario holds that 10 Virginia Power will have another way of preventing the loss 11 of fullcore reserve at the July 1986 refueling at Surry? .
12 A That's true. It should also be noted, however,
'i
- 13 that the other Surry unit is scheduled for refueling in 14 October of next year shortly after the completion of the 15 refueling of the first Surry, which would require further -- l 16 56 to 60 fuel assemblies that would need to be removed from j l
17 the spent fuel. l 18 Q Thank you very much. That will be fine, Mr. f I
19 Smith.
20 I would like to talk now about full core reserve.
1 21 A section of your testimony is devoted to it. Is it true
()_
22 that the maintenance of full core reserve is not essential 23 for the protection of the public health and safety or the 24 environmental quality?
Ace-Federal Reporters, Inc.
25 A That's correct.
259
- 8-2-Suet i 0 So, would you say that the protection of full core 2 reserve is more important from the operations and management 3 standpoint? It' protects the Company's financial interests
( )
' and those of the ratepayer; is that right?
4 5 A The interest of the Company and the ratepayer; 6 that's correct.
7 Q Would you say that it's fair to characterize the !
I 8 availability of spent fuel, storage -- spent fuel storage space l
}
9 at either North Anna or Surry as a resource that the Company l 10 must manage to promote the economic interest of the stock-11 holders and ratepayers?
12 l A- (The witness did not answer.)
~'
13 Q Perhaps I should rephrase it.
14 Would you characterize everything we've talked )i 15 about here,'the proposed transshipments, the proposed con-16 struction of a dry cask storage' facility, as well as the 17 maintenance of full core reserve as an attempt to manage 18 this storage resource that the Company has?
19 A Yes.
20 Q Now, you are a ranking employee of Virginia Power.
21 Is it true generally that you are involved in the planning i i
() 22 stages of activities and its reactors that might impinge
.23 on the storage of nuclear fuel?
24 A Generally, yes. -
A=-F e ra n eo m n.ix. f 25 fQ So, for example, when the steam generators were ;
E 260 i
- 8-3-Suet replaced at Surry in '79 and '80, you had pretty much been ,
1 2 involved in the planning stages of that and knew for some 3 period of time in advance that that was going to happen?
( )
4 A I was not involved in that activity at that time, 5 no.
6 0 Well, if say the Company were to consider replacing l
7 the steam generators at North Anna, you would now be involved i i
8 in your current capacity in the planning of that, I take it? !
l 9 A In as far as it might impact spent fuel storage, ;
10 yes. I 11 Q Can you estimate for the Board how much notice you, f I
12 as an insider, would have of that kind of activity? Nould !
(,) 13 you expect to be able to plan that kind of activity two years 14 in advance? !
15 A In the case of a steam generator replacement, in 16 all likelihood if you were developing problems of steam 17 generators those would be apparent in advance. Yes.
18 Q By a matter of years? {
19 A That's difficult to say. It depends upon what 20 particular mechanism was causing the problem in the steam 21 generator. But typicall with the steam generator you would
) 22 expect it to be a period of years but there is no guarantee.--
23 0 I understand. 1 24 A -- that the problem would not occur more suddenly ;
Am-Federd Reporters, Inc.
25 than that, j ;
' j l
i
261 !
l#8-4-Suet 'l Q The other kind of activity that you identify in 2 -your testimony is one requiring a full core discharge, '
3 conducting an in-service inspections.
(~).
4 Isn't it true that in-service inspections are 5 generally scheduled well in advance by a matter of years, 6 -perhaps over the course of the reactors life?
l 7 A Yes.
l 8 Q Do you know of any planned activities at Surry, l 9 either at Units 1 or-2, that would call for a full core !
10 discharge, something along the lines of a steam generator in !
11 service inspection or the like?
1 12 A Yes. It would be at Surry next year.
e- .
And what kind of activity would that. be?
(_) 13 Q 14 A In-service inspection. ]'
i 15 Q How about in subsequent years?
16 A The next- one would come at some point in the future. '
17 I don't know.
18 Q Do you know if there is any .in-service inspection i 19 planned for 1987? ,
20 A Not to my knowledge. -
4 21 Q How about 19887 l
22 A 1"o . Not to my knowledge.
/~)N
( .
i 23 Q So, I take it you just simply don't know what the 24 plans are for a future in-service inspection?
l Am-Federal Reporters, Inc.
25 A There are none planned in the near term. In-service
262 ,
I
- 3-5-Suet 1 inspection is performed on an average of once every ten years i
2 depending on the nature and type of inspection that has to 3 be done.
I ;
4 Q I see. I would like to turn next to the economic 5 issues that we have been discussing concerning their relative 6 economic costs of dry cask storage, transshipment. You have i
7 devoted a section of your testinony to this.
l 8 I would like to explcre it briefly with you. Page l i
9 13 of your testimony, you state that the -- you give a figure !
i 10 at the bottom of the second full paragraph of 18.4 million j 11 dollars of the cost o,f dry cask storage activity without 12 fuel' consolidation; is that right? l i
7s
(_) 13 A (The witness is looking at the document.)
, 14 Yes. f 15 Q Could you describe how you arrived at that figure, l 16 please?
l ,
17 A It's based on the unit price sf dry cask storage i
18 of about eighty dollars a kilogram.
19 Q So, what you did was, you multiplied eighty dollars a
20 per kilogram times the number of kilograms uranium, and came 21 within 500 assemblies?
<~ '.
I A Right.
> _) 22 !;
23 Q Tell me if my calculations are correct. Are there 24 two hundred and thirty thousand kilograms of uranium in 500 Ace-Federal Reporters, Inc.
25 assemblies?
I 263 I
" 1
- #8-6-Sue'T 1 A I don' t. have a calculator with me. It's 460 1
2 kilograms per assembly.
3 Q Times 500 assemblies?
Times 500 assemblies.
4 A
-5 Q Now, from Pages 13 to 14 in your testimony, you.
6 state that if fuel consolidation is used then the price of i
7 dry cask storage may drop from 18.4 million down to -- no, l'
8 I misspoke.
I 9 What you stated was that with consolidation of fuel 10 the price would drop down to sixty to seventy dollars per 11 kilogram; is that correct? j l' .
12 A Yes.
13 Q Well, just so we can get apples and oranges --
14 A That's assuming twenty-five dollars-per kilogram f 15 .before the consolidation.
16 Q Thank you. Just so we can get apples and oranges, 17 how much money are we talking about?
18 Are we talking about 18.4 million mithout consolide-19 tion? Can we come up with a figure of consolidation so we .
20 can compare them?
21 A It would reduce it based upon the lower unit cost i
- O (j 22 of sixty to seventy dollars per kilogram. I 23 Q In an effort to come up with a dollar figure, would 24 it be fair to multiply an average price of, say, sixty-five ;
weemws ca nm. ine. }
25 dollars per kilogram times that same figure, number of kilograms? :
I
s 264 if8-72 Suet ^1 A Yes.
~
"2 Q Does 14.95 million dollars sound about right?
o . 3' .A It sounds about right. Without a calculator, ,I 4 can't say that 'it's exactly correct but it sounds about-5 _right.
6 ' O .~ ' Now, on Page 15 and in your oral' summary this }
-7 morning, you stated that some . expert ob' servers have estimated l l
8 that their cost of ' fuel consolidation may run as low as ten 9 dollars per kilogram?
10 A Yes.
l 11 Q I .take it that would have the effect of further _ !
12 reducing the cost of the dry cask storage for consolidation?
l'^' (~' . A Yes.
If the unit cost of consolidation were lower,
-13
- 1'4 -it would certainly reduce the. cost of dry cask storage in 15 consolidated fuel. i 16 Q If the cost of consolidation were to drop from --
17l well, L for purposes of your calculations, instead of using; a !
l 18 figure'of twenty-five dollars _per kilogram and using the-figure!
i 19 Lof: ten dollars,z wouldn' t that _ tend to reducce the cost- of dry cask from an average cost of sixty-five dollars .per [
20 1
.. 21 kilogram down to fifty dollars per kilogram?
D ib I - 22 A Approximately, yes.
23 -Q ~ And would that produce a total cost for dry cask i
'4 4 .
with consolidation of 11.3 million dollars, or does that yFederes neoormes. Inc.
-25 sound about right?
\
.,e==-~ w m..e- ec -- ,--e.r,,.wd--,.3-m,,,c wr
! 265 i i
- 8-8-Suet ! A That sounds about correct. 9 2 Q So, what we have identified for dry cask with r;
~
3 consolidation is a range of costs of somewhere between 11.5 V
4 million dollars and 15 million dollars; is that right?
5 A Of consolidated fuel.
6 Q With consolidation, right.
t 7 A (The witness nodded in the affirmative.) ,
8 Q Now, I would like to turn to the cost of trans-9 shipment. Starting at Page 11 in your testimony, you state 10 that so far Virginia Power has spent somewhere in the range i 11 of 886,000 dollars on the transshipment proposal; is that -
12 right?
74
'~~
13 A Ye s . -
14 Q And you expect to spend another 235,000 dollars i
15 this year on that? '
16 A Correct.
I 17 Q Now, when you calculate what the total costs of 18 transshipment will be you then seem to add that figure, 886,000; 19 to the figure of 235,000 and to add that combined figure to 20 a per kilogram cost of fifteen dollars; is that right?
7 21 A That's correct.
22 Q And the total cost then is 4.57 million dollars, 23 according to your testimony; is that correct?
24 A Yes. ;
Am-Femi ngemn. is :
25 Q Well, I wonder if there is not a problem with this. ,
i
266 j
- 8-9-Suet 1 Specifically, at later points in your testimony, at Page 14 ,
i i
2 and Page 15, for example, you sort of throw out a figure of
- 3 fifteen dollars per kilogram as the cost of transshipment.
f i l 4 And wouldn' t it be more accurate to say that the 5 cost of transshipment is fifteen dollars per kilogram plus 6 these front end costs, the so-called startup costs; so i l
7 actually fifteen dollars per kilogram probably understates 8 the cost by some factor?
I 9 Is that right?
10 A The total cost would include the front end cost; 11 however, those have been already either expended or committed 12 to expenditure.
,/m
\' >l 13 So, if you are looking at the cost of the future ,
14 options, for example, ;omparing dry cask to transshipment, i 15 the numbers I mentioned for dry cask did not include some 16 startup costs for VEPCO. So, if you are trying to make a 17 comparison between transshipment and dry cask storage the 18 comparison I made is on the basis of what future costs would !
19 1 be per unit, not including for either case the startup costs.
20 Q If, however, we were to be making these comparisons 21 in a previous day, say a year ago or two years ago, then you
-J 22 would want to incorporate some of those startup costs into i 23 your economic calculations; isn't that right?
24 A. - Yes.
us-FMwd Rmonen, lm:. l 25 Q Turning to Page 14 in your testimony, at that l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ __ 1
267
- 8-10-Suet j point --
2 JUDGE WOLFE: Wait a minute, please, Mr. Dougherty. ,
,~ '
3 BY MR. DOUGHERTY: (Continuing)
V 4 Q In the second full paragraph, which is the last 5 full paragraph, you acknowledge that the proposed trans-i 6 shipment of 500 assemblies to North Anna would advance the l 7 loss of full core reserve there and provided an analysis ,
l~
8 of economic costs of two different means of dealing with 9
that increase, i
10 The first involves consolidation of the fuel in 11 the North Anna pool and you estimate that consolidation would 12 cost sixty-five dollars per kilogram, as I recall; is that
\' right?
13 14 A The sixty-five dollars per kilogram is a total ,
15 cost which includes the transshipment and the consolidation. l 16 In terms of Ehe sixty-five dollars per kilogram, 17 what that includes is based upon an assumption of twenty-five 18 dollars a kilogram for the consolidation itself. Since you j 19 have to consolidate two kilograms of fuel to create one 20 storage space, if you take a twenty-five dollar a kilogram 21 consolidation cost, double that, which is fifty, and then g
x- '
22 add fifteen, is where you get the sixty-five.
23 Q Could you give me a dollar figure for that? What 24 would the total cost be at sixty-five dollars per kilogram Am-Federal Reporters, Inc.
25 times 500 assemblies? Do you have that figure available, or d
268
- 8-ll-Suet j can you calculate it?
2 A If someone had a calculator I could do it in two 3 seconds.
' ')
~
Q How does 13 million dollars sound?
4 5
A That's probably about correct.
6 Q Now, the other alternative that you discuss is 7
Che use of dry cask storage at North Anna. And you state ,
8 that this would probably cost in the range of seventy to 9 ninety dollars per kilogram, plus fifteen dollars per kilo-10 gram for the transshipment direct cost. .
11 For purposes of calculation, would it be fair to 12 use an average figure of eighty dollars plus fifteen?
( _) 13 A That's reasonable, yes.
14 Q So you are talking about ninety-five dollars per !
15 kilogram. !
16 Do you know how much that would be on a total 17 base, with the total cost of that transshipment and dry cask 18 storage at North Anna? ,
19 A It would be approximately 20 million. Again, 20 without a calculator, I can't give you the exact figure.
21 Q 22 million doesn't sound out of range, out of n
() _ 22 line?
23 A That's probably not too far of f.
24 Q So what we have then -- tell me if I'm wrong --
Ace-Federal Reporters, Inc.
25 for dry cask at Surry we have figures in the 11 million to
m 269 .
15 million to 18 million dollar range, depending on whether !
- 8-12-Suet) 2 or not we consolidate and_ whatnot. For transshipment with x 3 these other scenarios at North Anna, we have a range of 13 4 million to 22 million.
5 A Except that I should note that in the case of 6 the lower figure at- Surry, you are looking at ten dollars 7 .a kiiogram for consolidation.
8 The comparable figure at North Anna, assuming ten !
9 dollars per kilogram for consolidation, would be a total cost i
10 'of approximately thirty-five dollars a kilogram for the !
11 transshipment and the consolidation at North Anna.
12 Q Thank you very much.
k- 13 A That figure would be considerably below the lower 14 limit for the range that you 'are quoting of 11 million. {
15 Q What would that figure be?
16 A At thirty-five dollars a kilogram, again if you 17 multiply by the number of kilograms of fuel -- let me do 18 the multiplication in my head for a second.
19 (Pause.)
20 MR. MAUPIN: Mr. Chairman, it might be well if 21 the witness could do it on paper, because we are certainly I think it would be better to !
22 in no hurry that I know of.
i 23 have the record as accurate as we can have it.
24 JUDGE WOLFE: All right.
AeFederd r.eportm, inc.
l 25 (The witness is calculating.)
L .'. ,
270
- 8-13-Suet.1 WITNESS SMITH: It would be slight yl over eight 2 million dollars.
3 BY MR. SMITH: (Continuing) f-s
~b~'I Q For what? [Now, what does that .eight million 4
5 dollars - what is that associated with?
6 .A That is associated with the lower limit for the i
.7 total cost in terms of the transshipment to North Anna and !
i 8
consolidation based upon an assumed ten dollars per kilogram {
9 for consolidation, which is comparable to the figure that l
10 you were talking about for the dry cask storage at Surry, 11 assuming ten dollars a kilogram. ,
i 12 .Q What about dry cask storage at North Anna without f^
(-)' 13 consolidation? Are we still talking 122 million for that?
14 A Yes. l 15 Q' Thank you. Now, you stated in your testimony ,
16 that for the dry cask storage proposal at North Anna without 17 , consolidation is 22 million, that 22 million dollar figure i
18 that that perhaps shouldn't be that high. Those costs will l
19 accrue-in the future. Therefore, they are less expensive 20 than costs that would be occurring today.
21 Is that correct? i rm .
A)ss 22 A ' Typically, in a present worth cost evaluation you 23 discount future costs based on approximately three percent 24 per year. So that if you look at the cash flow over a Am-Federes n.corters. ine.
25 period of years, future costs would be discounted.
a 271 i
- 8-14-Suet 1 Q Have you performed such a present worth calcula-2 tion?
g-- 3 A For these particular figures, no, I have not.
N _/
4 Q So you don' t really have a figure as to how 5 much that should be decreased?
6 A No.
END #8 7 Simonc flws I 8
9 l l
10 11 12
(-).,
N_ 13 14 i 15 16 17 18 !
19 20 21 j
,r3 U' 22 23 24 l
Aca-Federal Reporters, Inc.
l 25 !
272 I Sim 9-1 1 Q Mr. Smith, do you know how to perform a present
~
2 worth calculation?
3 A Yes.
. /3 V 4 Q 'Have you ever received a' degree in economics?
~5 A No -
6 Q How about finance. or accounting, any of those?
7 A No, I have not.
8 Q' Have you ever received forma.1 training in.
9 cost accounting?
10 A In cost accounting?
II Right.
-Q 12 A Yes.
.'A
(,) 13 Q Where was that?
14 A At the university that I went to which was Ohio.
15 I went to Virginia Tech also and took courses at the University 16 of' Tennessee.
17 Q So somewhere in your undergraduate or graduate 18 . training you took a course in cost accounting; is that it?
19 A Yes.
20 0- Have you ever been employed as an economist?
21 A No, I have not.
) 22 Q How about as an accountant?
23 A No.
24 0 Have you ever published papers on an economic Ace Fedorol Reporters, Inc.
25 issue?
273 Bim 9-2 1 A In terms of engineering economics I have.
2 Q Which papers are you referring to now?
3 A For example, the publication that I listed in 4 my resume which dealt with the Vepco interim spsnt fuel storage 5 program included an economic evaluation of various options 6 for spent fuel storage.
7 Q I see. But you would admit though that you have 8 never received a degree in economics nor been employed as 9 an economist?
10 A No, I have not.
11 Q Do you think that yu are qualified to testify 12 before this Board on questions of economics?
,'j';
13 A In terms of questions of the relative costs of 14 these various options, yes, I do.
15 MR. DOUGHERTY: Just Wolfe, I would like to make 16 a motion at this time to strike that portion of Mr. Smith's 17 testimony that relates to economics. His training and 18 employment is in the area of nuclear engineering, and gi:ven 19 the complexity of the economic questions that were involved 20 in here, I suggest that his testimony is not credible on the 21 economic questions.
22 JUDGE WOLFE: And the economic question being what?
~ .),
23 MR. DOUGHERTY: Being the relative costs of dry 24 casks going to Surry with transshipment to North Anna and the Ace-Federal Reporters. Inc.
25 attendant activities that will ensue, including the present
,- = . ~ _ . - . .- . - .
274 wopth calcualtion s and the other items to which Mr. Smith
' ~
} ]
l 2 has testified.
I 3 MR. MAUPIN: -Well, No. 1, on a technical point,
'4 there 'is no objection to the admissibility of the testimony.
5 If'Mr. Dougherty had wanted to go into voir dire as t'.the o
6 ' qualifications of the witness he should have done so at that 7 point.
- i. <
.8 No. 2, and I may be wrong about this, but it 9 was never my impression that one needed an economist to 10 Perform..a-pr_esen t worth ca.lculation or to give a rough estimate 11 'of what the present work calculation would show. If that:were 1 (12 the case,'I think any individual industry would have to change .
its staffing quite a lot, because my impression, and we can
. () 13 11 4 'ask Mr. Smith, and in fact I think he has testified that- he
' Perfectly l capable of doing the present wor.th calettaltion,
, 15 16 but my impression. has always -been that in doing engineering 17 cost analyses that those~ kinds of calculations would come 18 as a matter of cource.
19 - MR . DOUGHERTY: Judge, may I respond to that?
20 JIJDGE WOLFE: Yes.- .
21 MR. DOUGHERTY: The essence of Virginia Power's 22 opposition to this contention is that dry cask storage is- f 23 not economic and it1 simply costs too much and therefore it
- 24 'doesn't make sense to have to compare it to the proposed Ace Federal Reporters, Inc. . .
25 . transshipment scheme. .This affects our argument that L
.. 4 -.-_._.u..,_._-.u_,_.. _ - . . . . _ . . . . . . . . _ . , . ...,..~..._._.;..,.,...,.
' 275 iSim-9-4 under NEPA dry cask islan alternative- that must be examined.
j 2 Theircresponse has been that it is not an alternative and 3 it is too' expensive, which-is really.the key issue here. I am d ,) 4 sure that Vepco has a very large staff of economists and 5
cost accountants and the rest-who are quite qualified to L6 . appear here and testify as to what the relative costs were.
~
7 : But Linstead they sent their engineer, and I just think it is 8
. inappropriate.for this Board to be asked to rely on this 9 testimony.
l'O MR. MAUPIN: May'I respond to one characteriza-
. I' ) . -tion of.that testimony?
12 JUDGE WOLFE: If Mr. Dougherty believes that
- the gist- of that testimony is that dry cask costs too much,-
.{ j 13 14 after the witness has said until he is blue.in the face that' 15 _ dry cask':is an; alternative that we 'are pursuing diligently and 16 . vigorously _ and hoper to be able to use it in the near future, 17 thenjhe-has missed the entire point of it.
-18 The point of this testimon t, which is perfectly 19 : apparent -on its face, is to show at least that there .is no 20 clear economic benefit to dry cask vis-a-vis transshipment.
. 21 Now once the present worth- were _done,2 whethe" ,
- 22 it shows it is a million"dollarsccheaper orra~million dollars-23 more.rexpensive c is not really the point of the testimony, and 24 -I would have thought that should'have been clear.
wel ne Inc.
25 (Board conferring.)
276
' JUDGE-WOLFE: The motion to strike is denied.
Sim.9-5 i First.of all, pursuant to Federal Rule of 2
Evidence 702, ' which is captioned "Tes timony by Experts ,"
3
- rm
\_j)
'this rule reads'"If scientific, technical or other specialized
'A knowledge will assist the trier of fact to' understand the
.5 evidence or to determine a fact in issue, a witness qualified 6
as an expert by knowledge, skill, experience, training or 7
education may testify thereto in the form of an opinicn or 8
otherwise."
9 Now granted and admittedly the witness is not 10 an economist, but I take it through his experience and his.
11 skill land his knowledge certainly he has that competency and 12 -
~
. ability. And he says or he has testified that he is perfectly 13
(~#)
capable and willing to make a present worth calculation.
14 Therefore, if there is going to be any question 15 as'to the validity of his.calculatio~ns, you are perfectly 16 entitled to cross-examine him on that point, and you may 17 proceed to do so.
18 As I say, the motion to strike is denied.
-19 BY MR. DOUGHERTY:
20 Q Mr. Smith, on page 16 you address the subject
.of comparative environmental effects. Starting 'on the last
.22 line n that page, in the middle of the sentence you say 23 "The effects of the proposed shipments from Surry to North 24
- "#' Anna would be well below the postulated effects set out in 1
277 Sim 9-6 j Table S-4."
2 In the same paragraph you state "In short, 3 the overall environmental effects of the proposed shipments
./ 4 from Surry to North Anna would be negligible."
5 I would like to ask you again about your 6 training. Have you ever received a degree in environmental 7 sciences?
8 A No.
9 Q Would you characterize yourself as an expert 10 in environmental impact associated with radioactive materials 11 transportation?
12 A No,
- ') 13 Q Have you ever been employed as an environmental w
14 specialist or scientist?
15 A No, I have not.
16 Q Have you ever published any papers on the topic?
17 A Published papers? No.
18 MR. DOUGHERTY: Judge, I have got the same problem 19 with this part of the testimony, and I suppose my motion to 20 strike will meet the same fate as the last one. But I at 21 least want to say that, and I think the Board should certainly (N _;
, 22 examine this testimony with the most careful scrutiny.
23 JUDGE WOLFE: We most certainly plan to examine 24 with scrutiny the testimony of all witnesses and look at all Ace Federal Reporters, Inc.
25 documents in evidence before us.
Sim 9-7 278
'l We: understand your position and we certainly 4
2 will weigh;the testimony in light of your questions or 3 cross-examination and observations.- But such testimony does 4 assist the trier of fact, which we are.
l5 MR.'DOUGHERTY:1 I am fin'ished.
6 JUDGE WOLFE: Mr. McGurren.
7 MR. McGURREN: - Your Honor',. the . staff does not have 8 any questions of this witness.
9 JUDGE WOLFE: Redirect?
10 MR. MAUPIN: I think I will not ask any questions.
II
~ JUDGE WOLFE: Judge Ferguson, Board questions?
12 BOARD' EXAMINATION
.(). 13 BY. JUDGE FERGUSON:
I4 Q Just to follow up on the area that we have just INDEX 15 discussed, Mr. Smith, Mr'. Dougherty called your attention or 16 directed your attention to ~the statement on page 17 of your
'17 prepared testimony.
18 For the record, why don' t you give us the basis l9 of the. statement that you make, namely, the last sentence in 20 that first paragraph which says . "In short, the overall
'21 _ environmental effects of the proposed shipments from Surry
() 22 to North Anna will be negligible." What basis did you use 23 to make that statement?
24 A The basis that I used was two parts, first, the
, Ace-Fedorol Reporters, Inc.
25 study that I quoted, WASH-1238, which is the environmental
-, r,e,, -- -- -,,rr,--- - , ,, .,w--- --,--.--e , - , - , - .,-e --,~n- - --w-, ,
279 Sim 9-8' j survey . of the . transportation of radioactive materials removed 2
from. nuclear power plants. I am familiar with that document 3
and I- understand the contents of it. In part it is based 4 .upon that. In addition, it is based upon the .NRC staff's
. 5 review f the proposal .that we made for the transshipment 6
of spent fuel from Surry to North Anna.
7 While my background is not in environmental
~
8 science per ce, I do have a degree in physics as well as a 9 degree in nuclear engineering. When it comes to radiation 10 and health effects of radiation. I certain have an under-11 standing of that through both the background that I have 12 from my education as well as my work experience and training F
13 I received at the company that I work for.
14 Q That is fine, but let me ask you to be specific 15 and tell us how that trainin,g that you have just referred 16 to would lead you to a statement that these environmental j7 effects are negligible?
18 A In the study that I referenced where the 19 environmental, both radiological and non-radiological effects 20 of shipment was evaluated, there were certain assumptions 21 made which are listed _ in my testimony in terms of the number -
, 22 of shipments'per year, the cooling time, in a sense discharge 23 before those shipments'are made as well as the shipment 24 distance and duration.
Ace-Federal Reporters. Inc.
25 I compared our proposal to the assumptions made
?
280 Sim 9-9 , ,j 'in the eval.dation under S-4 as to the assumptions of those 2
parameters,'and in all cases we are significantly less in 3
terms of effect than the parameters assumed in the construction
[') of Table S-4.
C- 4 5
Table S-4 was ruled as being the governing 6
generic evaluation for this type of shipment, and in that 7 table it discusses both the radiological and non-radiological-8 effects of the transport of spent nuclear fuel.
9 Q So would it be fair to summarize what you have 10 just said to say that . there is some guideline that you are 11 familiar with that says that if the effects do not exceed 12 this, then they are negligible?
13 A Yes. j 14 O And you have found that the effects do not 15 exceed what is considered to be negligible; is that correct?
16 A That is correct.
37 -Q Let me ask you to complete something that. I 18 think you' did not- complete during Mr. Dougnerty's line of j9 cross-examination, and for-the Board's information, would 20 you g over very briefly again where the proposal for dry 21
- cask storage at Surry stands between the licensee and NRC 22 that indicated that a plan had been submitted to the NRC 23 .and it is under review.
24 Could you say just a little more about that or Ac w ne inc.
25 clarify it for me?
4 -
281/82 Sim 9-10 We submitted our initial license A Yes.
ePplication under 10 CFR Part 72, as I indicated, in October 2
i f 1982. Since that time we have recieved questions from' 3
O 4 ene unc reaue ei=9 eaattio et i=cormetio= or c erificeti ==
of the information provided in that document.
At this point in time, with the exception of some questions that we hope to have answered this week, we 7 %
have answered all of the questions that we have received from 8 g the NRC staff on that proposal.
9 In addition, the licensing als'o involves 10 jj licensing of a specific cask design to be used in the pr p sed facility. The proposed facility itself consists 12 ,
O '3 The casks are the principal j4 associated with storage of casks.
safety component as far as that storage system is concerned.
15 The cask design that we would intend to use 16 j7 initially at Surry, as I have stated in the testimony, is the 18 CASTOR-5/21 indicated a source 21 fuel assemblies in the j9 cask.
20 That cask, a topical report has begn submitted 21 to the NRC on that cask. It has been reviewed by the NRC 22 and their consultants. The topical report was revised to 23 Provide additional information requested by the NRC and 24 their consultants and was resubmitted in January of this hFederal Reporters. Inc.
25 year.
283 Sim 9-11 1 It is my understanding that a topical on a 2 smaller version of the CASTOR cask has recently received 3 approval from the NRC's staff as being acceptable for 4 referencing in specific license applications. We are J 5 hopeful that the CASTOR-5/21 topical will receive a similar 6 approval.
7 We are in the process right now of incorporating MI 8 all of our resonses to the NRC's questions in our license
}
9 application for resubmittal. The NRC has indicated that if 10 the information that we are now providing is found acceptable, _
11 that they could grant a license for this facility as early d
12 as September. .
Q 13 Q September of what year?
14 A September of this year. Licensing under 15 Part 72 is based upon a one-step licensing procedure where p
i 16 a license is issued both for construction and operation of ;
+
t 17 the facility. It is prohibited under Part 72 to begin j%
18 construct' ion without authorization from the NRC, and that 19 was the reason why last month after issuance of the NRC's 20 environmental assessment for the dry cask facility we $
21 did make the request that we be allowed to begin construction 22 at Surry. That request is under consideration by the NiiC 23 at this time.
end Sini 24 Aes Federal Reporters. Inc.
Joe fols 25 -
~ -
.)
284 10-1-W21 1 Q. That is.very helpful. Now,-let me just very l 2 :briefly ask you to clarify one additional statement you made.
3 Let me see if'I can give you the context in which 4 ;I,want'to ask the question. You had indicated that there
- 5 'wasn't capacity at Surry. There is.some. capacity at North 6 l Anna'. . You indicate'd that the next refueling cycle at Surry 7 ' was . July ' 86, is that correct, number ope?
8 .A. There is a refueling going on presently at' Unit-2 9 at Surry.
10 The. next one after - that is scheduled for July.
q11 However, as I pointed out in my written testimony, that is
-12 I assuming a coastdown of that unit, in'other.words, operation 13 beyond normal full power limited lifetime, so we do have to i
, o 14 consider the fact in planning for 'the refueling that it might L15 i occur somewhat sooner than the present schedule calls for. l
+-
16 0- Q .Okay. .Now,._ tell us what occurs in October of ' 86?
I
- 7 A In Oc> >ber of ' 86, Surry Unit-1 is scheduled for
-is g refueling again, and will- then dischargeadditional spent i 19 fuel into the spent fuel pool.
20 JUDGE FERGUSON: Thank you, Mr. Smith.
XXlINDEX. 3a BOARD EXAMINATION ,
.22 BY. JUDGE KLINE:
23 .- Q With reference to the DOE test program, has NRC 24 . indicated to ycu that its granting of a license for the dry wr.e r:s n.po,s inc. '
25 cask _ facility is somehow dependent on the outcome of the DOE
J10-2-Wa1 285 1 tests?
2 A No. The DOE test program. is not required by
-3 .NRC for' licensing of the proposed dry cask' facility at Surry.
o 4 Q Why is, DOE testing these casks?. Why is it necessary 5 to test them?
6 A The test-program is being conducted for two 7 -reasons;. one has it in terms of storage of -- not consolidated-t 8 spent f fuel, . to . restore spent fuel that is viery close to the 9 design limits of the cask to ensure that the spent fuel
- 10 integrity, even with fuel.very close to the. design limits, 11 is maintained for the long term.
12 -Studies have been done that demonstrate 'the-
- 13 acceptability of dry storage. However, we. feel that it is 4
14 prudent to look at storage we feel are very close to the i
15 . design limits, much more so than would be the cas'e where --
- i i
n16 like tMe fuel source at Surry. I 17 In addition, the DOE program also involves 18 consolidation of spent fuel at the Idaho facility in dry-19 test storage of consolidated fuel. The licensed application
]
.20 (for the facility 'at Surry restores inpact fuel,not for storage
- - 21 of consolidated fuel.
22 In discussions with the NRC, it is not clear?.y 23 'am absolute requirement, but it certainly will. greatly l
24 facilitate license amendments in the future to store consolidated lmm noo,wn. Inc.
. 25 fuel, to have testing. information available from 2 Federal site
- . . - .- - -.:---.-..=.-...:--....,.,-.,- --
? f a
- l W21L 286 -l.
. -1 storage of that type"of- fuel to' present' to the NRC for r
- vg -
2 license amendment, and allow us to consider storage of consolidated fuel at Surry in the future.
3 l4 Q' On NRC's questions to you regarding.the drk cask ;
p 5 storage, could you give us some indication of the' nature of J6 It hese questions as ' to whether -- I am particularly. interested 7 as to whether they involve sny unresolved issues of health and 8 safety, or are they -- do they address some other aspect? -
e 9 A To our knowledge,'there is no unresolved health 2
10 and safety. issues remaining with the dry cask storage program.
^ 11 The CRC questions were a variety of areas, including environ-
' 12 mental. effects,. radiological effects, the exposure of personnel
~
O '13 at'the site, the maximum exposure to the nearest resident.
14 They even -tell of things like potentials for
. ' 15 fire-being caused byf the heat created by the cask, so they. were 1
16 . very comprehensive in a series of questions that we had 17 responded to.
18 The only outstanding question that I refer.to is I 19 . we had responded to questions dealing with dose rates on the l-
! 20 -s'urface of the' cask. And the NRC has asked for additional l
l _
21 backup information to allow them to repeat those calculations 3J 22 to ensure that our answers agreed with our own independent 23 . evaluation plan.- .
I- 24 QL I understand all that. You are able to answer m neoo,ws, Inc.
25 these questions without relying on any future research and L.
i, u
287-10-4-Wal
.l development, is that correct?
.2 -A . Yes. Again,-the-licensing now deals with a 1
1 3 specific cask design.. The. CASTOR-5 air intact fuel, and 77 4 this does.not. depend upon'in any way the DOE program.
5 JUDGE KLINE: Okay. Thank you very much.
6 JUDGE WOLFE: 'Any cross examination on Board's 7 questions?
8 MR.lDOUGHERTY: No questions, Judge.
9 MR. McGURREN: No questions,-Your-Honor.
10 MR. MAUPIN: Judge Wolfe, I think there are two 11 possible -- one area -- ons incomplete answer in the record 12 in response to Judge Ferguson's questions. Let'me see if I
~
y ' 13 .can clear those up.
XX INDEX- 14 REDIRECT EXAMINATION 15 BY'MR. MAUPIN:
l.
16 Q First question, Mr. Smith, that I refer to was I 17 one asked by Judge Ferguson. He asked you what you had.
18 relied on in making the statement at the end of the carry-19 over paragraph at the top of page-17, that the negligibility 20 of the environmental affects of the proposed shipments, where 21 you said you relied on two items. The WASH 1238 was one, 22 and the environmental assessment that .; Staff Exhibit No. 2 23 in this case, was'the other. l i
24 Your testimony.says -- indicates you are relying
( ._
wo mesments lne.
-25 on the testimony of Mr. Jefferson, who is not yet part of the 4
+ #
,a+ ,-n--, - --n,. w-- _,e-,. .-- p.-,.,-,--,p.,,,--,..-,w-, ,,-m,++,r --r-,,-------,,.r-w,e.me,.,,,s -m~e--,e,~,e a- -,,rn,w,,--w--wn-- em --..--eme
288 10-5-Wal 1 record.
2 Is your prefiled testimony correct?
ry 3 A Yes, it is. I would like to mention that --
U 4 Q Judge Ferguson also asked you what you had 5 said earlier would happen in October 1986 with respect to 6 refueling.
7 I believe the record will now show that your 8 testimony says Surry Unit-1 is scheduled --
A 9 It should be Surry Unit-2.
10 MR. MAUPIN: That is all.
11 JUDGE WOLFE: Can the witness be excused 12 permanently, or does he have another item of testimony?
r's. 1 -
\~ / 13 Is that not correct? Yes.
14 MR. MAUPIN: (Nods head affirmatively.)
15 l
JUDGE WOLFE: We can break -- I would like to l 16 break in at this point and ask if there is anyone in the i
17 audience who has not spoken yet who wishes to make a limited 18 appearance statement?
I9 (No response.) l 1
20 No? All right. Proceed, then. All right, it 21 is 12:23 now, and I think we may as well break for lunch, !
~' 22 and return at 2:00, at which time we will proceed with Mr.
23 Smith's second portion of his testimony. li l 24 MR. MAUPIN: My plan -- it is certainly not Am-F dera reporters. anc.
25 essential that we do so, but my plan had been to put on Mr.
1 289 8046-Whl ,
1 Jefferson who will not arrive,'as we. discussed, until
.2 tomorrow, along with Mr.. Smith.
3 Mr. Smith, his second piece ~of testimony is 4 very-brief, and is really in support or'is complimentary
~5 of Mr. Jefferson's testimony.
6 JUDGE WOLFE:- So they will appear as a panel more 7 or less?
8 MR. MAUPIN: That is what I had planned.
9 JUDGE WOLFE: All right. Well, it being understood 10 and agreeable that we^ hold off until tomorrow, then certainly 11 Mr. Jefferson's -testimony, I take it you have no objection to 12 waiting until tomorrow to hear the balance of Mr. Smith's 13 testimony? ,
14 MR. McGURREN:- No, sir.
15 MR. DOUGHERTY: No, sir.
16 JUDGE WOLFE: Well, I guess that .is the order 17 of business. After we return from lunch is to proceed with i
18 the Staff's testimony, is that correct? l 19 MR.- McGURREN: Your Honor, I don't know if it is l 20 reflected -- I can't recall if it is reflected in the letter 21 from Mr. Maupin to the Board about the difficulty with Mr.
22 Jefferson testifying this afternoon, but it is the Staff'.s 23 intent -- the Staff not proceed with its case until the direct 24 . case of the Applicant or Licensee is complete.
m n.oon.n. inc.
25 And in adt , Your Honor, one member of our I
10-7-W21 250 1
1 panel will not likely arrive until this afternoon late, and 2 we indicated that we would go tomorrow, so it was our intent
,, 3 that we follow the Applicant or Licensee's case tomorrow.
4 JUDGE WOLFE: I wasn't aware that you had noted 5 that in your letter, Mr. Maupin?
6 MR. MAUPIN: Sad to say, I thought I had every 7 piece of paper in North America. I. don't seem to have tha,t 8~ letter.
9 MR. McGURREN: Regardless, Your Honor, it was 10 our intention to follow the Licensee's case tomorrow, 11 JUDGE WOLFE: As far as I can read your letter, 12 Mr. Maupin -- do you have a copy now?
n C) 13 MR. MAUPIN: I do.
14 JUDGE WOLFE: I guess the implication is that the
.15 Staff would not proceed with its direct testimony, although i
16 i it is only by implication. There is no direct statement to i 17 that effect. Would you agree?
18 MR. MAUPIN: I agree with that. On reflection, I
.19 can see that that proposal did not come through with crystal l 20 clarity, but I had no intention -- when I say I adjourn the l 21 evidentiary portion, to mislead you..
n
'J _
22 JUDGE WOLFE: How do things stand now? What is 23 the consensus among counsel? I would like to proceed, 24 obviously, so that we can -- we are here to take evidence. If Ace-Federal Reportars, leic.
25 there is some objection or some reason why the Staff testimony
-- - - - - . -- . . ~
'10-8-W21.. 2291 l continue, put its witness up,--- well, I guess you can't really 2 .until one.of your witnesses appears, is that correct?
- .., 3 .MR. McGURREN: We would prefer to go as a panel.
f I.h . 4 We. really' didn't think that we would run out of witnesses 5 this-early.
- 6 JUDGE WOLFE: Fell, then, I take it we necessarily 7 .w ill-have to adjourn then until 7:00 tonight, with the.taking 8 of.the' limited' appearance. statements, and then wait until
'9 . tomorrow morning to proceed-with your Mr. Jefferson and Mr.
10 Smith,-is that correct, Mr. Maupin?
11 MR...MAUPIN: That is what I propose to do.
12 : JUDGE WOLFE: Mr. Dougherty, any objection.
40 i3 MR. DOUGHERTr= <Neds head neeative11.>
14 JUDGE WOLFE: Judge Ferguson indicated.that-it 15 .might be good to find out time estimated by Licensee for 16
.-- what'it considers will be cross examination. I guess we l
17 had better put that-to Mr. Dougherty and Mr. McGurren how 18 much time you both estimate you will need to cross examine
+
19 Messrs. Jefferson and Smith.
20 MR. DOUGHERTY:- Well, Judge, we never submitted 21 .a contention on sabotage. Sabotage issue is the remninents 22 o'f.our original. contention after it was largely disposed of ,
- j. 23 summarily on adable 4 issue. 'As a result, we don't have a
- 24-
,. lot of questioning to proceed with on this issue.
& noorwes. ine.
l _ 25
- JUDGE WOLFE: All right.
e i
, . . . - ,.-.:....-.=-.--.-..-.-.---....--..-...-..-.
ac' -
- 16 -W51 292 I
-m
~
1 MR'.- McGURREN: Your Honor, at this- point we do 2 not have any questions of Mr. Jefferson or Mr. Smith.
- 3 JUDGE SMITH: Do you plan to put on your panel LJ 4 of all of your witnesses-some time tomorrow, I guess?
5 Mid-morning.or.so. Perhaps earlier.
6 MR.=McGURREN: They will be here at 9:00 in the 7 morning.
-8 JUDGE WOLFE: All right. And Mr. Dougherty, how 9 much time do you think that we need without holding you to it, 10 just an estimate?
1.1 MR. DOUGHERTY: It.will be short, Judge.
'12 MR. WOLFE: Mr. Maupin?
.A D. 13 MR. MAUPIN: Mine, too.
14 JUDGE WOLFE: All right. I take it no one has 15 come in to make a limited appearance statement?
i 16 (No resp 3e.) !
17 All right.' We will recess then until 7:00 p.m. , f f
' 18 this evening here to take further limited appearance statements.
19 .We stand in recess.
20 (Whereupon,thehearingwasrecessedat12:30p.m.,{
21 to reconvene at 7:00 p.m., this same day.)
) 22 23 ,
' 24 Am-Federal Caporters, Inc.
25
CERTIFICATE OF OFFICIAL REPORTER
~This' is to ~ certify that the attached proceedings before the UNITED -STATES NUCLEAR REGULATORY COMMISSISON ~in the matter of:
-NAME'OF PROCEEDING: . Virginia Electric & Power Company (North Anna Power Station, Units l'& 2)
~
DOCKET NO.: 50-338-OLA-1 50-339-OLA-1 PLAbE: Charlottesville, VA DATE:
Tuesdav, May 21, 1985 were -held herein appears, and that this is the official
,U transcript thereof for the file of the United States ' Nuclear r Regulatory Commission.
m (sigt) MM . ,
(TYPED) GARRETT $ WALSH, JR.
(sigt) M m 78,,//, O m ,[f)
' MY '?LE H. TRAY OR A e (sigt) A A4*tM I
(TYPED)' MARY M. SIMONS Official Reporters Reporter's Affiliation
- - . - , , , - , , . - - , - - ~ , . - . , , , , , . . . , , - . , - . - - - , - , . . . . - - , , , . . . . , , , , , . - - - , , .