ML20128A773
| ML20128A773 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/22/1985 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#285-211 OLA-1, NUDOCS 8505240325 | |
| Download: ML20128A773 (54) | |
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VIRGINIA ELECTRIC & POWER COMPANY '
50-338-0LA-1 JNORTH ANNA. POWER STATION, UNITS 1 & 2) 50-339-OLA-1
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CHARLOTTESVILLE, VA PAGES: 313-364
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'MAY 22,~1985
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ACE-FEDERAL REPORTERS, INC.
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Walsh-313 UNITED STATES OF AMERICA 1
2 NUCLEAR REGULA'IORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
5
X 6
In the matter of:
- Docket Nos 50-338-OLA-1
]-
7 VIRGINIA ELECTRIC & POWER COMPANY 50-339-OLA-1 i
g (North Anna Power Station, 9
Units 1 & 2)
X 10 11 U. S. District Court for the 12 Western District of Virginia Room 300 13 255 West Main Street Charlottesville, Virg, inia 22903 14 Wednesday, May 22, 1985 15 Hearing in the above-entitled matter was convened 16 at 9:00 a.m., SHELDON J. WOLFE, presiding:
17 BEFORE:
i 18 SHELDON J. WOLFE, Chairmaa 19 Nuclear Regulatory Commission Atomic Safety and Licensing Board 20 JERRY F. KLINE, Member 21 Nuclear Regulatory Commission Atomic Safety and Licensing Board 22 GEORGE A. FERGUSON, Member
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23 Nuclear Regulatory Commission.
Atomic Safety and Licensing Board 24
' ' Ace Federal Reporters, Inc.
25 4
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APPEARANCES:
2 On Behalf of the Applicant, Virginia Electric & Power Co.
3 MICHAEL W. MAUPIN, Esquire MARCEA R. GELMAN, Esquire 4
Hunton & Williams 800 East Main Street 5
Richmond, Virginia 6
On Behalf of the Intervenor, concerned Citizens of Louisa County:
7 JAMES DOUGHERTY, Esquire 3
3045 Porter Street, N. W.
Washington, D.
C.,
20008 9
On Behalf of the NRC Staff:
10 HENRY J. McGURREN, Esquire 11 WILLIAM D. PATON,-Esquire Office of Executive Legal Director 12 Nuclear Regulatory Commission Washington, D.
C., 20555 13 14 15 16 17 18 19 20 21 6
22 23 24 Am-Federal lhportees, Inc.
25
315 g
Sic i-1 CpNIEggS WITNESSES DIRECT CROSS, REDIRECT RECROSS BOARD 2
3 HARVIN SMITH 316 319 320
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323 and 4
ROBERT JEFFERSON) 324 5
6 WILLIAM LAHS )
CARL SAWYER
)
7 WILLIAM LAKE )
JOHN ROBERTS )
341 349 352 354 8 DONALD CLEARY)
JUSTIN LONG
)
9 LEON ENGLE
)
10
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LAY-IN DOCUMENTS 1]
Fols Page 12 Testimony of Robert Jefferson 326 13 Testimony of Marvin L.
Smith II 328 14 Testimony of Messrs.
Lahs, Sawyer, Lake, Roberts Cleary, Long and Engle 346 15 16
- _X _H I B I.T _S E
37 EXHIBIT NO.
IDENTIFIED ADMITTED 18 Staff Exhibit No. 3 357 358 20 21 22 1
23 24 Ac> Federal Reporters, Inc.
25 I
316
- 1-1-Suet 1 P_ R_ O_ C E_ E D,I_ N G S_
2 JUDGE WOLFE:
All right, Mr. Maupin.
3 MR. MAUPIN:
Judoe Wolfe, would you call Marvin 4
Smith to the stand, please?
^
5 JUDGE WOLFE:
Mr. Smith. ' Mr. Smith, you remain 6
under oath.
7 MR. SMITH:
Yes, sir.
i 8
Whereupon, INDEX 9
MARVIN L. SMITH 10 is recalled as a witness by and on behalf of the Licensee, 11 Virginia Electric and Power Company, and having previously 12 been duly sworn, is examined and further testified as 13 follows:
14 DIRECT EXAMINATION 15 BY MR. MAUPIN:
16 0
Mr. Smith, were you in the courtroom yesterday
-17 during the limited appearances that were. delivered in the 18 morning?
19 A
Yes, I was.
20 0
Were you here when Molly Osmer commented on an 21 accident that occurred in Louisa County involving a truck
(
22 shipment of new fuel?
23 A
Yes.
24 0
I asked you t.resterday, as a result of an inquiry A
p.dn. ne, Inc.
25 by the Board, if you would make such inquiry as you could 1,
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317 l#3-2-Suet 1
yesterday and last evening about the events surrounding 2
that episode.
3 Have you done that?
4 A
Yes, I have.
I 5
0 would you describe for the Board the inquiry 6
that you have undertaken?
7 A
I contacted several people at Virginia Power who 8
had at least some familiarity with the particular accident 9
that had occurred, including one individual who was in a 10 car that by chance was following the truck at the time the 11 accident occurred.
12 0
Would you tell the Board the findings that you 13 were able to come uo with?
14 A
Yes.
The truck was being used to transport new 15 fuel from the Westinghouse facility in South Carolina to 16 Virginia Power's North Anna Power Station.
The transport 17 of that fuel is the responsibility of the fuel manufacturer 18 who, in this case, is Westinghouse.
19 They contracted with C&H Trucking to have the 20 fuel transported to North Anna.
C&H in turn used an inde-21 pendent trucker for that transport.
22 The truck ran off the road on Route 522.
The --
l 23 Q
Is that in Louisa County?
L 24 A
It's in Louisa County, ves.
The truck driver i Ac. Peder.1 n.p.,,.n. ene.
was subsequently convicted in, I presume, a traffic court of 25
318
- 3-3-Suet 1
reckless driving and one other charge which again I attempted 2
as to the best of my ability to determine the exact nature 3
of that charge.
It was somewhat difficult to get an exact 4
accounting of it.
But, apparently it was related to either 5
failure to maintain a log book in which he should have record-6 ed whether or not a safety check was performed on the vehicle 7
or failure to perform a safety check.
8 And it may have also been related to fa'ilure in 9
the log book the record the amount of time he had been on 10 duty.
11 Q
Any other facts about the accident which you 12 want to disclose to the Board?
13 A
The car following the truck, as I indicated, had 14 a VEPCO, Virginia Power, employee in it.
The State Police 15 were contacted and responded fairly quickly to the scene of 16 the accident.
17 The State Police were made aware that the accident 18 involved new fuel which, of course, does not constitute a 19 significant radiological hazard as could have been potentially t'
20 the case with spent fuel.
The cleanup of the accident pro-F
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21 caeded with the -- by having a response from the North Anna l
22 Power Station.
i j
'23 They brought out a crane, placed the containers 24 of new fuel on trucks and transoorted that to the oower i m W lac.
25 station and then removed the vehicle.
The area was -- as I
319 l
43-4-Suet 1
understand it at least -- surveyed to make sure that there 2
had been no release of any type of radioactive material.
i 3
MR. MAUPIN:
I have no other questions.
4 MR. DOUGHERTY:
One or two questions, Judge.
5 JUDGE WOLFE:
All right.
6 CROSS EXAMINATION INDEXX 7
BY MR. DOUGHERTY:
8 Q
Mr. Smith, do you know what the cause of the 9
accident was?
10 A
I don't have any knowledge of the cause of the Il accident, no, other than the truck driver ran off the road.
12 O
So the people that you have spoken with didn't 13 say anything about the driver falling asleep at the wheel?
14 A
There has been speculation to that effect, as 15 I understand it.
But I don't know that that has been 16 established as the cause of the accident.
17 MR. DOUGHERTY:
That's all, Judge Wolfe.
18 JUDGE WOLFE Mr. McGurren, any questions?
19 MR. MC GURREN:
We don't have any questions, 20 Your Honor.
21 JUDGE WOLFE:
Mr. Maupin?
22 MR. MAUPIN:
No, sir.
23 JUDGE FERGUSON:
Just a very short question, Mr.
24 Smith.
wr. der.: n.p.mr., :=.
25 BOARD EXAMINATION
320
- 3-5-Suet 1 BY JUDGE FERGUSON:
2 0
could you identify or distinguish for us, if INDEXX 3
you will, the difference between the containers in which
/
4 the fuel you just described were contained in and those 5
that we are considering in this spent fuel transshipment 6
issue before us?
7 A
Yes.
The containers that are used for new fuel 8
are relatively thin-walled metal containers designed to 9
really protect the new fuel from damage during transit.
10 There are two fuel assemblies contained within 1
11 each container.
And I believe there are six containers 12 normally included in a single shipment, for a total of 13 twelve assemblies.
14 These containers, since you are dealing with new 15 fuel which is unirradiated and does not constitute a hiahway 16 route control quantity of radioactive material or a signi-17 ficant radiological hazard, you know, they do have to be 18 approved by the NRC but they are not designed to the same 19, standards that a spent fuel transport cask ist designed to 20 in terms of ability to withstand accident conditions.
21 And, of course, there is no need for oroviding i
22 any shielding or containment of the radioactive contents.
23 0
I think that's important for the record at this 24 point.
If one looked at that accident, that is the one Aso Pederal floporters, lac.
25 that you just described, and commented that -- something to
F 321
- 1-6-Suet 1 the effect that:
Thank God, that wasn't spent fuel, they 2
essentially have missed the point in the difference between 3
the shipping procedurest is that correct?
4 A
Yes.
There are significant differences in the 5
procedures that are used, that are required to be used for 6
spent fuel shipment as opposed to a new fuel shipment.
7 Shipments of highway route control quantities of radioactive 8
material have additional procedures required as far as 9
training of the drivers and the conditions under which the 10 shipments are performed.
11 Also, of course, the containers themselves are 12 designed to withstand very severe accidents.
Certainly the 13 type of accident associated with this particular truck run-14 ning off the road would have been a very minor accident 15 compared to the design basis of the containers used for 16 spent fuel transport.
17 In fact, of course, I might point out that even 18 though the new fuel containers are not designed to anything 19 like the same standards in terms of surviving an accident, 20 they were not breached or broken in this particular accident.
21 Q
Just a minor point.
You indicated I thought a
(
22 moment ago that the response time of the authorities was 23 rather short.
Is that -- do you have any estimate of the 24 time?
l l A e red.I % ix.
25 A
The -- I think it's -- was in the range from what i
322
- 1-7-SneT 1
I was able to determine as far as the initial responso by 2
the police of perhaps 15 to 30 minutes.
I don't have any 3
real exact amount of time.
4 0
I thought when we took the statement yesterday, 5
it was about two hours.
But do you think that is incorrect?
6 A
There may have been some type of breakdown in 7
communication as far as contact to the Department of 8
Emergency Services for the County of Louisa.
9 In this case, of course, the peoole on the scene 10 were aware of the fact that this was a new fuel shipment as 11 opposed to a -- you know, it is a radioactive shipment but 12 certainly not one that presents a significant. radiological 13 hazard.
14 The exact nature of the breakdown, I can't really - -
15 was not able to determine in the calls I made yesterday.
16 Part of the reason for that is our emergency response 17 people were preparing for a drill, emergency response drill, 18 that is being conducted at North Anna today so I was unable 19 to get in contact with them for a more complete description 20 of that.
END #1 21 Simons flws 22 23 24 m es,.nw k l
25 l
323 Sim 2-1 1
Q To the best of your knowledge, the time between 2
the accident and the time the first authorities appeared on 3
the scene was approximately how long?
4 A
Approximately 15 to 30 minutes for the first 5
authorities to appear.
6 JUDGE FERGUSON:
Thank you.
7 I have no further questions.
8 JUDGE WOLFE:
Mr. Maupin.
9 MR. MAUPIN:
No questions.
10 MR. DOUGHERTY:
I do have any extra question, 11 Judge.
12 FURTHER CROSS-EXAMINATION INr 'C 13 BY MR. DOUGHERTY:
14 Q
Mr. Smith, do you have any direct knowledge 15 of the facts surrounding that accident?
16 A
No.
My knowledge is not a direct knowledge 17 as I think was indicated when we started to make these 18 coments, my knowledge was based on telephone conversations 19 yesterday as wiel as some familiarity with the accident 20 prior to that.
21 Q
My concern is your estimate about the time that 22 it took for response authorities to arrive at the scene.
23 Would you describe your testimony on that topic as hearsay?
24 A
Yes, it would be hearsay.
Ase reder.1 hp.,em, w.
25 Q
Could you tell the Board who it was that you
324 l
Sim2-2 spoke with that gave you that information?
2 A
I spoke with Lucian Fox who works for our 3
company who was in a car following the truck and contacted 4
from a telephone the police authorities and reported the accident.
l 5
6 MR. DOUGHERTY:
Thank you.
7 No further questions.
g JUDGE WOLFE:
Mr. McGurren, anything?
i l
9 MR. McGURREN:
We don' t have any questions, 10 Your Honor.
11 JUDGE WOLFE:
Nothing more, Mr. Maupin?
12 MR. MAUPIN:
No, sir.
13 (Pause.)
l 14 Let's ask Mr. Smith to stay on the stand and 15 call Robert M. Jefferson to the stand, Your Honor.
16 JUDGE WOLFE:
All right.
17 Mr. Jefferson.
13 Whereupon, 19 ROBERT M. JEFFERSON 20 was called as a witness on behalf of the applicant and, i
21 having been first duly sworn by Judge Wolfe, was examined 22 and testified as follows:
23 DIRECT EXAMINATION l
INDEX 24 BY MR. MAUPIN:
w eder W,i=.
25 Q
Mr. Jefferson, would you state for the record
325
' Sim 2-3 your name and your residence address.
y A
My name is Robert M. Jefferson.
I live at 2
3 13136 Montgomery Northeast, Albuquerque, New Mexico, 87111.
4 Q
Mr. Jefferson, I have before me a document 5
consisting of 38 typed pages and one appendix.
It is dated 6
May 9th and it is entitled the
" Testimony of Robert M.
Jefferson."
Do you have a copy of that document?v 7
A Yes, sir, I do.
g Q
Have you read that document?
9 A
Yes, sir, I have.
10 jj Q
Did you write the document?
A Yes, sir, I did.
12 13 Q
Are there any corrections you wish to make to.
14 the document?
15 A
I have two corrections. The first is on pago 4, le line 7, a sentence that begins near the end of that line, "In 17 1978, the NRC.
" and it should be "1979".
18 The next correction is on page 20, line 9, 19 the word " actuating" should be " alignment."
20 Q
Are.those the only corrections you wish to make 21 to the testimonyi 22 A
Yes, sir.
I 23 Q
As. corrected, is the testimony, to the best of 24 your knowledge, true and correct?
m asp.,=,., :=.
25 A
Yes, sir, it is.
326 Sim 2-3 Q
Do you wish to adopt it as your testimony in this proceeding?
A Yes, I do.
3 MR. MAUPIN:
Mr. Chairman, I move the admission 4
of the testimony of Robert M. Jefferson into evidence and request that you instruct that it be bound into the trans-cript at this point as though read.
7 JUDGE WOLFE:
Any objection?
MR. DOUGHERTY:
No.
MR. McGURREN:
No objection, Your Honor.
JUDGE WOLFE All right.
The written testimony jj f Robert M. Jefferson will be incorporated into the record 12 as if read.
g (The Testimony of Robert M. Jefferson follows:)
34 15 16 17 18 19 20 21 22 23 24
- 4. ped I m,.=n, w.
25
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFCRE THE ATOMIC SAFETY AMD 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 ROBERT M.
JEFFERSON I.
Introduction My name is Robert M. Jefferson.
I am a private consultant in the area of the transportation of radioactive materials.
I began my consulting activities on April 1, 1985, after being em-ployed by Sandia National Laboratories (Sandia) in Albuquerque, New Mexico for the previous 28 years.
During the period from 1978 until my retirement in 1985, I was Manager of the Transpor-tation Technology Center operated by Sandia for the Department of Energy (DOE).
For three years prior to that, I managed a variety of transportation and reactor safety programs for the Laboratory.
My direct involvement in transportation of radioactive mate-rials goes back to 1970, when I was responsible for shipping re-search reactor spent fuel from Sandia to Idaho.
Subsequently I was Supervisor of Waste Management and Transportation activities for Sandia until 1975.
From 1975 to 1978 I was Manager of Reactor Safety Studies and Transportation Research.
As Manager
. e of the Transportation Technology Center, I have been responsible for the majority of the transportation safety research that has been conducted worldwide for the past 8 years.
This includes i
research designed to assess the ability of spent fuel casks to withstand transportation accidents and hostile attacks.
In addi-l tion, I have been cognizant of those activities being carried on by other countries and other organizations within the United States, as they related to the safety research being conducted by Sandia.
During my years with Sandia I was an active participant-in the deliberations of the technical community on the safety of
, transporting spent fuel and other radioactive materials, both on a dcmestic basis and on an international basis.
My personal involvement in the area of sabotage and diver-sion of special nuclear materials, and the possible consequences arising from such acts, began in 1969.
At that time I was asked by the Atomic Energy Commission (AEC) to participate in a study, later known as the Rosenbaum Study, to evaluate the susceptibility of uranium and plutonium to diversion into clandestine production of weapons.
As the result of that study, i
I developed an interest in this field that I have maintained I
since that time.
That study was conducted by a team of five people.
My area of expertise was physical access, adversary encounters, use of explosives and other weapons, escape, and detection avoidance.
I was selected for participation in the study by virtue of my continuing responsibility for the protection of the special nuclear materials utilized by Sandia's i
V b
y fast burst reactors (an operation which I supervised for approximately 10 years).
Sandia's involvement in spent fuel cask testing began shortly after the 1970 explosive attack on the Mathematics Research Center at the University of Wisconsin.
This explosion of 4,000 pounds of ammonium nitrate / fuel oil (ANFO) created concern at AEC over the vulnerability of spent fuel shipping casks to explosive attack.
Sandia was asked to undertake a series of experiments to evaluate the effects of various explosive attack methodologies on full scale spent fuel shipping casks.
The objectives of that study were to determine what sabotage methodologies were successful, the level of expertise needed to make them successful and the resources needed by a saboteur to mount a successful attack.
Because the results of that study provide information that would be of great use to a potential saboteur, the tudy itself was classified confidential and is unavailable for this proceeding.
However, since the work was conducted by my organization within Sandia, I am familiar with the purposes, experiments and results.
Since those early tests were intended to serve only as scop-ing studies and since they showed that it would be difficult to mount a successful attack, there was no follow-up.
However, as an outgrowth of the 1978 " Urban Study," - performed by Sandia for NRC to assess the risk of transporting radioactive materials through urban areas - interest in sabotage was rekindled.
That study, based on estimates of release fractions approaching li of task contents, predicted hundreds of early deaths and thousands
O
-4 of latent cancers should a successful attack be carried out in downtown New York City at rush hour.
A series of simple tests was performed in 1979 which indicated that the release fraction would be closer to 0.07% of cask contents.
This data point was included in a 1980 " Urban Study," and the consequences dropped to tens of early deaths and hundreds of latent cancers, again in a densely populated, highly urbanized locality.
In 1978 the NRC instituted safeguards requirements to protect spent fuel shipments from sabotage with the condition that if research should show that the concern was unjustified, NRC would relax the requirements at a later time.
In 1980 two programs were
. initiated to study explosive attack on shipping casks.
One study, funded by NRC, was conducted by Battelle Columbus Laboratories.
The other, funded by DOE, was conducted by my organi:ation at Sandia.
I shall discuss the results below.
l As an outgrowth of the early work, my experience with the study of sabotage and diversion, and this recent experimental work, I have kept in close contact with the rather substantial safeguards tetivity carried on at Sandia since the mid-1970's.
I l
have participated in that activity as a peer reviewer for reports, and I have been involved in the process of deciding whether special programmatic activities belonged in safety research or in safeguards.
My resume is attached to this testimony as Appendix 1.
The purpose of my testimony is to address four primary areas of concern.
The first involves the threat that a malevolent act will be attempted against a shipping cask during the process of l
transporting spent fuel from Surry to North Anna.
The second is the prebability that such an attempt, if made, would result in the saboteur's taking possession of the spent fuel cask or reach-ing it with some attack method.
I shall discuss these two areas, which are closely related, in Section III of this testimony. The third area, discussed in Section IV, involves the potential consequences of saboteurs' gaining possession of the cask or reaching it with an attack method.
The fourth concerns the emergency responses that could be expected from public and private entities in the highly unlikely event thac a successful sabotage attack was to be accomplished against these shipments.
This is the subject of Section V.
II.
Description of the Cask The TN 8L cask to be used for the transport of spent fuel from surry to North Anna is a NRC-certified shipping cask.
As such, it must adhere to certain design criteria imposed on all shipping casks for spent fuel and other high level radiation sources.
Unlike the container for any other hazardous material currently being shipped within this country, a shipping cask for spent fuel must be, designed to accommcdate the severe environments that might be encountered during a serious accident.
While the regulations do not require that the casks survive these environments without any change of physical appearance, they do require that the ability of the cask to centain its radioactive contents remain unaffected b'/ the accident.
r.
Further, NRC's regulations require that the radiation shield-ing, which is an important safety feature of the cask, remain i
essentially intact, although external radiation levels are allowed to be greater after an accident than before.
The regulations contained in 10 C.F.R. Part 71 specify that the cask must be de-signed to survive a set of engineering criteria specified in the regulations as " hypothetical accident conditions."
These design criteria encompass impact, puncturo, fire and immersion and, by inference, such other phenomena as crushing and tunbling.
Since these design criteria are in offect worldwide, they have been
, evaluated by a nunbar of reses.rch organizations around the world for their adequacy.
Studies conducted within the United heates indicate that these criteria unecmpass nubstantially mr.eu than 99% of all accidents encountured in the real world.'- It la to this kind of standard that the TN GL cask has been designed.
The cask itself is roeghly triangular in cross section with heavily rounded corners.
In has a. vert. Leal diransion of 5 feet, 4 inches, top to bottom, including the copper fine.
The cask is of typical steel-lead-steel censtruction, similar to those tested in the explosive scoping tests conducted in the early 70's and to the later units subjected to attack by conical shaped charges in the Sandia work by Sandoval, at a,1. which is described belev.
The cask is roughly 18 feet, 1 inch long including shock absorbing covers and 15 feet, 8 inches long without the covers.
The shock absorbing covers are additional cuahloning material (balsa wood and steel) placed on either and of the cank during transit to mitigate some of the forces that might be ence6ctured
-7 l
during severe accidents.
These covers are attached by four bolts j
and are removed prior to handling the system at the reactor pool.
The fuel elements are contained in three individual stainless steel %" wall square chambers.
Two are arranged side by side on the bottom with a third centered above them.
Surrounding these stainless steel chambers are boron-loaded copper plates to reduce the thermal neutron flux emitted from the fuel assemblies.
The bottom ends of these chambers are closed with stainless steel plates, while the tops are open to the outside of the cask once the lid has been removed.
Surrounding the three square stainless steel chambers is i
lead that varies in thickness from a minimum of 5.3 inches to a i
maximum approaching 9.8 inches.
Proceeding out from~that point
{
is a layer of wet cement (0.4 inch thick) and a carbon steel outer shell (0.8 inch thick).
Attached to this carbon steel l
shell are 15,800 copper cooling fins or fingers that project
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L outward from the surface of the carbon steel outer shell.
In addition, there is a 5.9 inch thick resin coating on the outside f
of the carbon steel shall which encapsulates the bases of the 1
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+
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fins.
The entire cask, when empty, weighs 73,600 pounds.
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The open and of the cask is closed by a structural assembly
~
knowa as the lid which serves to complete the shielding at that I
i point and provides the containment seals to prevent escape of l
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gases-from the chambers.
This lid is approximately 10.6 inches thick, is constructed of stainless steel, carbon steel, lead and resin.and weighs approximately 1,875 pounds.
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- i Beneath the balsa wood and steel shock absorbing cover, the lid is held in place by 16 1 " bolts.
There are four lifting eyes on the lid outer surface.
Further, there are two centering pins mounted in the body of the cask that act to center the lid onto the cask and to maintain its proper rotational alignment so.
that it is always placed on the cask in the same orientation.
While this cask has never been subjected to actual test con-ditions, calculations contained in the Safety Analysis Report for Packaging (SARP) indicate that the cask can survive, without loss of containment and with minor loss of shielding, the regulatory i
requirements contained in the 10 C.F.R. Part 71 hypothetical acci-dent conditions.
While it might suffer some cosmetic damage in an accident (such as the bending of fins) the cask is capable of hurvivingtheprescribedaccidentconditionswithnostructural damage.
In addition to holding a certificate of Compliance from the NRC, this cask holds a certificate from the French Atomic Energy Authority and is being widely used in Europe.
The NRC Certificate of Compliance for the TN 8L cask allows Transnuclear and Virginia Electric and Power Company (Virginia Power) to load the cask with no more than 4,840 pounds of spent fuel assemblies, irradiated to a maximum level of 38,500 megawatt days per ton and cooled for a-minimum of 150 days, assuming an initial average uranium 235 en-
- Krichment of 3.2 weight percent.
These requirements define the maximum decay heat and radiation levels of the spent fuel.
The decay heat of the fuel assemblies must not exceed 7.9 kilowatts per assembly.
The spent fuel to be shipped from Surry-to North Anna falls well within these limitations.
'll r
_9_
The cask is not authorized to ship failed fuel, and the cer-tificate of compliance requires that, on completion of loading, the external radiation level must be less than 17 mrem per hour one meter from the surface of the package.
This is considerably below the regulatory limit of 200 mrem per hour at a distance of one meter.
III.
Threat of Sabotage Malevolent attacks on this kind of transportation system have been virtually nonexistent.
In the more than 5,000 ship-
'ments of spent fuel that have occurred in the United States since 1964, there has been so far as I know only one case of an attack of any sort.
This occurred in the early 1970's on a shipment be-tween Sandia and the Idaho National Engineering Laboratory.
The shipment involved a cask carrying four research reactor fuel ele-ments of the Materials Test Reactor type.
The cask was the sole cargo in a forty-foot aluminum van-type trailer carried by a trucking company specializing in this kind of material.
At the time, the company was having labor difficulties, and in southern Wyoming the trailer was fired upon by unknown assailants using a shotgun.
Pellets penetrated the aluminum siding of the trailer but, as one would expect, did absolutely no damage to the cask.
Because this event happened on a shipment that I was making, and because of my continuing interest in this subject, I have in the intervening years tried to find other instances of attacks on
- P.
shipping casks both in this country and in other western countries.
To date, I have discovered no other examples.
On the basis of this experience, then, one can comfortably say that the probability of attack, although it cannot be quanti-tatively stated either from experience or by modern estimation means, is quite low.
In addition, an analysis of the impediments to sabotage attack, their effects on would-be attackers, and the types of objectives that potential saboteurs might wish to achieve, supports the conclusions that (a) the likelihood that such an attack would occur is small and (b) the likelihood that such an attack would place the saboteurs in position to damage the cask is also small.
A.
Impediments to Sabotage.
Section 73.37 of 10 C.F.R.
sets out NRC requirements for the physical protection of spent fuel shipments.
Virginia Power must comply with this provision.
The regulations are designed to minimize the probability of sabotage and to facilitate the loca-tion and recovery of spent fuel shipments that may come under the control of unauthorized persons.
The utility-shipper must develop a physical protection system that provides for early detection and assessment of attempts to gain unauthorized access to spent fuel shipments, notification to appropriate response forces of any sabotage attempts and plans for resisting sabotage
- attempts until response forces arrive.
The shipper's physical protection system must provide fer (a) notification of NRC in advance of each shipment, (b)
_11-procedures for coping with circumstances that threaten deliberate damage to a shipment, (c) instructions to shipment escorts for analyzing and dealing with threatening situations, (d),
establishment of a communications center staffed continuously
+
during shipments to monitor the progress of the shipments and notify appropriate agencies if an emergency should arise, (e) prior arrangements with local law enforcement agencies for response to emergencies, (f) training of shipment escorts and (g) calls from escorts to the communications center at least every
- two hours.
With respect to shipments by road, the regulation requires that the spent fuel transport vehicle be accompanied by an escort and specifies that in heavily populated areas, the vehicle b,e accompanied by an armed local law enforcement agent or by escort vehicles front and rear, each with an armed escort.
It also requires that escorts have the capability of communicating with the shipper's communications center, local law enforcement agencies, the transport vehicle and one another through the use of various types of communications equipment.
The regulations require that the transportation vehicle be equipped with an NRC-approved method for immobilizing the cab or trailer in the event of a sabotage attempt.
All of these requirements are designed to increase the com-plexity of an attack for a would-be saboteur, the number of hurdles to be overcome and the time the attack would take.
In addition to the impediments posed by 10 C.F.R.
S 73.37, the saboteurs would confront significant obstacles simply by
virtue of the bulk, weight and design of the cask, the perilous nature of its contents and its ability to withstand explosive and other attacks, which I will discuss in the next section of this testimony.
What effect would the impediments I have described have on persons considering sabotage of a spent fuel shipment?
It is generally conceded that the probability of an attack is inversely proportional to the difficulties involved in the attack.
- Thus, the more resources or skill a successful attack would require, the lower the probability that the attack would be attempted.
Plainly, a saboteur considering an attack on a spent fuel shipment would face a formidable array of difficulties or, put the other way, would require a formidable array of resources and skills.
In the first place, the potential saboteur would run a serious risk of death or injury, given that armed escorts or law enforce-ment agencies will accompany these ' shipments and that others would be called to the scene promptly in the event of a threat.
This risk, I should add, is in addition to the threats of harm he will face if he should gain possession of the cask and attempt one of the damage scenarios I describe in the following section.
Although not true in the Middle East, studies of terrorist activities to date in the United States have indicated that the probability of an attack is drastically reduced if the attcck requires the sacri-l fice of the attacking team's lives.
l l
The physical dangers inherent in such an attack are accentu-l ated by virtue of the fact that the saboteur would face significant i
I
time pressures.
Transport and escort vehicles will be equipped with communications equipment - at least citizens' band radios and radiotelephones - and will be in contact as a matter of course with the shipper's communications center.
The communications center will check periodically with the convoy.
The vehicles, and in turn the communications center, will also be able to com-municate with local law enforcement agencies, who will be aware of each planned shipment before it begins.
The transport and escort vehicles can summon help quickly.
This consideration, along with the likelihood that the transport vehicle immobiliza-
, tion device would be used, would make it extremely difficult to
^
carry out a successful hijacking attack.
Thus, it would be par-ticularly difficult to mount an attack that contemplates securing possession of a cask in a remote area and transporting it to another destination.
In short, from the terrorist's standpoint, the longer the period of time involved from the initiation of his action until 4
its completion, the higher the probab~ility that society will take countermeasures and that his attempt will fail.
Further, the higher the apparent probability that his effort will fail, the lower the probability that the saboteur will attempt it.
- Thus, when one studies the probability of terrorist attack on the shipping cask it becomes important to examine the scenarios involved and the risk to the saboteur (including the length of g
time each imagined scenario would involve).
Moreover, the very impediments that will discourage a sabo-tage attempt will tend to insure that if it is nevertheless t
9 carried out, it will fail.
Studies conducted of the battlefield methodologies employed in Vietnam indicate that in small group encounters, such as the kind that would be involved in a terrorist attack, the aggressor usually breaks off contact at the first indication of the loss of his ability to control the situation.
Thus, I would anticipate that unless the terrorist was very, very dedicated (even to the point of death) he would likely terminate the attempt when the situation had approached the point where he might risk capture or death (e. g., due to response by local law enforcement agencies).
A saboteur's ability to control all of the variables surrounding a spent fuel shipment would be severely limited.
With the impediments I have discussed in mind, it is important to consider what objective an attacker might have in mind if he were to consider attacking one of the Surry-to-North Anna ship-ments.
B.
Sabota'ge Objectives.
One obvious objective might be to attempt to divert special nuclear material for weapons purposes.
If that were a saboteur's intent, however, he would have far more promising targets.
Mate-rials.for weapons use could be extracted from spent reactor fuel only by reprocessing, and it is difficult to imagine how a sabo-teur, even if he could gain possession of a cask and its contents in the first place, could manage to have it reprocessed.
Another objective, of course, might be to make a " political statement."
Historically, the underground movement it. this country has staged its attacks in order to embarrass the m
. t political establishment or commercial activity involved.
Their attacks, however, have been carefully planned and mounted at times and locations so as to minimize the possibility of public injury.
The " political statement" is intended to draw attention to "the cause" and to rally public support for the terrorist's objectives.
Attacks which harm innocent bystanders do not develop sympathy or public support for the terrorist's cause but instead arouse outrage and demands for his removal as a threat.
As long as this continues to be the case in this country, and I see no reason for it to change, then an attack for the purpose of making a statement would take the form of harassment rather than an attempt to breach a cask with its potential dangers to the public.
Given the danger to saboteurs that I have described and the likelihood of failure, a spent fuel shipment simply would not be an inviting target.
A third purpose of attacking a shipment of this nature would be to cause direct harm to the public.
If the attacker intends harm to the public, he could try to accomplish it by one of two broadly defined approaches.
Either he could attack the cask di-rectly as it travels along its intended route (for example, by a projectile fired from a weapon) or he could attempt to divert the j
shipment (i.e., hijack it) for use at a time and location of his choosing.
The direct attack has the advantage of minimizing his time involvement and therefore minimizing the probability that he might be detected and preve~nted from completing his attack, but it also poses the possibility of producing inconsequential results.
For example, in order to stage a successful attack he i
4 would probably have to interdict and strike the cask along a remote part of the shipping route in order to minimize the chance of early detection.
If he does, however, the consequences of breaching the cask, even if he can accomplish it, would be far less than if the attack were carried out in a heavily populated area.
In contrast, a diversion would require the terrorist to hide his hijacked possession, or to transport it to a point where he might cause more damage, and would therefore increase the time span required and the likelihood of his detection prior to the time that he could produce significant public damage.
As I indi-I cated above, this time trade-off is important, since the more time involved, the greater the probability of the terrorist's detection and subsequent capture or destruction.
As I shall discuss below, the cask is a rugged system requif-ing more than simple explosive techniques to create a release.
The requirements of 10 C.F.R. S 73.37 for communications and es-corts reduce the attractiveness of this target a great deal.
Furthermore, the fact that the tractor will be equipped with a device to immobilize it should the driver decide that he is under attack makes it necessary that an attack be a highly coordinated event.
If the element of surprise to the driver and escort are not sufficient to prevent their notification of appropriate autho-rities, or if surprise is not sufficient to prevent the driver from disabling the tractor, the potential saboteur is faced with i
the task of uncoupling the crippled tractor from a very heavy 1
l
trailer and recoupling another tractor to pull the load away.
All of these activities would take place in full public view and would take long periods of time, again reducing the potential saboteur's likelihood of success.
The requirement for a highly coordinated attack reduces the likelihood of success as attested to by certain operations carried out by this country in support of rescue attempts overseas.
Furthermore, should the attacker be successful in hijacking the shipment he must find a place to hide it while he awaits the optimum conditions for the second stage of his activity.
Einga_.
.the cask emits radiation that is detectable at very, very low levels, it is well within the capability of existing equipment to search for and find the diverted shipping cask, thus in. creasing the time pressure felt by the attacker.
The searching can be carried out using helicopters or fixed-wing aircraft carrying low-level radiation detection equipment.
Such equipment is available to the Commonwealth of Virginia on short notice from Andrews Air Force Base.
Again, diversion is not an attractive alternative.
In summary, then, it is doubtful whether spent fuel is an attractive target for a terrorist at all.
It is a poor target for one who wishes to divert weapons grade material.
If the saboteur's purpose is embarrassment of the Company or the political system, there are certainly more attractive targets available that are less protected, require less skill, involve less probability of detection and capture, and provide suf-ficiently spectacular results to produce acceptable press
coverage.
In any event, adequate political effect could be achieved in an attack on the cask without attempting to breach the cask and thus risk harm to the public.
Finally, if it is harm to the public that the saboteur has in mind, there are many other less risky targets that can, in fact, provide far greater risk of harm to the public than the sabotage of a spent fuel ship-ping cask with far less risk of failure and possible injury or death to the saboteur.
In short, there is no compelling reason to select spent fuel as a target of opportunity, whatever the saboteur's motivation.
There are too many dangers involved, too much time is required, too many things can go wrong.
The likeli-hood of failure is very high.
Thus, I believe the likelihood that such an effort will be made, or that if made it will succeed, is correspondingly low.
IV.
Consecuences of a Successful Attack In spite of the low probability that a terrorist will under-take an attack on a spent fuel shipping cask, and in spite of the impediments to the success of such an attack if attempted, the question remains, what if the attack itself were successful.
What sort of consequences might be the result?
It is important to understand that there are three very different approaches to a successful sabotage, each with different consequences.
A.
Mechanical Damace.
One approach that has been suggested is to mechanically dis-assemble the cask and remove a fuel element from the cask for subsequent dispersion using explosives.
While this is possible,
it would be an extraordinarily difficult, dangerous and time-consuming undertaking.
First of all, the cask has been designed for vertical loading and unloading, but it is carried lar truck in a horizontal position.
The cask weighs approximately 37 tons, so in order for a terrorist to erect the cask to the vertical position, he would have to have access to a 50-ton crane with adequate hook height, or he would have to devise some sort of alternative erection system for this purpose.
Most scenarios would have the terrorist remove the lid of the cask while the cask is still mounted in the horizontal posi-9 tion and then remove a spent fuel assembly.
This activity is not impossible, but it would require a time consuming and difficult process.
First, he must remove the shock absorbing cover, which weighs 900 pounds and is held on by four bolts.
Subsequently he must withdraw sixteen ik inch diameter bolts.
Even with the bolts removed, the lid of the cask, which weighs nearly a ton, would remain in place.
The fit of the lid to the cask body is very close, making it doubtful that the saboteur could remove the heavy lid without it binding during the process.
Further, there is a vertical steel wall welded across the front of the trailer that would make is impossible to do such things as attach cables to the lid in order to pull it out.
It is also important to note that once the lid is removed the terrorist has no way to put it back on the cask, so he must carry the situation he has created through to some conclusion.
The opened cask, minus its lid, would project an intense beam of radiation along the cask axis.
The radiation beam would decrease in intensity with distance, but
the intensity close to the open lid of the cask would be high enough to deliver a lethal dose in a very short period of time.
Assuming that the cask lid were somehow removed, the next task facing the terrorists is to remove the spent fuel elements from the cask, which some say can be quite easily done by simply grappling for a " handle" on the fuel bundle and extracting the fuel elements one at a time.
The fuel elements being shipped do not have a " handle" or bail but are normally picked up by a special tool that fits inside the top nozzle and uses actuating pins to engage small holes in the nozzle wall.
If a saboteur was to plan to use such a tool, he would have to have it manufactured in ad-vance and then face using it without the benefit of proving it works.
Moreover, there is no spot on the top of a fuel assembly that could be easily hooked, certainly not by a person who cannot look at the object he is trying to hook.
For example, the leaf springs at the top of the assemblies would accommodate a hook or grapple if the assemblies were free standing.
But when the assem-blies are in the square chambers of the cask the leaf springs (the only parts that might be grasped) lie flush against the chamber walls, so that a hook could not be attached to them.
Furthermore, in older to attach a special tool or grapple for a hold on the fuel tssembly, one must place part of his body, at least his arm, into the high radiation field.
When one sticks his arm into a high radiation field, the ionization on the skin and the hair causes all the hair on the arm to stand up and gives one a tingling sensation.
Thus, the terrorist involved in this sort of activity would be very conscious of the fact that he was
1 '
4 receiving a high dose of radiation to his arm.
This dose would indeed be quite high since the saboteur would be required to grapple for this difficult-to-grasp fuel element in a blind fashion.
Assuming, nonetheless, that the saboteur could secure and maintain a firm hold on one of the fuel bundles with his grapple, he might attach the grapple to a long line and attempt to use some motive means to extract the fuel bundle from the spent fuel shipping cask, but the steel wall welded to the front of the trailer would prohibit this approach.
In addition, as long as the steel wall remains in place at the front of the trailer, he could not in any event extract the assembly all the way from the cask.
Even if he can remove the wall and take the assembly all the way out of the cask, he is now faced with the fact that he has an exposed fuel bundle giving off a very high signal to those searching with aircraft-carried radiation detectors, and further-more, that it will prevent him from removing the other fuel from the cask.
The remaining problem is how he is to go about placing the explosives along the fuel element.
There are several means pos-sible, but all of these involve high radiation doses to those involved in placing the explosives.
Because of the time and dif-ficulty involved, it might be argued that the saboteur would in-stead simply remove the lid of the cask and place explosives in the mouth of the cask in order to disrupt the fuel on the inside.
While this might sound more plausible, again the saboteur faces a trade-off since the amount of spent fuel that would be disrupted i
-Q l
in( the explosive in this manner is considerably less than in the
\\
previous scenario.
To be sure, if this type of attack could be executed success-fully, it could result in significant release of respirable mate-rial.
Simply describing the process, however, emphasizes the tremendous time constraints and extraordinary difficulties that would face the saboteur.
My view is that this type of attack is the one a saboteur is least likely to try.
To remove the fuel from the cask involves high risks for the saboteur, both radio-logical and in terms of interdiction.
Moreover, one may assume that this type of effort would have to be attempted in some remote 1
location.
A great deal of time would be required to remove the shock absorbing cover, the 16 1% inch diameter bolts in the lid and the lid itself.
There would be risk enough of detection in a remote area.
If this operation were carried out along the.out-skirts of Richmond, it would greatly increase the probability that before the operation could be completed, it would be pre-vented by local law enforcement agencies.
If the attack must be
?
carried out in a remote area, on the other hand, the potential 4
consequences will be decreased significantly.
Thus, with these mechanical attacks on a cask, the saboteur is faced with a very high risk scenario that is likely to produce '
minimal results even if successful.
I repeat, there are simply more attractive targets involving less risk and higher pay-offs.
i B.
Projectiles Since mechanical disassembly involves such a high risk to a potential saboteur, he might consider using projectiles to attack
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the shipment, since they would permit him to attack quickly and from a distance.
During the mid-1970's, Sandia tested the use of devices such as light antitank weapons (LAW) or other projectiles that could be launched from firing tubes, such as bazookas.
These projectiles use shaped charges to penetrate armor plating, and therefore could theoretically be used to penetrate a shipping cask.
As a result of the tests, it was concluded that this type of armament would be ineffective against spent fuel shipping casks for two primary reasons:
First of all, the aiming had to be ex-tremely accurate, which is not to be expected by persons who are not using this type of weapon on a continuing basis.
Second, the conical-shaped charge used in these devices is simply not large enough to be effective against the wall thicknesses found among typical spent fue.1 shipping casks including the TN 8L.
We also considered armor-piercing projectiles that use impact shock waves to create spall on the inside of the armor against which they'are used.
These devices normally require a cannon for their firing, and therefore were not considered broadly available to potential saboteurs.
In addition, most shipping casks used today -- and certainly the TN 8L -- utilize lead shielding, which is not an effective medium for transmitting spalling-type shock waves.
Thus, I conclude that " stand-off" type weapons, such as the bazooka-fired LAW devices, would not be effective for use by sabo-g_
teurs in attacking spent fuel shipping casks.
i f
- ~ ~ - - - -,,
C.
Explosives A third methodology would be the use of explosives.
As I indicated earlier, Sandia, at the request of the Department of Energy, has evaluated a number of types of explosives, both thec-retically and through the conduct of a series of experiments.
~
Taking a cue from the 1970 attack against the Math Research l-Center at the University of Wisconsin, Madison, Sandia conducted a test utilizing a 4,000-pound charge of ANFO, placed ten feet away from a spent fuel shipping container.
The resulting explosion hurled the shipping cask approximately 150 yards and bent the cask, but did not breach its containment.
Similar evaluations were carried out using breaching charges which I
consisted of large quantities of material placed in intimate con-i tact with the shipping cask.
The TN 8L is a particularly effec-tive cask in resisting the use of this kind of explosive.
i I
Another attack methodology evaluated was the'use of a platter charge.
Here a circular steel plate is mated with an appropriate mass of high explosives and detonated such that the l
platter becomes the' projectile.
It was found that, in spite of their apparent simplicity, these are difficult to construct and even more difficult to aim.
One of the most obvious o'f the explosive attack methodologies, and one that is widely available, is the conical-shaped charge.-
In contrast to the small and somewhat ineffective 4
LAW, it is possible to place larger charges at appropriate loca-tions to create damage on a spent fuel shipping cask.
A variety of sizes and configurations of shaped charges was tested.
25 -
The final unit used in this series of tests conducted by Sandia was a burn bar, in which an oxygen-lance type of device could be used by a saboteur to burn a hole in a shipping cask.
This particular approach has the difficulty of being suicidal on the part of the saboteur, since burning through to the spent fuel i
would expose the individual to very high levels of radiation.
Each of these attack methodologies was evaluated from the s
standpoint of its relative degree of success, the availability of the explosive devices and the time required for their use.
From this group of attack methodologies, it was concluded that the
, conical-shaped charge meets most of the requirements that a sabo-teur might consider when mounting his attack.
While the conical-shaped charge does require some skill, both in selecting the proper charge for the job and in using it, it was considered that the probability of success using this method is higher than the other methods available.
In analytical studies conducted in 1977 and 1979 (published in 1978 and 1980 as the " Urban Study"), it was estimated that a successful attack upon a spent fuel shipping cask, using a conical-shaped charge, could possibly disrupt as much as 10% of the contents of the shipping cask.
It was further estimated that, of the 10% disrupted, approximately 10% could be
-mechanically fractured into respirable-size particles.
This would result in a release fraction from the shipping cask, as the g
result of a successful sabotage attack, of approximately 1% of the cask contents.
Very early explosive tests indicated that this value should probably drop to 0.7%, and that was the value i
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used in the first Sandia " Urban Study" (SAND 77-19 27).
In the i
interval between that study and a subsequent revision of the Urban Study published in 1980 (NUREG/CR 0743), additional testing by Sandia indicated that the most likely release fraction would approach 0.07% of the contents.
This series of explosive tests on spent fuel shipping casks carried out at Sandia culminated in an experimental attack using a full-scale conical-shaped charge against a full-scale spent fuel cask containing a typical fuel assembly (although not spent).
This final test in the series was conducted inside a chamber so that all of the resulting debris could be collected.
The conical-shaped charge managed to punch a hole through one side of the cask, which at its narrowest point was 0.6 inch in diameter.
The resulting explosion and intrusion into the cavity of the cask disrupted the equivalent of 10.4% of the fuel.
That means that a little over 10% of the fuel pellets contained in the zirconium tubes in a fuel assembly inside a cask attacked by this means would be broken into more than two pieces.
As a result of the disruption of this fuel, slightly over 1%
of the fuel was ejected from the cask.
While this was very~close to the origina1' estimate, most of that 1% was in the form of large particles that would be deposited in the immediate vicinity of the cask.
Only about 0.0034% of the fuel in the cask was re-
' leased in respirable form and therefore available to cause biological harm to the general public.
Since that test was con-
-ducted on a single fuel element cask, additional studies were done to evaluate what might happen with a three-element cask such
as the TN 8L.
Since the respirable fission product release is proportional to the amount of fuel disrupted, and since not all three fuel elements are in line (so that the same jet,can go through a proportional amount of all three of them) the actual release is something less than three times the amount that would be released from a single fuel element cask.
Calculations using data obtained in these tests indicated that the release from the TN 8L-type cask would be on the order of 0.0024% (while the percentage released is smaller for the three-element cask the actual amount is larger).
It is comforting to see that the percentage of release is constantly going down as more and more is discovered about what actually happens as a result of an explosive attack, but our ultimate concern is the potential effect on the the public of
~
such an attack.
In the first Urban Study where this sabotage problem was addressed, it was calculated that the result of a
~
successfu1 sabotage conducted in a location in downtown New York during rush hour could create hundreds of early fatalities and thousands of latent cancers.
The 1980 Urban Study, utilizing a release fraction of 0.07%, reduced those public impacts to tens of early fatalities and hundreds of latent cancers.
It should be noted that the explosion itself was estimated to kill at least 140 people in the vicinity of the blast.
Utilizing the results of the full-scale tests that I 4
discussed above, and including results from parallel testing conducted for NRC by Battelle Laboratories in Columbus, Ohio, it has now been calculated that the consequences of a successful
explosive sttack on a spent fuel shipping cask, again in downtown New York, would be one expected early fatality (that is, a death occurring within one year of the time of the sabotage).
If all of the uncertainties were pushed to their limits, it might be
- possible to achieve a maximum of three early fatalities.
Using the same analytical models, one would calculate an expected consequence of four latent cancers, with a maximum possible of 14 (these are cancers occurring anytime following the event and include the early fatalities).
The experimental work and conclusion are described in An
^
. Assessment of the Safety of Spent Fuel Transportation in Urban Environs, R.P.
Sandoval et al., SAND 82-2365 (June 1983), which l
will be introduced as an exhibit in this proceeding.
These con-sequences were calculated using very specific assumptions as to the spent fuel involved and the population density ib. mediately
{
surrounding the event.
For instance, the,New York City case in-volved an average population density of 101,500 persons.per square mile.
Data from the County Road Map Atlas of the i
j Commonwealth of Virginia, published by the Department of Highways j
and Transportation in January 1981, using preliminary 1980 census data that match those used for the New York City study, indicated that the average population density of Louisa County was 32.4 i
persons per square mile.
In fact, the highest population density along any route between Surry and North Anna is the City of Richmond, which the County Road Map Atlas states has an average j
{
population density of 3508 persons per square mile.
Since the consequences of a release are directly proportional to the number i
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of people exposed, which is in turn directly propertional to the population density, a simple ratio between the population densities along the route and those in the study would give a ratio of the effects as well.
For the highest population density in Richmond, Virginia, that ratio turns out to be 3.5%.
Applying that percentage to the figures previously stated would result in zero early fatalities and zero expected latent cancers although, using the limiting error bounds, one might expect a maximum of one-half a latent cancer as the result of a successful sabotage attack in Richmond,
.. Virginia.
Should the attack be successful but occur in the rural portions of the state, those figures would drop to zero across the board.
Further, the consequences are reduced by the age of the fuel being transported.
The fuel considered in the Urban Study upon which the figures above were based was 150-day-old fuel that had
.been burned to a level of 33,000 megawatt days per ton.
Using calculations for the fuel that Virginia Power intends to transport, and the additional decay time between 150 days and the approximately 5-year-old fuel that will be transported, the consequences can be further reduced by at least a factor of 10.
Should a saboteur be successful in blowing a hole in a cask, the cleanup operation would be complicated only slightly by the
(
resulting beam ~that would be emitted from this penetration.
The very fact that a shaped charge was used to produce the penetration and subsequently disrupt the fuel beneath the hole would indicate that the source inside the cask for irradiating through the hole has been reduced as a result of the explosive
attack.
Even if it had not been reduced, what would come out of this conical hole would be a beam of radiation which, by the time one got 500-600 feet away, would have dropped to a level of little concern.
The recovery operation, therefore, is complicated only 1
i by the fact that there is a beam which must be avoided.
Further-more, the beam can be rather easily plugged in the early phases of the recovery operation.
Since the beam itself would in all likelihood be pointing up in the air, it would be a simple matter to take molten metal such as Cerrobend (which melts at 150-250*
F.) and pour it into the opening, thus forming a temporary shield over the hole.
Other materials could also be used, such as lead shot or even earth.
All that is needed is to close the hole to prevent additional escape of particulates and to provide some sort of shield in the opening created by the blast.
Once this closure is accomplished, the cask can be handled using conventional means.
{
On these bases, I have concluded that the consequences of a successful sabotage attack within the Commonwealth of Virginia upon the TN 8L cask would be minimal in terms of public health.
Since these calculations address just the fission products, the question reasonably arises, what about other radioactive mate-rials within the cask?
One of the other products would be fission-product gases, which, by the time fuel is two years old, would j
have decayed to rather negligible values.
Further, since this group of fission products consists of noble gases that would not chemically combine with other materials, their possible release
=
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.I from the cask would simply result in their dissipation in the atmosphere, and they would have little effect upon the public.
Another material inside the cask would be the crud or corro-sion products that collect in the crevices on the fuel assemblies.
This material could be dislodged as the result of an explosive attack, but it represents a small portion of the total radioactiv-ity involved within the cask and would be released in roughly the same proportion as the other radioactive material or fission prod-ucts.
Thus, it too would contribute insignificantly to the re-lease accomplished.
As a part of the studies conducted by Sandia, analyses were performed on the behavior of certain representative and volatile fission products.
The concern was that since some of these fis-sion products may be vaporized at fairly low temperatures, they might behave differently as a result of an explosive attack.
The finding was that, in fact, most of the materials which are volatile at the temperatures involved in the explosive attack do behave quite uniformly.
Cesium, for example, is volatile at the tempera-tures involved, but is very active chemically and condenses very rapidly on any cold surface.
Since the entire inside of the cask is not heated, but only subjected to a pulse of high temperature, any cesium produced during the attack quickly condenses on the cold surfaces of the inside of the cask, and on the cold surfaces immediately outside the cask, so that almost none of the cesium would escape the cask itself.
One of the interesting results of the sabotage tests con-ducted on spent fuel casks was the electron microscope analysis
. _ ~ _
of the products produced by the explosion.
Those materials were found to contain lead, which had condensed from the vapor state, stainless steel and zirconium cladding, which had solidified frem the molten state, but no evidence whatsoever that any of the funi material (UO ) had suf fered anything more than mechanical frac-2 turing.
Since the melting point of UO is on the order of 5000*
2 F.,
this finding is consistent with expectations.
Furthermore, it means that in order to produce respirable-size particles, they must be created as the result of the shock waves and not the tem-perature involved in the explosive attack.
This significantly
. reduces the quantity of respirable fines produced.
V.
Emergency Response Response to an emergency occurring during the transport of radioactive material generally occurs in three phases with differ-ent personnel being involved in each phase.
Obviously, the first phase begins when the first person of authority comes upon the scene.
This is usually a local policeman or fireman but frequent-ly will be a state police officer.
These people have a simple set of responses in the case of any hazardous material accident (egg., radioactive materials, gasoline, propane or other such threats to the public health and safety).
First they will typi-cally cordon off the area to prevent bystanders from getting in-volved in the accident by being too close.
Sec6nd, they will notify the appropriate personnel, who then notify the authorities about the event.
For example, the local policemen, the state policemen or the fire crew responding to such an accident would
_n
notify their dispatcher, who in turn would notify the carrier, the shipper and emergency response personnel within the state or locality in which the accident occurred.
These first_ responders are authorized to attempt to save life, but they are not usually trained or equipped to make decisions concerning recovery from the situation, although this is not uniformly the case in the Commonwealth of Virginia.
The second phase is stabilization.
It consists of the col-lection of more knowledgeable people at the accident site who can evaluate what has happened and determine what steps are necessary
,to stabilize the situation to prevent the accident from creating progressively worsening problems or continued involvement of the public.
In the case of a radioactive accident, this phase would involve the use of radiation detectors of various types to define the extent of the accident, to decide upon the most appropriate response measures on the part of the responders and the public and to formulate long-term response plans for the incident.
The third phase of the recovery is cleanup.
It involves commercial organizations who come in to clean up and restore the site and decontaminate the area to its original condition.
These companies generally respond to all sorts of accidents involving hazardous materials and are equipped to address the situation in such a way as to prevent further public involvement and to expedit-(
iously return the accident site to normal conditions.
This same response pattern would hold true whether the acci-dont was created by chance or deliberate intent.
34_
/
d It is important to note that there are capabilities ab various levels for addressing the first two of these three phases.
In my travels around the country and talks with emergency response personnel and state police, sheriff's depprtments and local fire departments, I have yet to find a police chief or fire chief or sheriff who did not know the proper procedures for this first level response.
Further, they all know the appropriate persons to contact in case of an accident involving hazardous materials including radioactive materials.
Without exception,
,for example, every emergency response person I have run into knows the phone number for Chemtrec.
Chemtree is a commercial organization sponsored by the Chemical Manufacturers Association that provides information to first responders on the nature of the hazard involved so they may more appropriately tailor their
-s response to the situation.
In the case of radioactive materials the Chemtrec response will be supplemented by consultation with the Interagency Radiological Assistance Program headquartered in Germantown, Maryland.
All that is required is that the U.N. haz-ardous material number _on the placard be given to the Chemtrec operator.
Chemtree is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week, and I
can in fact give quite accurate information on what to do in the i
initial phase.
Further, Chemtrec automatically notifies several groups of people if information on the shipper, carrier or con-4 signee is available to them from the first responder.
For example, they will notify the carrier, the shipper *and under some circum-stances the Joint Nuclear Accident Coordinating Center (JNACC).
I
..,--,~_..-n_,,-....
.,,,.--.,,,_n_,-.-.---..
- - - ~. - - -. - ~ - - - - -. _
JNACC is composed of a group of federal agencies who jointly support the response centers in six geographical areas around the 3
country.
The response center for the Virginia area would be in Washington, D.C.
This system, which was designed solely for re-4 3
f sponse to nuclear accidents, can provide a variety of services ranging from simple information transmitted ov'er the telephone to the ' dispatch of teams of personnel and supporting equipment for aiding in thg second or stabilization phase of the response.
Perhaps the best known illustration of their response capabilities f
is that a team from Albuquerque, New Mexico was on site in Polo-4 maris, Spain, within 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> after four nuclear weapons were lost from a U.S. Air Force bomber as the result of a midair col-
^
lision in that locality.
Their capability includes complete moni-toring systems mounted in light vehicles that are capable of being transported.by air to any air field capable of handling a C-141 aircraft.
Furthermore, they have available to them, in compu-terized forh, a list of all air field facilities in the country such that, given the location of an accident, an inquiry to the computer will tell them which air field is the nearest to the accident scene.
In addition to these capabilities, there are a host of other 1
personnel and equipment available to the first responder should he feel the need for this additional help.
For example, all hos-7 pitals accredited by the American Hospital Association must have
=s nuclear medicine department and must therefore employ a health N
I s
F
.,__-,_---._.-._,_,.__,,_,,___m__-
physicist.
This health physicist must be provided with the proper instrumentation for carrying out his job.
Thus, the first re-sponder could call upon any local hospital for support in evaluat-ing the magnitude and extent of an accident. involving radioactive materials.
A similar capability is available from many state universi-ties, including the University of Virginia and Virginia Polytechnic Institute and State University.
Perhaps the strongest support in the case of the shipments under consideration would be the utility itself.
Virginia Power has a staff of health physicists and a broad range of instrumentation capabilities that would enable them to participate in the second phase to define the appropriate response mechanisms and otherwise to advise those responsible for both the first and second phases of the operation.
One additional
- capability available from Virginia Power is a helicopter which could be used along with appropriate instrumentation to track or otherwise find the shipment should it have been hijacked and di-verted (although it is more likely that equipment available at Andrews Air Force Base would be used).
As indicated before, this tracking from the air is quite feasible because of the radiation signature given by the cask.
Finally, the Commonwealth of Virginia has in place a well-trained cadre of personnel in the Bureau of
-Radiological Health and the Department of Emergency Services to I
deal with any possible sabotage-induced radiological incident.
The second phase response would be coordinated by the Department of Emergency Services.
Even the initial response would be aug-s mented by the fact that many Virginia law enforcement officers
- and fire department personnel have already been trained by the
- Commonwealth in handling such emergencies.
Thus, there are in place both the' techniques for responding to an accident of the type of concern here as well as a well-established cadre of re-sponse personnel.
VI.
Conclusions The likelihood that a sabotage attempt bent on injury to the public will be aimed at the Surry-to-North Anna shipments is quite small.
To my knowledge, no such serious attempt has ever been
- launched against any of the more than 5,000 shipments of spent fuel that have been made in this country.
This is not surprising.
The threat of injury or death to the saboteurs, the terrible time constraints affecting the attack and the small chance of success are significant~ deterrents.
If the objective is weapons-grade material, the saboteur i
will recognize that spent fuel is a poor source of such material.
If the objective is to make a " political statement," he is likely to conclude that there are far safer and easier ways to make that statement, and, in any event, such attacks are unlikely to have as their purpose significant injury to the health and safety of the public.
If the objective is to injure the public, he is like-ly to conclude what common sense tells us, namely that there are
(
far more accessible targets that will produce much greater levels of the damage he wishes to inflict.
Even if the saboteur should elect to make the effort, he faces severe impediments in gaining access to or control over the l
l
38-O cask.
He.may face armed escorts in multiple vehicles.
He must deal with a sophisticated communication system among the vehicles, the shipper and law enforcement officials and thus the prospect of bringing large rataliatory forces down on his effort.
He will face the prospect that the tractor will be immobilized and an awareness that the spent fuel shipment is not a cargo that he can successfully hide.
Finally, even if he can gain possession of 4
the cask, the maximum damage he could reasonably be expected to inflict has been shown to be quite small.
When I consider (a) the small probability that an attack
.will be launched, (b) the small probability that an attack will successfully breach the cask, and (c) the fact that even if an attack is~ successful the public health risk is almost non-existent, I conclude that the sabotage risk associated with the proposed shipments is insignificant.
S w
v-e-
sn-
~
r:-
i
~'
Appendix f 4
' ROBERT M. JEFFERSON 13136 Mongtomery Blvd. NE Albuquerque,. New Mexico 87111 (505) 291-0484 EXPERTISE:
Technical aspects of the transportation of radioactive and other hazardous materials including: The regulations (both domestic and international), their interpretation, their adequacy and the technical impact of any proposed changes; the technology as has been developed by the various R&D programs worldwide since 1978 and applied to design concepts, materials, interfaces, testing and sabotage; the risks surrounding the transportation of radioactive materials both real (as quantified in technical risk assessment methodologies) and institutional (as defined by activists, political bodies and media);
emergency response techniques, capabilities and agreements.
In addition, as a recognized authority in the field, I am well known by activists, state personnel, carriers, industry people and U.S. government personnel.
This capability is augmented by well developed communication skills that make it possible to adapt information to specific audiences.
More details and additional expertise available upon request.
EMPLOYMENT:
1957 to present Sandia National Laboratories Albuquerque, New Mexico -
Since 1978 Manager Nuclear Materials Transportation Technology Department (Transportation Technology Center)
Responsible for the operation of the full range of Transportation R&D -
programs sponsored by the DOE to asure that there are safe, effective, economical, and publically acceptable means of transporting radioactive materials in support of DOE programs.
1975-1978 Manager Nuclear Fuel Cycle Technology Department 4
Responsible for R&D on the safety of commercial nuclear power plants including effects of fire, radiation, and aging on the reliability of safety systems.
1973-1975 Supervisor of Waste Management and Transportation Division Responsible for R&D programs in waste technologies and in the equipment for transporting radioactive materials.
1965-1973 Supervisor of Radiation Applications Division Responsible for the design, development, operation, and utilization of five research reactors (both steady state and pulsed) and eleven electron beam i
machines.
i l
1962-1965 Supervisor of Research Support Section L
Responsible for the design, construction, installation, and initial operation of special apparatus for conducting research in the interaction of radiation with matter.
l
. 1957-1962 Staff Member Involved in nuclear reactor design and field experimentation in radiation effects.
1954-1957 U.S. Air Force - Sandia Base, Albuquerque, New Mexico Instructor in nuclear physics, health physics and weapons systems.
1953-1954 Convair - Ft. Worth, TX.
Junior-Engineer designing kinematic systems for aircraft landing gear and similar actuating mechanisms.
1964-1980 University of New Mexico Nuclear Engineering Department - Albuquerque, New Mexico Adjunct Professor of Nuclear Engineering (part time) teaching courses at MS &
PhD level.
EDUCATION:
BS ME Michigan Technological University 1953 (with Honors)
MBA University of New Mexico 1964 (with Horv,rs)
CURRENT PROFESSIONAL ACTIVITIES:
e Member National Research Council, Transp ortation Research Board, Committee on Transportation of Hazardous Mat stials (A3 C10) e Member - San.dia Reactor Safeguards Committue e
Chairman - University of New Mexico Reactor Safety Advisory Committee Member Publications Steering Committee of the American Nuclear Society e
e Instructor for Energy Education Programs; a continuing eduction seminar i
for high school school science teachers in Illinois Speaker in Media Information Program conducted by (SE)2 e
e Speaker. for American Nuclear Society on topic of Transportation of Radioactive Materials PAST PROFESSIONAL ACTIVITIES:
e Member National Academy of Science Committee on Nuclear and Alternative Energy Sources e
Chairman Fifth International Symposium on Packaging and Transportation of Radioactive Materials PATRAM (5/78) i e
Chairman Ad Hoc Committee on Transportation of the Intiernational Atomic Energy Agency (5/78)
. e American Nuclear Society Chairman - Special Publications Books (76-79)
Chairman - National Publication Committee (71-76)
Chairman - Remote Systems Technology Division (73-74)
Chairman - Trinity Section (New Mexico) (70-71)
AWARDS:
Exceptional Service Award - American Nuclear Society, November 1980 e
e Nuclear Public Communication Award - American Nuclear Society, November 1983 (First Recipient)
PUBLIC SERVICE ACTIVITIES:
Teaching leader - Bible Study Fellowship (1980-Present) e Past Show Coodinator - Southwest Arts & Crafts Festival 1975 e
Past President New Mexico Arts & Crafts Fair 1973 e
PUBLICATIONS:
Available upon request G
327 Sim 2-4 1
DIRECT EXAMINATION (Con tinued) 2 BY MR. MAUPIN:
3 Q
Mr. Smith, you have already identified yourself.
4 I have before me a document consisting of three typed pages 5
dated May 9, 1985 entitled " Testimony of Marvin L.
Smith (II).
6 Are you familiar with this testimony?
7 A
(Witness Smith)
Yes.
8 Q
Was it prepared by you or under your supervision 9
and direction?
10 A
Yes, it was.
11 Q
Are you satisfied that it is true and correct?
12 A
Yes.
13 Q
Do you wish to adopt it as additional testimony 14 in this proceeding?
15 A
I do.
16 MR. MAUPIN:
Mr. Chairman, I move the admission 17 of the testimony of Marvin L.
Smith, II into evidence in this 18 proceeding and as that you instruct the reporter to bind it 19 in the transcript at this point as though Mr. Smith had 20 read it.
21 JUDGE WOLFE:
Any objections?
22 MR. DOUGHERTY:
No objection, Judge.
23 MR. McGURREN:
No objection.
24 JUDGE WOLFE:
All right.
The written direct AceJederal Reporters, Inc.
25 testimony of Marvin L.
Smith, II is incorporated into the
328 1
record as if read.
2 (The testimony of Marvin L.
Smith II follows:)
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 c
22 23 24 Ace Federol Reporters, Inc.
25
May 9, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
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 (II)
I.
Introduction
, My name is Marvin L.
Smith.
I am a Supervisor, Nuclear Engi-neering for Virginia Electric and Power Company (Virginia Power).
My responsibilities and qualifications are described in Testimony of Marvin L. Smith (I), which describes Virginia Power's spent fuel storage problems, and its solutions to those problems, and which will be made a part of the record in this proceeding.
II.
Virginia Power's Physical Protection System Robert M. Jefferson will testify in this proceeding about the requirements of 10 C.F.R. 5 73.37 and the implications of those requirements for possible sabotage attacks on the proposed i
Surry-to-North Anna shipments.
Virginia Power has in place a physical protection system that complies with, and in some in-stances exceeds, the requirements o'f 10 C.F.R. S 73.37.
_.m
~ _., _. - -... - _,,, _ _ _.. _.
.-_,--...,___,_y_
' ~.
3-III.
' Photographic Exhibits 1
Virginia Power will offer as Exhibits in this proceeding twelve photographs of the Model TN 8L spent fuel shipping cask.
These photographs are designed to familiarize the Board with some of:the cask' features and the steps taken during the loading and unloading of the cask and the preparation of the cask for shipment.
All of the photographs were taken by Bryan H. Wakeman, a Virginia Power employee who reports to me.
The photographs were taken either'at'the Surry Power Station, the North Anna Power Station or the AGNS Facility at Barnwell, South Carolina.
I shall give
-below a brief description of each photograph.
Unless the desqrip-tions states that the photograph was taken at the AGNS Facility, it was taken at either Surry or North Anna.
The letters in the left-hand column correspond to the letters that are affixed to
.the photographs that will be offered as Exhibits in this proceed-ing.
Designation Description A.
The cask arriving at the Power Station.
B.
The front trunnion with impact limiter attached; the front tie-down is also shown.
C.
The rear shock absorbing cover, the rear trunnion with impact limiter attached and the rear tie-down.
D.
The cask suspended from the Power Station 5
handling crane.
E.
The lid bolts being loosened and the "A" penetration being used to vent air while the cask is being filled with water; this photograph was taken at AGMS.
I 1
+e-
..,,-,s-
,ym.,
m.-.,_,,v,v-.,ym.y-+-._--..r----.-,--,,.,ww.y..-s.
_3_
Designation Description F.
The cask with the skirt attached; this photograph was taken at AGNS.
G.
The cask being lowered into or removed from the Power Station spent fuel pool.
~H.
The cask submerged in the Power Station spent fuel pool-with the lid still on.
I.
The cask in the Power Station decontami-nation area with the template attached.
J.
The cask with the vacuum drying attach-ment affixed; this photograph was taken at AGNS.
K.
The cask being prepared for shipment i
from a Power Station.
L.
A close look at the cask lid.
4 L
4 2
4 I
329 "Sim 2-6 j
~ DIRECT EXAMINATION (resumed) 2 BY MR. MAUPIN:
~
3 Q
Mr. Jefferson, would you summarize your 4
.prefiled testimony for the Board, please, sir?
5 A
(Witness Jefferson)
Yes, sir.
Must of the 6
beginning portion of my testimony is similar to that already 7
given concerning the description of the cask by Mr. McCreery 8
and some of the photos contained in Mr. Smith's testimony.
9 So I won' t cover that.
I will concentrate on that portion of 10 my testimony that deals with sabotage and emerg' ncy response.
e 11 First of all, in evaluating the threat of 12 sabotage, the likelihood of an attempt to sabotage a spent 13 fuel cask is considered to be low for several reasons.
14 First of all, there is a physical protection plan 15 in effect for all shipments required by the NRC and subscribed 16 to by Virginia Power that is intended to discourage such an 17 attack.
18 The plan includes procedures for coping with the 19 threat, instructions to those involved in the shipment on how 20 to recognize a threat.
It involves communications systems 21 of various types, it includes prior arrangements with local 22 law enforcement agencies and requires trained escorts.
23 Secondly, the cask itself is not an easy target.
~
24 It is a very massive system which is difficult for someone Ace 4edecol lleporters, lac.
25 without the proper equipment to handle or move and, secondly,
330 Sim 2-7 it is very resistant to attack itse'lf.
j 2
. Finally, the cask presents a formidable obstacle
~
3 to the saboteur in that a successful attack could easily 1
4 involve exposure of the saboteur as well, and therefore it 5
becomes somewhat less desirable 'as a target.
6 In any sort of sabotage or terrorist activity, 7
one of the important considerations in evaluating ahead of 8
time the likelihood of that event taking place is the times involved.
The longer the time involved for the saboteur 9
10 or the terrorist, the most likely his interdiction and the n
more likely he is to break off his contact and his attempt 12 before it is completed, and therefore the lower the probability 13 f success.
14 And then, finally, the cask is not an attractive 15 target because the consequences that can be produced are 16 certainly lower than the consequences that could be produced 17 on other more accessible and easier to attack targets.
18 If you look at the objective of the individual 19 involved, there are basically three possible objectives.
One i
20 of those and one that is very popular with the press is 21 to divert the nuclear material contained inside to clandestine 22 uses, and most frequently that is assumed to be utilization 23 of the plutonium contained in the fuel element to preduce 24 some sort of nuclear weapon.
A r.d I h p.,,m. inc.
25
-m m
1-Wal 331 1
That simply is not a viable objective, because 2
.the use of that plutonium would require reprocessing the fuel 3
.and that is hardly an activity that is accomplishable on a
=
4 sub-national basis.
5 The saboteur might want to attack the shipment 6
for.a political statement, if you will, simply to show that' 7
1it can be done or to prove that in his opinion this is unsafe, g
and.if you look at the history of sabotage and terrorism in 9
this country you would come to the conclusion that if such a 10 statement is going to be made, it would be made on the basis 11 of harassment rather than intentional damage to the cask and f
12
.erposure to the public because he loses public sympathy when j
- i 13 he exposes the public.
14 If, in fact, though the third possibility was 15 his intent and that is harm to the public, you have a different 16 set of circumstances and that is the basis upon which the 17 protective systems in place have been founded.
I 18 There are basically two ways to attack the cask 19 with intent to harm the public.
You can attack the cask l
20 essentially in place.
In other words, a hit and run attack i
21 while the cask is mounted on its trailer and still on the f
22 highway, in which case you simply approach the cask rapidly, 23 place explosives, and depart and detonate or try to attack it 24 from some distance, and the second methodology would be to
,assenweino ww i,sne.
25 hijack the cask so that it is in your possession, and you i
3-2-WQ1 332 1
hopefully can gain enough time to do a more competent attack 2
scenario.
3 Again, when you get to the hijack scenario, time 4
becomes an important factor and this is an object which is 5
difficult to hide because it can be found even before you open 6
the cask by sophisticated instrumentation mounted on aircraft 7
whi h are available.
l 8g Still, the question comes what if an attack was f
l 9
mounted and was successful, what sort of consequences could 1
10 you create and I think in order to evaluate that you have to g
11 look at basically three different methodologies for attacking n
the cask.
l l
6 One is to, hijack it and to mechanically disassemble!
it and remove the fuel element.
This is a very difficult 15 Procedure, not the least difficulty is removing the head itself; le which weighs nearly a ton, and is designed to be removed in a 17 vertical position, and not a horizontal, so the saboteur would 18 li have difficult time removing the head;even with proper equipment t
that removal takes several hours, and without proper equipment a
20 it could easily take a day or so.
21 Secondly, he has got to grapple for a fuel element i
22 down inside the cask in a blind fashion, because he cannot l
l l
23 l stick his head in there to see without over-exposing himself, i
b 24 and even the process of sticking your arm in there is something Ace Federal Reporters, Inc.
25 of a frightening situation, because at those kind of radiation
3-3-Wal 333 1
levels the ionization -- the skin ionization would cause all 2
the hair to stand up and it gives you a tingling sensation.
3 So, nonetheless, he has got to grapple for the 4
fuel element in order to grab hold of it, and then once he 5
does get hold of it, you have got a fifteen hundred pound 6
object which is not going to slide very easily and so it takes 7 h a good deal of motive power to pull it loose.
'l 8
He is involved in a very dangerous operation.
l i
9l The radiation dose to the saboteur could easily be fatal, and i
10 N it has not been the history of terrorists in this country to 11 launch kamakazi attacks.
I i
I:
And then, thirdly, that particular approach is l
i
's very time consuming, which gives you plenty of time for I
interdiction.
I 15 A second method of attack would be to use projectiles
!6 We have looked at -- that is to say Sandia -- when I was there,;
17 looked at a number of these kind of projecticles, including t
18 high powered rifles an'd armor piercing devices that could be j
19 fired from hand-held devices.
Those do not appear to be 20 particularly useful.
i 21 Bullet-type projectiles simply don' t penetrate the 22 cask at all.
We have looked at light anti-tank weapons, and I
i 23 ll there are two problems with those, not the least of which is --
n 24 these are shoulder-launched projectiles.
Am rec.i nmomes. im.
j 25 Probably the most significant deterrent to the i
l
3-4-W21 334 I
effective use of those is aiming it.
-2 People who are not used to using these kind of 3
weapons generally can't hit the broad side of a barn I think 1
l
-4 the-term goes, much less a cask.
5 But even if you do hit the cask, the penetration 6
capability of these small-devices is limited.
7 The third approach that we have looked at when I I
8 i was at Sandia was the use of explosives.
That is one group 9
of a wide range of attack methods that we looked at, and we 10 finally settled upon conical shaped charge as being the most 11 - e ffective.
It is the same device that the NRC has settled on, l
+
as their most effective attack methodology.
j 1
z 13 Originally, when we looked at this attack method I
4
'l we estimated that you might be able to release as much as one 15 percent of the cask contents in restorable form.
In a series l
16 ' of tests conducted by Sandia, and in parallel or semi-parallel 17
. tests conducted by Batta11e Laboratories in Columbus, Ohio, the i
18 { conclusion was that you would release much less than this, and {
I 17 in fact, for the TN8 cask, the release fraction would be
[
20
.about two one-thousandths of one percent.
21 The consequences under those criteria would be 22 that there would be no detectable health offacts in the l
23 Commonwealth of Virginia, even if you were to successfully j
i 24 sabotage one of these casks, and poke a hole in it with a l
' Ase-Federal Reporters, Inc.
i 25 shaped charge.
. - - -.. - ~.
3-5-WO1-8 335 1
Again, still the question remains:
What if?
2 What if you were to be able to release this 3
material somehow, what sort of emergency response capability 4
do you have, and I think it is impor' tant to understand that 5
-- how emergency response is undertaken, and I have considerable 6
experience in evaluating emergency response capability in 7
several of the states of this country.
8 The emergency response is carried on in basically 9
three phases.
The first phase is the initial response, and 10,
the kind of thing that Mr. Smith talked about a minute ago 11 ' would constitute the original response, and in almost all cases,
i C
that involves a local law enforcement agency or a local fire f
13 department.
"a These first responders have basically three things 35 that they are asked to consider to do.
First of all, they 16 should isolate the accident through the use of crowd control i
17 in the case of an accident of the kind, or a sabotage of the 18 g kind we have been talking about, that would mean evacuating i
O people back to a distance of about six to eight hundred ' feet, 20 ;
and in my experience, most of the time they will evacuate about ;
21 a mile, so they way over-respond in that regard.
j i
22 Secondly, they are to notify others of the accident.!
l In almost every case, the responder will notify his dispatcher. I 23 24 The dispatcher then has available to him a number of services wesem n
,. anc.
25 for gaining other information.
L
4 13 6-w21:
336 1
'One of these is a commercial organization called 2
Cheatrek.
It is an 800 number that is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day 3
by the Chemical Manufacturers Association.
If a radiological 4
- accident is reported to them, they will notify a number of 5
People, including the Joint ~ Nuclear Accident Coordinating 6
Center.
There is one of those centers in Washington.
There 7, _also one of those centers in Albuquerque, New Mexico, and they 8.
have heavy response capabilities.
9 They, in turn, or Chemtrek would notify the 10 Interagency Radiological Assistance Program, who could also giv 11 J advice to the responder.
1 The third thing that initial responder can do
- s if he so desires is to attempt to rescue life, but he does so f
l on a voluntary basis.
The second level of response is a iI' 13 stabilization phase, where knowledgeable people are collected 16 at the site to evaluate the accident or the incident, and to I
.?
develop appropriate measures to stabilize the thing and to get i
18 p it -- keep it from progressing any further.
{
17 There is lots of help available here.
As I 20 mentioned before, there are several Federal response j
21 capabilities there, and there is a good deal of local response i
22 capability.
Almost -- well, in fact, every hospital accredited 23 by the American Hospital Association must have a nuclear medicine 24 department, and those people must have health physicists, and Ass-Federal Reporters, Inc.
25 they must be equipped with proper radiation detection
- 3-7-W21 337 1
instrumentation, so any hospital could provide assistance.
2 In the commonwealth of Virginia, there are a number of 3
universities.that have reactors and nuclear engineering 4
programs.
They can provide assistance and then the 5
Commonwealth's emergency government, or emergency response 6_
capabilities also have those.
l End 3.
7 !.
-Suet fols.
j 8 'i 9
10 ll n
i' i
I
- 2 l
I
'o i
l
- r l
18 !,
i' 87 20 (
I 21 l j
22 0
23.>
'l 24 Am-FeewW Roonm. Inc.
25
_ -. _ _ - ~ - - _ _, -
338 44-1-Suet 1 The third phrase of a response to an accident, 2
or an emergency response, would be the cleanup phase.
And 3
that's handled by commercial organizations who specialize 4
in that kind of activity.
5 As I indicated before, I looked at a number of 6
these capabilities throuchout the country.
I have been 7
instrumental in developing the emergency response programs 8
for two states.
And I find that there is a uniform high 9
degree of competency at all levels throughout.
10 The conclusion that I draw from this is that the --
t 11 first of all, the likelihood of attack is quite small.
12 Secondly, given that there is an attack mounted the likeli-4 13 hood of its success is quite small.
And, thirdly, given 14 that it is successful the consequences are minimal.
- And, J
15 fin' ally, that if there are consequences we have in place 16 effective emergency response capabilities.
17 The sum and substance that I draw from that is 18 that the public health risk to the citizens of the Common-19 wealth of Virginia are minimal.
20 Q
Mr. Smith, your testimony is very brief.
Nould i
21 you give an even briefer summary of the gist of it?
22 A
(Witness Smith)
Yes.
The testimony consists 23 of a description of the photographs, that the circumstances i
24 under which they were taken for the photographs that have
. m hp veers, :=.
25 been entered into evidence previously, as well as a discussion i
i w
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339
- 4-2-Suet j
of the fact that we, Virginia Power, will have in place and 2
thus comply with 10 CFR Part 73 as far as a physical pro-3 tection system requirements for transport of spent fuel 4
between Surry and North Anna.
5 MR. MAUPIN:
Mr. Chairman, that completes the 6
direct testimony of these witnesses.
7 JUDGE WOLFE:
Cross, Mr. Doughterty?
8 MR. DOUGHERTY:
I have no questions, Judge.
9 JUDGE WOLFE:
Mr. McGurren?
10 MR. MC GURREN:
The Staf f has no questions, Your 11 Honor.
12 JUDGE WOLFE:
All right.
13
.TUDGE FERGUSON:
Just very briefly, Mr. Jefferson..
14 You kept referring to the fact, when you were at Sandia.
15 What is your current employment?
16 WITNESS JEFFERSON:
I'm currently a private 17 consultant.
18 JUDGE FERGUSON:
Thank you.
That's all that I 19 have.
20 JUDGE WOLFE All right.
Absent anything more, 21 the witnesses are excused.
22 WITNESS JEFFERSON:
Thank you, Your Honor.
23 JUDGE WOLFE Permanently, Mr. Maupin?
24 MR. MAUPIN:
I'm sorry?
AceFederal Reporters, Inc.
25 JUDGE WOLFF Permanently excused?
340
- 4-3-Suet I MR. MAUPIN:
Yes, sir, as far as I'm concerned.
2 (The witnesses stood aside.)
3 MR. MAUPIN:
That completes the Licensee's case.
4 JUDGE WOLFE:
Mr. McGurren.
5 MR. MC GURREN:
Yes, Your Honor.
The Staff is 6
ready to proceed.
7 The Staff calls to the stand William R. Lahs, Jr.,
8 Carl B. Sawyer, William H. Lake, John P. Roberts, Donald P.
9 Cleary, Justin T. Long and Leon B. Engle.
10 JUDGE WOLFE:
It would be much easier for the II Board for identification purposes, I guess for counsel as 12 well, if you, Mr. McGurren, would have them be seated as 13 they are listed in their --
14 MR. MC GURREN:
What I have done, Your Honor, 15 for the benefit of the Board and the parties, as well as 16 the audience, I have asked each to prepare --
17 JUDGE WOLFE You anticipated.
18 MR. MC GURREN:
-- nameplates.
19 JUDGE WOLFE:
All right.
Would each of you rise, 20 please?
21 (The witnesses are sworn by Judoe Wolfe.)
22 Whereupon, 23 WILLIAM R. LAHS, JR.,
24 CARL B. SAWYER, Ace Federal Reporters, Inc.
25 WILLIAM H. LAKE,
- 4-4-Suet 341 1
JOHN P. ROBERTS, 2
DONALD P. CLEARY, 3
JUSTIN T. LONG 4
and
.5 LEON B. ENGLE 6
were called as witnesses by and on behalf of the Nuclear 7
Regulatory Commission Staff and, having first been d l uy 8
sworn, were examined and testified as follows:
9 DIRECT EXAMINATION 10 BY MR. MC GURREN:
11 Q
I am going to address the initial questions to 12 the panel and if you would each respond in turn as I a k s
the 13 ques tions.
14 My first question is, do you have before you a 15 document entitled "NRC Staff Testimony of William R. Lahs, 16 Jr., Ca rl B. Sawyer, William H. Lake, John P. Roberts, 17 Donald P. Cleary, Justin T. Long and Leon B. Engle Regarding 18 CCLC's Consolidated Contention 17" 19 A
(Witness Lahs)
Yes.
20 (Witness Sawyer)
Yes.
21 (Witness Lake)
Yes.
22 (Witness Roberts)
Yes.
23 (Witness Cleary)
Yes.
24 Ace Federal Reporters, lac.
(Witness Long)
Yes.
25 (Witness Engle)
Yes.
L
342 94-5-Suet j
Q Was this document prepared by you?
2 A
(Witness Lahs)
Yes.
3 (Witness Sawyer)
Yes.
- 4 (Witness. Lake) Yes.
5 (Witness Roberts)
Yes.
6 (Witness cleary)
Yes.
7 (Witness Long)
Yes.
3 (Witness Engle)
Yes.
Q And at this point I'm going to ask you, do you have any additions or corrections to this document?
10 11 A
(Witness Lahs)
Yes, I do.
12 Q
Would you please state what those corrections j3 are?
14 A-Yes.
There are two corrections.
The first 15 appears on Pace 8, the seccnd line.
There is a footncte to 14 a ' Reference 2.
If you could move that footnote to Page 7, j7 the previous sentence.
18 The reason is that that particular referenca discussions motivations of adversaries rather than the --
19 a listing of the bomb threats, vandalism, et catera.
20 That 21 is in the sentence on Page 8.
22 O
So I take it that. footnote would then follow the 23 word " shipment" on Page 7, the second line from the 24 bottom?
Amededwel neposeri, saa.
25 A
That's correct.
343
- 4-6-Suet 1
0 Do you have another correct?
2 A
Yes.
The second correction is on Page 15, and 3
it's a spelling error.
The last word on tho' page, " fatalities 4
And that's it.
5 Q
Are those the only corrections?
e A
Yes.
7 Q
As corrected, is this document true and correct 8
to the best of your knowledge?
9 A
(Witness Lahs)
Yes.
10 (Witness Sawyer)
Yes.
11 (Witness Lake)
Yes.
12 (Witness Roberts)
Yes.
13 (Witness Cleary)
Yes.
14 (Witness Long)
Yes.
15 (Witness Engle)
Yes.
le O
Do you adopt this document as your testimony --
17 oh, I'm sorry.
John.
18 A
(Witness Roberts)
Just one minor correction 19 on Page 22.
About the middle of the page, " Questions and 20 answers have been docketed and made available..." the 21 "and" has a "d" missina.
22 Q
John, could you speak up again?
I didn't hear 23 you.
24 A
e nJ %. sw.
ch, I'm sorry.
On Page 22 about the middle of
~
25 the page, the sentence starting, " Questions and answers
344
- 4-7-Suet I
"have been docketed and made available
" there is a "d"
2 missing from the "and."
3 Q
All right.
Thank you.
Are those the only 4
corrections?
5 A
Yes.
6 Q
As corrected, is this document true and corre t 7
c to the best of your knowledge?
8 A
(Witness Lahs)
Yes.
9 (Witness Sawyer)
Yes.
10 (Witness Lake)
Yes.
11 (Witness Roberts)
Yes.
12 (Witness cleary)
Yes.
13 (Witness Long)
Yes.
14 (Witness Engle)
It is.
15 Q
Do you adopt this document as your testimony in 16 this proceeding?
17 A
(Witness Lahs)
Yes.
18 (Witness Sawyer)
Yes.
19 (Witness Lake)
Yes.
20 (Witness Roberts)
Yes.
21 (Witness cleary)
Yes.
22 (uitness Long)
Yes.
23 (Witness Engle)
I do.
24 wrederat neponen, nn.
MR. MC GURREN Your lionor, at this time I 25 requent that this document entitled "NRC Staff Testimony of u
^
~
345
- 4-8-Suet
" William R. Lahs, Jr., Carl B. Sawyer, William H j
. Lake, John Roberts, Donald P. Cleary, Justin T. Long and Leo 2
n B.
Engle Regarding CCLC's Consolidated Contention 1" -which 3
consists of 27 pages of testimony and the professional qualification 4
of each of the witnesses be received in evidence 5
into the record as if read.
6 7
JUDGE WOLFE:
Have you substituted the pages that 8
were corrected earlier, those substituted pages now as a 9
part of this direct testimony?
10 MR. MC GURREN:
Your Honor, let me iust make 11 clear.
On May 15th,, Your Honor, I sent a covering letter 12 to the Board as well as to the parties with four listed items that concern changes.
13 14 The changes reflected in that letter of May 15th 15 are the corrections that have been made but for the thr 16 changes indicated by the panel this morning.
17 JUDGE WOLFE:
Nould you say that again now?
18 On May 15th you sent us a letter with four pages, corrected 19 pages of the transcript.
20 And my question to you was, have those been incorporated into that which is now being offered as the 21 22 witnesses' testimony?
23 MR. MC GURREN:
Yes, they have, Your Honor.
24 Ace 4ederal Reporters, int JUDGE NOLDE:
Any objections?
25 MR. DOUGHERTY:
No objection.
o
- 4-9-Sue T I
346 MR. MAUPIN:
No, sir.
2 JUDGE WOLFE:
All right.
The testimony of the --
3 the written direct testimony of Messrs
. Lahs, Sawyer, Lake, 4
Roberts, Cleary, Long, and Engle is -- this testimony is 5
incorporated into the record as if read 6
(The direct testimony follows.)-
INDEXXX 7
8 9
10 11 12 13 14 15 16 17 18 19 20 22 23 4
24 5 - 2_.: n.por,,f 1,,e.
25 i
?
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of VIRGINIA ELECTRIC & POWER COMPANY Docket Nos. 50-338 OLA-1 50-339 OLA-1 (North Anna Nuclear Power Station, )
Units 1 and 2)
)
(Receipt of Spent Fuel)
NRC STAFF TESTIMONY OF' WILLIAM R. LAHS, JR.,
CARL B. SAWYER, WILLIAM H. LAKE, JOHN P.. ROBERTS, DONALD P. CLEARY, JUSTIN T. LONG AND LEON B. ENGLE REGARDING CCLC'S CONSOLIDATED CONTENTION 1 Q1._ Mr. Lahs, please state your name, affiliation and position.
A1. My name is William'R. Labs, Jr.
I am a senior project manager and nuclear engineer in the Office of Nuclear Regulatory Research at the Nuclear Regulatory Commission.
l I
Q2. Have you prepared a statement of your profess,ional qualifications?
A2. ies. A statement of my professional qualifications is attached to this testimony.
Q3. Mr. Sawyer, please state your name, affiliation and position.
A3. My name is Carl B. Sawyer.
I am a senior safeguards analyst in the bffice of Nuclear Material Safety and Safeguards at the Nuclear Regulatory Comission.
Q4. Have you prepared a statement of your professional qualifications?
A4.
Yes. A statement of my professional qualifications is attached to this testimony.
QS. Mr. Lake, would you please state your name, affiliation and position.
AS..My name is William H. Lake.
I am a mechanical engineer with a spe-cialty in heat transfer, and I am with the Transportation Certifi-cation Branch of the Office of Nuclear Material Safety and Safeguards at the Nuclear Regulatory Commission.,
Q6.
Have you prepared a.. statement of your professional qualifications?
A6. Yes. A statement of my professional qualifications is attached to this testimony.
Q7. Mr. Roberts, would you please state your name,' affiliation and
' position.
A7. My name is John P. Roberts.
I am Group Leader for Spent Fuel Stor-age Installation in the advanced Fuel and Spent Fuel Licensing Branch in the Division of Fuel Cycle and Material Safety in the Office of Nucl' ear Material Safety and Safeguards, United States Nuclear Regulatory Commission.
Q8. Have you prepared a copy of your professional qualifications?
A8. Yes. A copy of my professional qualifications is attached to this testimony.-
i 1
Q9. Mr. Cleary, please state your name, affiliation and position.
~
A9. My name is Don Cleary.
I am Acting Chief of the Site Analysis Branch and Section Leader of-the Regional Impact Analysis Section within the Site Analysis Branch.
The Site Analysis Branch is in the Division of Engineering, Office of Nuclear Reactor Regulation, Unit-ed States Nuclear Regulatory Commission.
Q10. Have you prepared a copy of your professional qualifications?
A10. Yes. Acopyofmyprofessionalqualificationsis,attachedtothis testimony.
Q11. Mr. Long, please state your name, affiliation, position and role in the preparation of the NRC Staff's Environmental Assessment Related to Increasing the Spent Fuel Storage Capacity and the Storage of' Surry Spent Fuel at the North Anna Power Station, Units No.1
- and No. 2.
All. My name is Justin T. Long.
I am a Senior Chemical Engineer in the Office of Nuclear Material Safety and Safeguards at the Nuclear Regulatory Commission.
I prepared that portion of the Environmental -
Assessment that related to the transshipment of spent fuel from the Surry Station to the North Anna Station.
I also prepared that por-tion of the Safety Evaluation Report that related to the transship-ment of spent fuel from the Surry 3tation to the North Anna Station (Sections 3 and 4).
vv
a,
012. Have you prepared a copy of your professional qualifications?
j A12. Yes. A copy of my professional qualifications is attached to this I
testimony.
Q13. Mr. Engle, please state your name, affiliation, position and role in the preparation of the NRC Staff's Environmental Assessment Related to Increasing the Spent Fuel Storage Capacity and the Storage of Surry Spent Fuel at the North Anna Power Station, Units No. I and No. 2.
A13. My name is Leon B.,Engle.
I am an Operating Reactor Project Manager in Operating Reactors Branch No. 3, Division of Licensing, Office of Nuclear. Reactor Regulation, United States Nuclear Regulatory Commis-sion. As project manager for the North Anna Power Station.
Units No. I and No. 2, I coordinated the NRC staff ir.put and pre-
- pared the final Environmental Assessment Related to Spent Fuel Stor-age capacity and the Storage of Surry Spent Fuel at the North Anna Power Station, Units No. 1 and No. 2 as well as the NRC Staff's Safety Evaluation on that proposal.
Q14. Have you prepared a copy of your professional qualifications?
A14. Yes.
A' copy of my professional qualifications is attached to this testimony.
Q15. Gentlemen, what is the purpose of this testimony?
__,y,
-y
A15. The purpose of this testimony is to address CCLC's Consolidated Contention 1 which reads as follows.
~
The Staff's Environmental Assessment is-inadequate and an Environmental Impact Statement should be prepared.
The bases for this contention are two-fold. First, the Environmental Assessment, did not evaluate the probabil-ity and consequences of accidents occurring during the transportation of spent fuel casks from the Surry Sta-i tion to the North Anna Station which might be occasioned by acts of sabotage or by error of Applicant's employees in preparing the casks for shipment. Second, contrary to the National Environmental Policy Act, 42 U.S.C.
4332(2)(E), consideration Was not given to the alterna-tive method of constructing a dry cask storage facility at the Surry Station which is feasible, can.'be effected in a timely manner, is the least expensive and safest method for at least 50 years, and can be used on or offsite.
The 3 aspects of th'is contention relating to sabotage, employee error and the alternative of constructing a dry cask storage at Surry are each addressed below.
Sabotage Q16. Could you' identify the factors the Staff considers in assessing the probability and consequences of potential acts of sabotage against a spent fuel shipping cask?
A16. The factors the Staff considers in assessing the probability and 4
consequences of potential acts of sabotage against a spent. fuel shipping cask include:
(1) the massive and durable structure of the cask, (2) an assessment of the threat to spent fuel shipments, (3) the physical protection provided for licensed spent fuel ship-ments, (4) the effects of postulated acts of sabotage on a spent
fuel cask, and (5) the consequences of postulated successful acts of sabotage. Successful sabotage when referred to in this test'imony is defined as a breach of a cask and a discharge of a portion of its spent fuel contents into the environment.
(WRL,CBS)
Q17. How are each of these factors considered by the Staff to determine the significance of the environmental impacts resulting from poten-
'tial acts of sabotage?
A17.~We will address each factor sequentially.
I.
Spent Fuel Cask Spent fuel assemblies removed from light water power reactors, such as those at the Surry Station, contain low enriched uranium, fission and activation products, plutonium and other transuranics. The spent fuel is highly radioactive and requires heavy shielding for safe handling.
During transport, the needed shielding is provided by a massive. durable cask. Typical truck casks weigh from 25 to 40 tons. The cask proposed for the Surry to North Anna shipments, the Transnuclear TN8L, weighs approximately 40 tons. All casks must meet Department of Transportation (DOT) requirements set forth in 49 C.F.R. Parts 171-178 and Nuclear Regulatory Commission (NRC) requirements for fissile material packages and Type B packages set forth in 10 C.F.R. Part 71.
The external shape of the TN8L cask' approximates a right circular cylinder (5.5 meters long and from 1.0 to 1.7 meters in diameter).
1.
From the inside-out, the cask includes an inner 6mm thick sthinless steel shell, a minimum 135mm thick lead gamma shield, a 10rni wet cement layer, a 20mm thick carbon steel outer shell, and a 150mm thick resin neutron shield transversed by radial copper cooling fins. The lid is a weldment of stainless steel plates containing 145mm of lead and 21mm'of resin. The lid weight is 850Kg or almost 1 ton. At each extremity, attached to the outer shell, is an impact limiter consisting of a circular stainless steel ring structure with internal radial gussets and filled with balsa wood.(10),
The structural featyres (e.g., multiplicity of steel shells, and thick, dense radiation shields), enable the cask to withstand accident-like events caused by sabotage and attack by small arms or conventional explosives.
Studies have indicated that it will re-quire skillful use of explosives by persons with knowledge of both
' explosives and shipping cask design parameters to potentially achieve a release of radioactive material.II)
II. Threat to Spent Fuel Shipments During the past several years, the NRC has conducted a number of studies to develop information about possible adversary groups who might pose a threat to nuclear transportation activities, including spent fuel shipments. Actions directed against domestic nuclear transportation were found to be limited to a number of activities
- The number in parenthesis refers to references set forth at the end of the testimony.
E,
and harassments such as hoax bomb threats, vandalism, radio '
pharmaceutical thefts, and fireann discharges.(2) No actiori directed against a spent fuel cask has affected the integrity of the cask, and therefore none has caused any radiological health hazard.
In addition, the Staff regularly consults with law enforce-ment agencies and intelligence gathering agencies to obtain their views concerning the possible existence of adversary groups inter-ested in sabotage of nuclear activities. None of the information the Staff has collected confirms the presence of.,an identifiable threat to domestic spent fuel shipments.
III. Protection of Spent Fuel Shipment In May of 1978, a draft study (3) predicted that serious radiologi-cal consequences could not be ruled out in the event of successful explosive sabotage of a spent fuel shipment in a highly populated 4
5
- - urban area (6 x 10 - 1.9 x 10 people / square mile - New York City).
In response to this study, the Comission issued interim regulations (sg 44 Federal Register 34466, June 15,1979 and 45 Federal Regis-ter 37399, June 3, 1980) which significantly strengthened the physi cal' protection provided for licensed spent fuel shipments (10 C.F.R 5 73.37). Currently these regulations include:
i routes to be approved by the NRC;
~
'the use of an armed escort, in instances where heavily populated
~
areas are transited;
prior arrangement for response from police forces along"the route in the event of need; equipping of transport vehicles with radio-telephones, CB radi-os, and immobilization features (for truck shipments);
the use 'of escorts capable of carrying out the physical protec-tion requirements en route; non-stop shipments where possible and special precautions if stops are nece.ssary; the development of response procedures for coping with safe-guards emergencies; and an NRC and a State official to be notified in advance of spent fuel. shipments.
Since little information was available to aid in predicting the release quantities associated with explosive sabotage of spent fuel, the consequence calculations presented in the May 1978 draft study
-were subject to large uncertainty. Specifically, the radiological consequence from an airborne release would be strongly affected by the quantity of spent fuel released in respirable form.
Respirable material is that portion of aerosolized material that can be inhaled and retained in the lung. The NRC and Department of Energy (DOE)
P responded to the need for technical data by sponsoring separate but coordinated experimental programs. The NRC, therefore, made clear by explicit statement in the June 15, 1979 Federal Register notice (44 FR 34466) that the protection requirements for spent fuel ship-ments were intended as an interim set of measures which would be reviewed when results of the research became available. The re-search has now been completed and is subsequently discussed.
4 IV.. Effect of Sabotage on Spent Fuel Shipments At present, there is no identified domestic threat against spent fuel shipping casks. Over the last several years, however, the effect of sabotage on shipping casks and their spent fuel contents has been studied for a wide range of sabotage scenarios.
Sabotage scenarios are grouped into three categories:
(i) sabotage through mechanical means.(e.l., removing cask lid) or deliberate j
" accident-like" means (causing a transport vehicle accident);
(ii) sabotage through the use of projectiles; and (iii) sabotage i
through the use of explosives. Again, successful sabotage when referred to in this testimony would involve breaching the cask in a manner that could discharge a portion of the radioactive contents into the environment.
(1) Sabotage By Mechanical Breaching of Cask Containment Deliberate acts directed at mecha'nical breaching of the cask would not be likely to create a significant release of spent
11 -
fuel due to the structural integrity of cask designs and the difficulties associated with mechanical disassembly. Over the last several years, a number of impact tests have been conduct-ed in the United States and the United Kingdom which have con-firmed the ruggedness and containment and shield integrity of spent fuel shipping casks when subjected to extremely severe accidentenvironments.(4)(5)(6)(7) 4 Removal of the cask cover such as the TN8L c,over would be both I
difficult and dangerous. The TN8L cover weighs almost one ton and, in practice, is removed with the aid of a crane. The removal operation is performed with the entire cask underwater to provide shielding from radiation.
In the absence of shield-iny, the radiation emanating from the open end of the cask would be lethal to anyone subjected to it.
Breaching of the cask cavity with use of power tools, burn bars or similar types of equipment also would be difficult and dan-gerous.
If sections of the gamma shielding were removed, the radiation field at working distances would probably be lethal.
(ii) Sabotage By Use of Projectiles Deliberate use of fireanns directed at breaching of the cask to release significant radiation, in almost all cases, would not be successful due to cask design. Most small firearns would cause no functional damage to the cask. High power rifle and i
~
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~.- -
e, n,-,-.----,an----
w, n.
.--,--,--.m c--,-
w -
1
. machine gun projectiles could penetrate the resin shiel'd on the TN8L cask or the outer water jacket on other cask designs.
However, the cask's steel shells and heavy th1ck shield would enable the cask to withstand any containment penetration.
(iii) Sabotage Explosives After considering the various technical approaches to sabotage,-
the NRC concluded that sabotage, to be successful, would have to be carried out with the aid of explosives. Accordingly, the NRC considered a range of adversary scenarios with a view to-ward determining the kinds, quantities, and placement of explo-sive charges that could conceivably result in successful sabotage. The factors considered included (1) the number of adversaries; (2) the adversary capabilities; (3) the avail-ability of various kinds and quantities of explosives; and
'(4) the explosive threats used in historic actions and credible hoaxes.
Explosive configurations considered included airblast and platter, bree-hing, and shaped charges.(1) As a result of its deliberations, the NRC further concluded that:
Release of spent fuel by sabotage of a cask would require skillful use of explosives.
Large amounts of explosives (tens or hundreds of pounds) would be needed in most scenarios considered.
f.
A saboteur interested in most effective use of explosives or larger releases would need to gain control of a' shipment.
Pound for pound, shaped charges would be more effective 9
than the other configurations.
Small shaped charges 6r sophisticated antitank weapons could penetrate a cask but the hole pro,duced and the sub-sequent release would be smaller than for the case of a large, manually placed shaped charge.
As a result, adversary scenarios were specified with major emphasis on the use of the U.S. Army M3Al shaped charge shich weighs 40 p6unds and is the largest shaped charge widely available in military arsenals.
(v) Consequence of Successful Sabotage Although no specific sabotage threat against a spent fuel cask has been identified, and although an extensive and skillful effort is required to cause any dispersal of radioactive mate-rials, the consequences of carrying out reference basis explo-sive sabotage have been calculated.(1) The calculation begins with the assumption that sabotage is attempted and is success-ful. The consequences then depend upon a number of factors, including the population density, the amount of radioactive
.' material released, the amount of released material that'is in respirable form, and the meteorological conditions.
Prior to-the availability of experimental information, several consequence studies had been performed in which, based on engi-neering judgment, radioactive material release fractions were assigned either conservative values or wide ranges of values to reflect the uncertainties involved. As has been mentioned, NRC's interim requirements for the protection of spent fuel shipments against sabotage, put into effect in 1979, were prompted by a draft Sandia s,tudy(3) which estimated that the successful explo-sive sabotage of a spent fuel shipment in a highly populated area (New York City) had the potential for producing serious I'
radiological cons'equences.
In that study, estimates of' respirable release ranged up to 14,000 grams for a truck shipment and potential health conseque'nces were summarized as tens of early fatalities and hundreds of latent cancer fatalities.
Experimental data to support estimates of the magnitude and the -
chemical and the physical form of radioactive material release from a presumed successful sabotage event is now available from two research programs. One of these programs was performed by I8)
Battelle Columbus Laboratories for the NRC The other was performed by the Sandia National Laboratories for the Department of Energy (DOE).I9) The research programs included a series of tests that used explosives against simulated casks containing either
irradiated fuel or unirradiated surrogate fuel and against a real cask containing unirradiated surrogate fuel. Tests from the NRC-sponsored program showed that for perfectly executed sabot [ age of a three-assembly truck cask, the likely release of respirable-particles would be less han 18 grams; tests from the DOE-sponsored' program showed the likely release to be less than 34 grams. These release figures are judged by NRC to be high because they were obtained under controlled experimental conditions (absence of water jackets or wet materials and iso-lation of released radioactive material from explorion debris)
- that make the. measured experimental respirable release higher than it would be under noncontrolled conditions.
Despite the level of conservatism, the experimentally obtained value's were much lower than previous release estimates which ranged up to 14,000 grams of respirable particles.
The calculated health consequences from inhalation of radioactive material are corre-spondingly reduced. According to the results of the NRC-sponsored program (18 gram release), the average radiolog-ical health consequences in a highly populated area such as New -
-York City can be characterized as no early fatalities and slightly less than one latent cancer fatality. According to the results of the DOE-sponsored program (which indicated a 34 gram release, and used a different consequence code), the average radiological health consequences in a highly populated area such as New York City can be characterized as no early fatalities and an average of about 4 latent cancer fataliies.
~
m
... m
Consequence estimates somewhat higher or lower than the average can be obtained depending on the values assigned to various parameters ( M., meteorological assumptions). The peak latent cancer fatalities predicted from the results of these programs are 6 and 14 respectively. This characterization applied for spent fuel cooled for a period of 150 days.
It should be noted that health effects from sabotage of 730 day, cooled fuel (proposed to be shipped fr6m Surry to North Anna) would be less than that from 150 day, cooled fuel. The regulatory result of this more precise characterization of sabotage consequences has led to a rulemaking proceeding proposing moderation of the interim requirements for the protection of spent fuel shipments.
(WRL,CBS) 018. Based on your testimony, what conclusions do you reach regarding
- Consolidated Contention 17 A18. Regarding the part of Contention I which states that the Environmen-tal Assessment,... did not evaluate the [ probability or conse-quences of] acts of sabotage against transportation of spent fuel
~
f casks from the Surry Station to the North Anna Station, we conclude that:
I i
1)
There is an absence of any information confirming an
+
idtntifiable threat to the shipments.
(2) Actions taken to breach a spent fuel shipping cask which could fragment and cause the release of radioactive material would be extremely difficult for any adversary without considerable expertise
~.
.in the skillful use of explosives and detailed knowledge of the shipping cask and its spent fuel contents.
H (3)
Using the most unfavorable results from recent research pro-grams, the magnitude of potential consequences from the release for radioactive material in respirable form as a result of successful sabotage of a shipping (cask through use of specified explosives in a highly populated area New York City) has been estimated in the range of 4-14 latent cancer fatalities.
(4) ~ The protection requirements set forth in 10 C.F.R. I 73.37 add significantly to the already lengthy chain of difficulties a sabo-i teur must overcome in order to successfully sabotage a spent fuel shipment.
The requirements thus provide assurance against levels of explosive sabotage that exceed the reference level and against health consequences that exceed the calculated. levels.
In summary, we conclude that the probability and'* consequences of acts of sabotage against transportation of spent fuel casks from the Surry. Station to th~e North Anna Station are small and have been adequately evaluated. This conclusion is in agreement with the conclusion reached in the Safety Evaluation by the Offices of Nucle-ar Reactor Regulation and Nuclear Material Safety and Safeguards Related to Increasing the Spent Fuel Storage Capacity and the Stor-
- age of Surry Spent Fuel at the North Anna Power Station, Uriits No.1 and No. 2, at p. 4-4.
(WRL,CBS).
Employee Error Q19. What is your position on the employee error aspect of CCLC Consolidated Contention 17 A19. Based on the cask closure design of the Transnuclear, Inc. TN-8L,
- cl6sure procedures, and because safety related activities are to be performed under an NRC approved QA program, I do not think a release 4
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' of radioactive material due to employee error is likely to happen.
(WHL) t' Q20. Do you believe that risk due to human error has been adequately evaluated?
A20. Yes, WASH-1238 presents a generic environmental impact analysis for transportation of radioactive materials that includes consideration of human error. Estimates provided in WASH-1238 indicate that the probable frequency of casks being improperly clbs,ed prior to shipment 5
is very low (i.e., no more than 1 in 10, see Appendix A, p. 72).
I The conclusion presented in WASH-1238 is:
"It is possible that a package will be constructed or used in a manner not in accordance with the design; however, the likelihood of such errors is considered small in view of the regulatory requirements for quality assuranEe and for various observations and tests before each shipment,"
- (Section III, pg. 16).
(WHL)
Q21. Do you agree with the statement of WASH-1238 that you have just cited? And, if so, on what basis?
A21. Yes', the estimated frequency of improper cask closure due to human error as reported in WASH-1238 has been substantiated by the more recent NUREG-0170 (Final Environmental Statement on the Transporta-tion-of Radioactive Material by Air and Other Modes, pg. 4-31).
Also, the NRC regulations for transportation of radioactive materi-als requires that licensees have an NRC approved QA program for transportation before they can ship radioactive material, and the
, c 4
NRC regulations specify requirements for operating controls and procedures to be applied to all packages (see 10 C.F.R. Part 71, subparts H and G, respectively).
(WHL)
Q22.-What closure design features an'd/or closure procedures do you think contribute to making release of contents due to employee error unlikely?
A22. The containment system of the TN-8L has a double 0-ring seal and three penetrations or entry ports into the contai,nment; these three ports are used for filling, draining, venting, and drying. Two of these ports have self closing type check valves, both of these are T'e third entry port is covered with sealed covers before shipment.
h closed by a sealed shield plug before shipment. This third entry port is used for vacuum drying the system as required prior to shipment.
The double 0-ring arrangement for the lid to cask body closure is leak tested by evacuation of the chamber formed between the two concentric seals and monitored for pressure rise.
Any detected leakage requires correction before continuing the closure proce-dures.
Of the three ports, two have redundant closures (one in the lid, the other at the bottom). These ports with redundant closures have at least one closure device that is leak tested. The remaining port (located in the lid and used for vacuum drying) is tested twice, once as part of the cask cavity check, and once using a bell jar to vacuum test the closure from the outside.
In addition, due to the procedures required to dry the cask cavity (a condition of the NRC approval reflected in the Certificate of Compliance, No. 9015 for the TN-8L)._these ports and the lid seals are checked.
These checks are not formal leak checks, but arise from the fact that the. drying process involves low vacuum pressures that are not achievable if gross leakage is present.
(WHL)
Q23. What makes you think that the 16ading procedure will be followed as intended and described?
A23. The general closure and drying procedure specified by Transnuclear Incorporated are called out as conditions of approval in the NRC Certificate of Compliance (No. 9015) for the TN-8L. The procedures followed to prepare the cask for shipment are to be done in accor-dance with an NRC approved QA program.
The utility (VEPCO) is re-sponsible for establishing written procedures.
(WHL)
Q24. Even though these procedures are written down, checked, and carried out under an NRC approved QA program, isn't employee error still possible?
A24. Yes', but as I* testified above with regard to the design and procedures, there is a great deal of redundancy in leakage barriers and in the tests performed on them. Any error would likely either be found by test or negated by a redundant leakage barrier.
Compo-nents or tests or both are redundant along any potential release path.
(WHL) 6
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Q25. What, then, is your conclusion regarding the employee error aspect of CCLC Consolidated Contention I?
A25. As I testified above, risk due to human error in transportation of radioactive materials has been adequately considered and release of radioactive material due to employee error is unlikely, based on the cask design the closure procedures and the use of an NRC approved QA program.
(WHL)
Dry Casks Alternative At Surry
,026. What is your opinion regarding the assertion that "the alternative method of constructing a dry cask storage facility at the Surry Station is feasible, can be effected in a timely manner, is the least expensive and safest method for a least 50 years, and can be used on or offsite"?
A26. As is more fully explained below, we are now in the process of con-ducting our safety review of the dry storage cask topical report that VEPCO proposes to use at a dry cask independent spent fuel storage installation (ISFSI) at its Surry Station site. The VEPCO ISFSI application is still under review as well. Until the review of the associated topical report which VEPC0 expects to reference, and the review of the application itself are complete and Commission approval obtained, I cannot give a definitive answer; I could only speculate.
(JR)
Q27. Can you describe the background and status of the dry cask proposal?
. 1 A27. Yes, in October 1982 Virginia Electric and Power Company (VEPCO) applied for a license to construct and operate a dry cask ISFSI located on the site of the Surry Power Station (by letter to R. E.
Cunningham docketed October 15, 1982 under Docket No. 72-2).
The dry cask design to be used was not specified in the application.
VEPCO chose to await approval of a dry cask design topical report submitted by a vendor. As noted in its letter of application, As these cask reviews are completed by NRC, VEPCO will advise the NRC of plans to purchase and ut.ilize the approved casks.
In a letter dated September 9, 1983, NRC staff provided questions related to the Staff's safety and environmental reviews.
VEPC0 has been providing answers to these questions to the Staff for eventual incorporation in VEPCO's safety analysis report (SAR) and to supple-ment its environmental report (ER). Questions and answers have been docketed and made available to the public at the NRC Public Document Room at 1717 H Street, N.W., Washington, D.C. and the Local Public Document Room for the Surry Station located in the Swemm Library, College of William and Mary, Williamsburg, Virginia.
~.
Subsequently, VEPC0 in a letter dated March 15, 1984 informed the NRC of its selection of the GNS Castor V type cask as the first to be considered for evaluation. VEPCO requested this cask design topical report be given priority in completion of our safety review.
(JR) f
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3
4 _ Q28.'When will the Staff's review of the proposal be completed?
A28. Assuming timely submittal of a complete topical report, its. safety a
review could be finished in the spring of 1985.
If the integration of the topical report by reference into the VEPCO safety analysis report proceeds in parallel with the topical report review, the Staff's safety review of VEPCO's application could be completed in the summer of 1985. The Staff's environmental review of the appli-cation has been completed. The' Staff issued a finding of No Significant Impact with an Environmental Assessme,nt on April 12, 1985.
(JR)
Q29. Are there any other considerations regarding an offsite dry cask ISFSI?
A29. For an offsite ISFSI, VEPC0 would have to characterize and select a site, a process that would probably take one to two years.
- Further,
' an ISFSI at a separate site would require the NRC staff to publish an environmental impact statement-(EIS), in accordance with
-10 C.F.R. Part 51, Section 51.20(b)(9). Thus, a draft EIS would be l
prepared and issued for public coment, and then a final EIS would be prepared and issued. Because fuel receipt and handling facili-ties would have to be constructed to allow for transportation cask unloading and storage cask loading and unloading, an ISFSI at a separate site would most likely involve more construction than one at a reactor site. After licensing, the construction period, which might take two to three years, would further delay storage of fuel.
Without being specific, I would, in general, think that an offsite
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l dry cask ISFSI would probably take about three or more years-longer to design, license and construct than.an onsite ISFSI. Accordingly' 4
1 an offsite ISFSI does not appear to be a feasible alternative as a near-term solution for VEPC0 in its present situation.
(JR) 4 Q30. Mr. Cleary, have you reviewed the proposal of VEPCO to receive and store at North Anna Facility, 500 spent fuel assemblies from the Surry Station, Units 1 and 2?
A30. Yes, I have reviewed that proposal with regard to,whether or not such an action would involve a NEPA Section 102(2)(E) conflict in the use of resources.
Q31. What is your conclusion with regard to whether or not such a pro-posed action does involve a conflict in the use of resources?
A31. The proposed action will not involve any noteworthy conflict in the
" use of resources.
I have compared the level of various resources, such as casks, trucks, automobiles and labor, which will be committed to the proposed action to the total availability of these resources and find the commitment to be insignificant. The spent fuel casks 4
are' fabricated from materials that are in ample supply, lead, steel, cement, resin and copper.
By weight lead constitutes the majority of a cask. The preliminary estimate of primary and secondary (repro-cessed) lead production in 1983 is 1,266 thousand tons. Assuming the upper limit of 40 tons of lead in a 40 ton cask each cask would use 3 x 10-5 of the 1983 production of lead in the United States.
I
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F~ a Other materials.used in_each cask would involve a smaller proportion
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of available supply.
Resources used in transportation of the spent fuel assemblies, like-wise, involve an insignificant proportion of resources used in truck transportation in the United States. VEPC0 has indicated that there
.will be a maximum number of shipments per year of 40 and that the routes under consideration from'Surry to North Anna range from 134 miles to 177 miles (letter from W. L. Stewart to.,H. R. Denton dated October 28, 1983; and " Spent Fuel Transportation Routing Plan for Transshipment from Surry Nuclear Power Station Unit 1 and 2 to North Anna Electric and Power Company",- June 1982). This level of activity Souldinvolvelessthanonefulltimetruckandtwoescortautomobiles per year, a very small proportion of total national truck activity.
In 1983, 1,433 thousand " heavy-heavy" trucks logged 49.7 billion
- miles in the United States. The commitment of labor to the proposed action is insignificant relative to total employment of over 1.1 million in the trucking industry in 1983.
The mineral and transportation statistics previously referred to are found in " Statistical Abstract of the United States - 1985" published by the U.S. Department of Commerce, Bureau of the Census.
Resources use for the transportation of all radioactive materials was considered in the " Final Environmental Statement on the Trans-portation of Radioactive Materials by Air and Other Modes", Docket I
No.PR-71,73(40FR23768), December 1977,(NUREG-0170).
Shielding materials and.the transport process were specifically considered.
Resource use was found to be negligible relative to the total level of these resources used in all other activities (pages xxy and 4-30).
(DC)
Q32. Mr. Long and Mr. Engle, what effect does the foregoing testimony of William R. Lahs, Jr., Carl B. S3wyer, William H. Lake, John P. Roberts and Don Cleary have on the conclusion in the NRC. Staff Environmental Assessment by the Offices of Nuclear Regulatory Regulation and Nuclear Material Safety and, Safeguards related to increasing the spent fuel storage capacity and the storage of Surry spent fuel at the North Anna Power Station, Units No. I and No. 2, Virginia Electric and Power Company and Old Dominion Electric Cooperative, North Anna Power Station, Units No. 1 and 2, Dockets No. 50-338 and 50-339 that
' the proposed action for receipt and storage of Surry Spent fuel at North Anna does not significantly impact the quality of the human environment, and that therefore an Environmental Impact Statement need not be prepared?
A32. We have reviewed the above testimony.
Based on this review, we believe that the above testimony has the effect of confirming that Staff conclusion contained in the Environmental Assessment.
(JL,LE) 0
REFERENCES 1.
Transport of Radionuclides in Urban Environs:
Draft Environmental 7
Assessment, Sandia National Laboratories, NUREG/CR-0743, July 1980 2.
Generic Adversary Characteristics Summary Report, NUREG-0459, U.S.
Nuclear Regulatory Commission, Washington, D.C., March 1979 3.
Transport of Radionuclides in Urban Environs:
A Working Draft Assessment, A. Ducharme, et al. SAND-77-1927, May 1978 4.
Analysis, Scale Modeling, and Full-Scale Tests of a Truck-Spent
[
Nuclear Fuel Shipoing Cask in High Velocity Impacts Against a Rigid Barrier, M. Huerta, SAND-77-0270, April 1978 5.
Analysis, Scale Modeling, and Full-Scale Tests of a Railcar and Spent Nuclear Fuel Shipping Cask in a High Velocity Impact Against a Rigid Barrier, M. Huerta, 5AND-78-0458, August 1978
' 6.
A Study of Full-Scale Test of A High Velocity Grade-Crossing Simulated Accident of A Locomotive and A Nuclear-5 pent Fuel Shipping Cask, M. Huerta and H. Yoshimura, SAND-79-2291, February 1983
. 7.
U. K. Train Crash Validates Scale-Model Testing, Nuclear News, September 1984, p. 80 8.
Final Report on Ship)ing Cask Sabotag'e Source Term Investigation, p
Battelle Columbus La) oratories, NUREG/CR-2472, October 1982 9.
An Assessment of the Safety of Spent Fuel Transportation In Urban Environs, Sandia National Laboratories, SAND-82-2365, June 1983 10.
Certificate of Compliance No. 9015, issued to Transnuclear, Inc.
dated March 7, 1985.
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2 Professional Oualifications William H. Lake, Jr.
' Employment Experience I am a Mechanical Engineer (Heat Transfer) in the Transportation Certifica-tion Branch of the Nuclear Regulatory Commission.
I have been with the Branch since joining the Atomic Energy Commission in November 1972.
I evaluate specific package designs for their ability to safely dissipate heat and withstand fire environments, and I provide technical support for generic issues related to heat transfer.
In addition to my responsibilities in the
. area of heat. transfer, I also:. (1) act as project manager for a number of l
design reviews, (2) evaluate containment capability of designs, (3) evaluate.
operating procedures for use of containers, (4) evaluate acceptance and maintenance tests, and (5) evaluate maintenance procedures.
Prior.to joining the AEC in 1972, I was a Thermodynama'cist with Grummann Aerospace Corporation of Bethpage, New York.
I joined Grummann in June 1969.
'I was-involved in Grummann's work on NASA contracted space programs. My work involved space vehicle thermal balance and atmospheric re-entry heating.
I was involved primarilf'in contract proposal work.
I Education
.I earned by B.S.M.E. from the Polytechnic Institute of Brooklyn (PIB) in l
1967.
I earned my M.S.M.E. at PIB in 1970, specializing in the thermal option of mechanical engineering.
-Since coming to the Commission (AEC/NRC) in 1972, I have taken a number of courses to develop a background in probabilistic analysis, including:
operations research, reliability analysis, human factors analysis and fault tree analysis, these includeo a combination of full college courses, but mostly short concentrated courses.
Honors I held an undergraduate research grant sponsored by NSF in 1966.
I held an NSF funded Polytechnic Fellowship between September 1967 and June 1969:-
I.am a member of Pi Tau Sigma (Mechanical Engineering Honor Society), and am associate member of Sigma Xi (Research Society of North America).
t 4
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. 3 lechnical Publications
. Lake, William H., " Thermal Analysis of Packaging Using the Integrai Method,"
l Proc. 7th Int. Symp.
Packaging and Transportation of Radioactive Materials, PATRAM E3, New Orleans, May 15-20, 1983.
Lake, William H., " Containment System Evaluation," PATRAM B3, New Orleans, May 15-?0,.1983.
Gordon, Leonard L. and Lake, William H., " Discussion of Regulatory Guide 7.10, En.phasizing the Graded Approach for Establishing QA Programs,"
PATP/F E3, May 15-20, 1983.
Lake, William H., "Modeling the Normal Thermal Environment," Proceeding, 6th International Symposium, Packaging and Transportation of Radioactive Materials, West Berlin, November 1980.
Lake, William H., " Containment Seal Reliability Testin5," Proceeding, 6th international Symposium, Packaging and Transportation of P.adioactive Materials, West Berlin, 'N69tmber 1980.
Lake, William H., " Reliability in Maintenance and Desi.gn of Elas~tomer Sealed Closures," Proceeding, 5th International Symposium, Packaging and H
Tr6nsportation of Radioactive Materials, Las Vegas, Nevada, May 1978.
f
'f Lake, William H.,
" Capabilities and Limitations of Heat Pipes for Use in F.adioactive Materials Shipping Casks as an Alternative to Active Cooling Systems," Proceeding, 4th International Symposium, Packaging and Transportation,o'f Radioactive Materials, Miami Seach, Florida, September 1974.
Lake, William H.,
" Aerodynamic Heating to Swept Cylinders Using the Energy Integral Method of Fleming and Krauss," Grumman Aerospace Corporation, Advanced Development Report No. ADR 01-04-71.2, December 1971.
Lake, William H., " Aerodynamic Heating Methods for Blunt-Nosed Hypersonic Vehicles," Grumman Aerospace Corporation, Advanced Developrent Report No. ADR 22-02-73.1, February 1973.
Flair, D. W. and Lake, William H., " Solid Propellant Flame Zone Radiation,"
AIAA J. V7, No. 9 September 1969.
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2
Professional Qualifications Carl B. Sawyer My name is Carl B. Sawyer.
I am a Senior Safeguards Program Analyst in the Material Transfer Safeguards Licensing Branch, Division of Safeguards, Office of Nuclear Material Safety and Safeguards, United States Nuclear Regulatory Commission.
I joined the Atomic Energy Commission, predecessor
~
agency to the Nuclear Regulatory Commission, in 1971 and since then have worked in various activities concerned with the planni,ng and conduct of
. studies and analyses for the protection of nuclear materials against tt.2ft and for the protection of nuclear facilities against sabotage.
I am knowledgeable of the Commission's regulations and practices concerning the protection of spent nuclear fuel during transport.
From 1956 to 1971 I was employed by various companies in the Washington, D.C. metropolitan area as an electrical engineer.
My duties with the companies consisted largely of the design and development of components for advanced communications systems used by the Department of Defense and other agencies of the U.S. Government.
From 1954 to 1956 I served as a communications officer with the U.S.--
Air Forc~e.
I graduated from North Carolina State College in 1954 with a B.S. in electrical engineering.
m. - -
~ STATEMENT OF FROFESSIONAL QUALIFICATIONS William R. Lahs Jr.
(
Ny name is William R. Lahs Jr.
I am a graduate of Purdue University with the Degrees of Master of Science in Nuclear Engineering and a Bachelor of Science in Engineering Science.
I have worked for the Nuclear Regulatory Comission since its inception in 1974.
Prior to that, I was employed for ten years at the Atomics International Division of Rockwell International and two years at the Environmental Protection Agency's Office of Radiation Programs.
In my position at NRC, I have been extensively involved with the broad area of radio-active material transport.
In 1979, I served as Chairman of an NRC panel which assessed the sienificance-of experimental information related to radioactive
- material package performann when subjected to malevolent attack.
I have been the NRC manager on numerous programs of physical research and analysis related..
to various aspects of transportation safety and safeguards.
Specifically,. in close cooperation with licensing offices personnel, I was the NRC manager of a progran at Battel,le Columbus Laboratories directed at establishing the radio-
~
~
logical sou*ce tern resulting fron potential adversary actions involving the use of explosives against a spent fuel shipping cask target.
s,.%
In the transportation safety area, I have served as Chairraan cf an NRC group which addressed the regulatory implications of potential oxidation of UO I"
2 irradiated fuel.
I am also the manager for the transportation model study
- 1.
orogram. The Modal Study is a research program attempting to establish the degree-of protection provided by spent fuel shipping casks, designed to exist-ing NRC s,tandards, if such casks are subjected to extremely severe transporta-tion accidents.
I have authored several papers which discuss the results of and progress in the above programs.
~
STATEMENT' 0F PROFESSIONAL QUALIFICATIONS
~
JOHN P. ROBERTS 6 name is John P. Roberts.
I am Group Leader for Spent Fuel Storage
~
Installations in the' Advanced Fuel and Spent Fuel Licensing Branch in the Division of. Fuel Cycle and Materigl Safety in the Office of Nuclee'r Material Safety and Safeguards, United States Nuclear Regulatory Commission.
I have been employed as a project manager for spent fuel storage licensing with title of Process Licensing Engineer since Npvember 1976 (. title changed to
~
Nuclear Process Engineer in 1983), and assumed the responsibility of group leader in October 1977.
I am presently project manager for the General
-=:.
Electric Company Morris Operation, the safety reviews of topical safety amlysis reports for dry cask and module indeptndent spent fuel storage
'hsta11ations (15F51's) and the Virginia Electric and Power, Company's application
.or spent fuel storage at an 15FSI to be located at its Surry nuclear power plant site.'
I have been employed by the Nuclear Regulatory Commission since Decenher 1974 (when it was the Atomic Energy Commission).
I Yas initially employed %
as a Criticality and Shie'1 ding Engineer to evaluate the safety of packaging designs for shipment of fuel and other radioactive materials.
In October 1975 I was assigned to. assist in the preparation of the Generic Environmental 5..tement on Mixed Oxide Fuel (GESMO).
My duties included preparing an-
' Integrated Environmental Impact Table for the nuclear fuel cycle and Sestifying in the GESMO proceedings.
2 '.-
o Subsequently I was assigned to the Task Force for the Environmental Survey the Reprocessing and Waste Management Portions of the LWR Fuel Cycle
. rforming similar work.
After joining what is now the Advanced Fuel and Spent Fuel Licensing Branch, I served:
(1) as project manager for' the preparation of the Generic,.
Environmental Impact Statement on Handling and Storage of Light Vater Power Reactor Spent Fuel (NUREG-0575) which was published in August 1979; (2) as witness during _ hearings on the application to transship and store irradiated
' fuel Trem the Oconee Nuclear Station at the McGuire Unit 1 Eclear Station and was subsequently project manager for that case during its appeal before
~
the Atomic Safety and Licensing Appeal Board; (3) as task leader in Advanced-notification to States of Transportation of Certain Types of Nuclear Waste ulemaking (47 FR 596,1/6/82); and (4) as a member of the staff working group to assist the Commission in the Waste Confidence Rule:naking Proceeding (f 9 FR 34688, 8/13/84).
l Before joining the Commission I was employed by Harry Diamond Laboratories I
as a researcit physicist.(nuclear) and then as a nuclear engineer perfonning 1
l radiation transport and effects studies from 1966-1974 with two years off for graduate study at the Catholit University of America.
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.om the Catholic University I received a Bachelor of Electric Engineering
'-6 tee (cum laude) in 1962 and a Master of Nuclear Science,and Engineering
~ Degree in 1965.
While an undergraduate I was employed as an Engineering Aid at David Taylor Model Basin (now U.S. Naval Ship Research and Develo5 ment Center) in the sumers of 1960 and 1961.
I returned as an Electronics Engineer in
.the. su:=ner of 1962.
I served as a graduate Teaching Assistant in the Catholic University, Nuclear Science and Engineering Division from 1962 to 1963, and in the sur=ner of 1963 was employed as an Electronics Engineer at the U.S. Anny Nuclear s?ower Field Office at Fort Belvoir, Virginia.
I am a member of the American Nuclear Society and of the IItitute of Electrical and Electronic Engineers.
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4 COPY STATEMENT OF PROFESSIONAL QUALIFICATIONS Jk' DONALD P. CLEARY My name is Donald P. Cleary.
I am Acting Chief of the Site Analysis Branch and also Section Leader of the Regional Imptet Analysis Section within that branch.
The Site Analysis Branch is in the Division of Engineering, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission (NRC).
I have been with the NRC (previously Atomic Energy Commission) since 1973 and was appointed Sectio 6 Leader in 1976.
As a technical reviewer and supervisor I have been responsible for various sections of environmental.igpact statements.
These include social and economic impacts, need for the project, alternatives to the profect,
-irreversible and irretrievable commitments of resources, relationships 9
between short-term use and long-term productivity of man's environment, and benefit cost balance.
, " Prior to j i io n ng NRC, I was first an Industry Economist and then Staff Specialist for Program Review and Evaluation in the Office of Resource Utilization, National Marine Fisheries Service, National Oceanic and
~^
Atm'o' spheric Administration, U.S. Department of Commerce.
I received a B.A. in economics from the University of Massachusetts in 1961, and an. M.A. in economics from the University of Florida in 1963.
I completed course work for the Ph.D in Natural Resource Economics at the University of Michigan.
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STATEMENT OF PROFESSIONAL QUALIFICATIONS j
LEON B. ENGLE My name is Leon B. Engle.
I am an Operating Reactor Project Manager in Operating Reactors Branch No. 3 Division of Licensing, Office of Nuclear Reactor Regulation, United St'ates Nuclear Regulatory Comission.
I have been employed as an-operating reactors project manager since October 1979.
Duties include the scheduling, management and participation in the review and evaluation of applications for power reactor license amendments and on
. occasion may involve a unique first-of-a-kind problem.
I am presently the project manager for the N rth A'nna Power Station, Units No. I and No. 2.
I am. also.the lead proiect manager for implementing the NRC Multi-Plant Action Items B-17 and B-22, technical specifications for hydraulic and mechanical snubbers, respectively.
I have been employed by the Nuclear Regulatory Commission since November 1974 (whenitwasthentheAtomicknergyCommission).
I was initially employed
.as a Licensing Project Manager to schedule, manage, and participate in the review and evaluation of civilian nuclear power reactor applications for'as c'enstruction permit or operatin~g license.
Facilities for which I have been a project manager in this capacity have included the Greenwood Energy Center, Units 182; Crystal River Power Station, Unit 3; Davis Besse Nuclear Power Plant',
Unit 1; Midland Nu, clear Power Plant, Units 1&2; the Arkansas Nuclear Plant, Unit 2; and the Palo Verde Nuclear Power Station, Units 4&5.
3
~
-1 From the period of May 1979 to October 1979 I was assigned to the Bulletin and Orders Task Force and the TMI Task Force.
I was responsible for preparing responses to public and Congressional inquires rdgarding TMI.
Also, I was responsible for coordinating staff, legal and management review and preparation of the draft Coeraission brder for Restart of TMI, Unit 1.
Before joining the Comission, I was employed by the Los Alamos Scientific 7
Laboratory from July 1951 tn November 1974.
My initial employment was as Research Assistant in Weapons Design and Evaluation.
Other responsibilities as Staff Member (Physicist) have igpart included the analysis of LMFBR hypothetical accidents for code development and the development and use of computer codes for determining the energy release of known reactor accidents.
Other duties have included the neutronic assessment of the Phoebus 2 nuclear rocket reactor, evaluation of experimental results from fast neutren critical assemblies for.th'eoretical code. development, and the use and application, of
' computer codes and methods to existing and proposed reactor designs and to conceptual experiments appropriate to reactor safety.
m During the' period of January 1969 to January 1979, I was appointed as member and elected as Chairman of the New Mexico Health and Social Service Board.
Responsibilites included policymaking and regulatory jurisdiction in e
environment, public health, and social services.
As chairman of the board, I was most involved with drafting of and steering toward adoption the Ambient Air Standards and Air Quality Control Regulations for the State of New Mexico (1970)..
[
3-l From the period November 1950 to July 1951, I was employed as a physicist with the United States Air Force, Hollaman AFB, New Mexico, and evaluated data reduction methods to be used in a radar beacon missile tracking' system.
I received a Bachelor of Science Degree (Physics) from Colorado College in 1950.
Other professional training has. included course instruction in physics and mathematics at the University of New Mexico Extension Courses, Los Alamos Scientific Laboratory and Air Pollution Control Technology at the University of Texas, Aus. tin, Texas.
In addition, I have attende,d NRC sponsored course training in Pressurized k'ater Nuclear Power Reactors.
.( -
I served in the United States Navy from 1943 to 1946 in the Pacific Theater of Operations.
9 e"
.I
\\
.__,.. _ 1
'y, sarn'.zNT or PRCTESSIONAI. QUAI,ITICATIONS JUSTIN T. IDNG
- P'y name is Justin T. Zeng.
I am a senior Chemical Engineer in the rachnical Assessment and Evaluation section in the Uranima Fuel I.icensing i
3 ranch, Division of Fuel Cycle and Material safety, Office of Nuclear Material safety and safeguards, United States Nuclear Regulatcry Co= mission.
I. joined the Atc=ic Energy Cc. ssion, predecesser agency to the Nn= lear Regulato:y Cce issica, in 1970 and since then have verkad in various nuclear material-licensing, regulatic= drafting, 'and policyr.aking activities.
Per nine months I was Acting Chief, contingency Planning Branch, :Divisica of
' Safeguards.
~
~
9.
Prior to joining the Atanic Energy Cc issica, I was erployed by Union Ca= hide Corporation at Cak Ridge Naticnal IAboratcry, Where I was a gredy leader in usaarch and development of nu' lear che=ical engineering ;macesses, a=d I e
was Assistant Research Professor at Auburn University for four years.
I am
~ the auther of a 1000 page book, Eneineering fer Nuclear Fuel Reprocessimer.
During World War II I was Chief of Operations of a ylight servJ.ca Centar that provided flight advisory services, including a:nergency evacuation, to all =ilitary aircraf t operating in the southeaste:n United states.
Q
.s I received a Ph. D. in chemical engineering frczn Iowa State University in 1950 and a 3. S. Ch. Z. frcan Purdue University in 1941, and an a graduate of 1
tha University of Chicago school of Meteorology.
e e=
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347
- 4-10-Suet 1
MR. MC GURREN:
Your Honor, at this time I would 2
like several of the panel members to briefly summarize the 3
major areas of the testimony.
4 BY MR. MC GURREN:
(Continuing) 5 0
And I would like to start with Mr. Lahs.
Would 6
you please give us a brief summary of the testimony?
7 A
(Witness Lahs)
Yes.
The testinony given by Mr.
8 Sawyer and myself, who worked on it jointly, is directed at 9
that part of the contention which states that the environmental 10 assessment did not evaluate the probability and consequences 11 of accidents occurring during the transoortation of spent 12 fuel casks from Surry to North Anna occasioned by acts of 13 sabotage.
14 Essentially we have considered the structure of 15 the cask, threats against such casks, the protection provid-16 ed, the effects of acts of sabotage on the casks, and the 17 potential radiological consequences which could result.
We 18 have concluded, as is stated in our testimony on Page 17, 19 that the probability and consequences or risks associated 20 with these transportation activities are small and have been 21 adequately evaluated.
22 O
Mr. Lake?
23 A
(Witness Lake)
My testimony is directed at 24 the human error aspects of Consolidated Contention 1.
I Ace Federal Reporters, Inc.
25 am testifying that risks', due to human error, in transportatic'n l
348
' #4-ll-Suet j of radioactive materials has-been adequately considered in 2
the generic study, WAsil 1238, and that release due to 3
employee error is unlikely based on the cask de~ sign, closure 4
procedures and the use of an NRC approved quality assurance 5
program.
6 Q
Mr.. Roberts.
7 A
(Witness Roberts)
My testimony is directed at 8
the dry cask alternative at Surry.
NRC Staff Safety Review 9
of the VEPCO application for dry cask storage, ISFSI, at 10 the Surry Station site, and its associated topical report
-jj for the CASTOR-V cask design are not complete.
Thus, a 12 definitive statement regarding such storage and its viability, V
13 as an alternative cannot be made at this time.
14 A review could be completed in the Summer of 1985.
15 Regarding the feasibility of an off-site dry cask ISFRI, 16 constraints on the time to characterize the site for issuance 17 of an environmental impact statement and to design, construct 18 and license an off-site ISFSI leads to the conclusion that 19 it does not appear to be a ' feasible alternative solution for 20 VEPCO in its present situation.
21 Q
Could you indicate what ISFSI?
I 22 A
Oh, ISFSI, independent spent fuel storage instal-23 lation.
24 0
Mr. Cleary, would you please briefly summarize m hp. rem, k j
25 your testimony?
349 44-12-Suet 1 A
(Witness Cleary)
I have reviewed the proposal 2
. to transship spent nuclear fuel with regard to whether or 3
not-such an action would involve a significant conflict
^
4 in the use of resources under 'NEPA Section 102 (2) (E).
5 I have concluded that the resource requirements 6
for the transshipment are so small that such a conflict 7
will not exist.
8 Q
And, Mr. Engle, would you please summarize your 9
testimony?
10 A
(Witness Engle)
All right.
I have reviewed the 11 Staff's testimony and believe that the testimony presented 12 confirms the Staff's conclusions contained in the environ-13 mental assessment that the proposed action for receiot and 14 storage of Surrv spent fuel at North Anna does not signi-15
'ficantly impact the quality of the human environment; and 16 that, therefore, an environmental impact statement need not 17 have been prepared.
18 MR. MC GURREN:
Your Honor, this concludes our 19 direct case.
At this time, this panel is available for 20 cross-examination.
21 JUDGE WOLFE:
All right.
Mr. Doughertv.
lt EX 22 CROSS EXAMINATION 23 BY MR. DOUGHERTY:
24 Q
Mr. Roberts, I would like to direct your attention Asadadorel Repeners, lac.
25 to Question and Answer 28 on Paga 23.
The question in essence
350
- 4-13-Suet 1 is when will the Staff's review of Virginia Power's dry cask 2
storage application be complete.
4 3
I wonder if you could explain your answer.
The 4
first sentence of your response says, " Assuming timely 5
submi.ttal of a complete topical report, its safety review 6
could be finished in the spring of 1985."
7 Could you tell me more about the timing or the 8
anticipated timing of Virginia Power's submission of that?
9 This would be -,
I suppose it's G&Ss submission 10 of a complete topical report.
11 And could you give me any update, if there is 12 such, about timing, your review in this now late spring of 13
'85?
I'm just curious about what the status of all of this 14 is.
15 A
(Witness Roberts)
All right.
Recarding the 16 timely -- all right.
A couple of clari.fications.
The 17 report is submitted by General Nuclear Systems, Inc. which 18 is a partnership between G&S for Nuclear Service and ChemNucletr 19 Systems.
It was received by us in February of '85.
20 When I was talking timely submittal, I was thinking 21 January but that's approximately the same frame work.
i 22 With regard to the safety review I still think 23 that we can probably complete it in the Spring of '85 but 24 obviously we are in late Sprina, as you remarked.
e e n.p.,,
sac.
25 Q
So when do you expect the Staff will get that out?
351
- 4-14-Suet 1 In a month roughly?
2 A
I think we could do that.
I say "could" because 3
the review is not complete.
4 Q
I wonder if you could also explain that second 5
sentence concerning the integration of the topical report 6
by reference into the VEPCO safety analysis report?
7 A
Well, VEPCO is referencing, of course, the topical 8
report and, therefore, in their safety analysis report that 9
must be incorporated in a proper fashion so that there are 10 not, if you will, gaps.
11 That work has been ongoing and while VEPCO has 12, not yet submitted that to us, they have discussed it with our 13 staff and so forth.
So dhat work is ongoing, as I understand 14 it.
15 Q
Explain to me again what it is that VEPCO has 16 yet to submit to the Staff?
17 A
Mell, basically they would have to resubmit this 18 safety analysis report as it incorporates the topical report 19 and I think there is one other small item of information that 20 we are st.11 waiting for docketing.
21 0
Is it your opinion that the dry cask storage 22 facility proposed for Surry presents greater public health i
23 and safety and environmental risks than the proposal to 24 ship 500 fuel assemblies to North Anna?
Ace Federal Reporters, loc.
25 A
No.
But I think I should explain that answer a
352
- 4-15-Sued little.
2 0
If you don't mind, that's a perfectly satisfactory 3
answer.
Thank you.
4 In your opinion, is the dry cask facility proposed 5
for Surry likely to be significantly more expensive in eco-6 nomic terms than the proposal to ship 500 fuel assemblies 7
to North Anna?
8 A
I can't really answer that question.
9 MR. DOUGHERTY:
Thank you.
That's all I have, 10 Judge.
II JUDGE WOLFE:
Mr. Maupin?
12 MR. MAUPIN:
Let me just think about the last 13 two answers I heard.
Id (Pause.)
15 No, I don't have any questions.
IO JUDGE WOLFE:
Redirect.
I7 MR. MC GURREN:
Yes.
18 REDIRECT EXAMINATION II BY MR. MC GURREN:
20 INDEX Q
Mr. Roberts, you wanted to finish an answer with 21 regard to a comparison.
22 What was going to be your explanation?
23 A
(Witness Roberts)
Well, I was just going to say 24 that basically, if one meets the safety requirements incorocra t-As. 7.derd hp.mr., w.
25 ed in NRC regulations I think it is rather difficult to make 6
353
- 4-16-Suet 1 comparisons of safety and safety.
2 MR. MC GURREN:
Thank you.
Ycrar Honor, that's END #4 3
all we have.
Si ns f1ws 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Ace Federal Reporters, Inc.
25
I 354
.Sim 5-1 1
BOARD EXAMINATION NDEXXXXXX 2
BY JUDGE WOLFE:
3 Q
Just as a point of information, do you gentlemen 4
know whether, and this is somewhat aside from what you have 5
been testifying to, but do you know whether the routes to 6
be taken, the primary routes and the alternate routes to be 7
taken from the Surry to the North Anna plant for the trans-8 Portation of spent fuel remain the same as that set forth 9
in a letter of July 28th, 1982 from Mr. Theordore Sherr to 10 Vepco's Mr. Leasburg, Vice President?
11 A
(Witne,ss Sawyer)
Yes, sir.
The terms and 12 conditions of that letter from our point of view in the 13 Division of Safeguards still remain ef fective.
14 O
Turning to page 15 of your written. direct 15 testimony and then followed by what is on page 16 by the 16 sponsors of that particular portion of the testimony, and 17 those are WRL and CBS, and I'would direct my question,to you 18 two gentlemen.
19 At the top of page 15 there appears language 20 to the effect that " Tests from the NRC-sponsored program 21 showed that for perfectly executed sabotage of a three-22 assembly truck cask, the likely release of respirable particles 23 would be less than 18 grams; tests from the DOE-sponsored 24 showed the likely release to be less than 34 grams."
Ace-Federal Reporters, Inc.
25 Without getting into a lot of details, could
a.e.
l 355
~
1 you advise the Board what these tests were and how these 2
grams were arrived at.
3 A
(Witness Lahs)
The Sandia program involved tests 4
using essentially a full-scale cask with a simulated PWR 5
assembly, but it was an unirradiated fuel assembly.
The 6
Battelle tests, on the other hand, involved approximately 7
a quarter-scale test with a simulated cask containing 8
actually irradiated fuel pins.
Therefore, it required an 9
adjustment on scaling to get to the reference basis event, 10 and that is one of the reasons why there is factor of two 11 difference.
12 Q
Do you have anyting to add to that, Mr. Sawyer?
13 A
(Witness Sawyer)
Perhaps amplification of the 14 phrase " perfectly executed sabotage" is in order here.
When i
15 we wrote those words we had in mind that the very severe 16 sabotage scenaro, which has been specified, would be carried 17 out perfectly, that is exactly as specified.
Now this is a i
18 situation very favorable.to.the saboteur.
19 JUDGE WOLFE:- You have seen the environmental
~
20 assessment of 19857 21 MR. DOUGHERTY:
Yes, I have, Judge.
22 JUDGE WOLFE:
In the past, Mr. McGurren, I have 23 presided over quite a few proceedings, and in some of these 24 proceedings the staff, for reasons best known to itself, has Aco Fede,ol Repone,s, lac.
25 not offered into evidence certain documents.
I am not telling
356 Sin 5-3
~
j you how to run your case, but there is some frequent reference 2
to this environmental assessment of April 12, 1982.
I can't 3
but say to you that if something is going to be extracted 4
from that document for the purposes of your proposed findings, 5
that is not in the testimony, the Board will not make a 6
finding because there is no exhibit, namely, the environmental 7
assessment that has been tendered and admitted into evidence.
8 I don' t know your case, and it is up to you, but 9
we plan to close the record today.
10 MR. McGURREN:
Just a minute, Your Honor.
11 (Pause.)
12 Your Honor, may we have a five-minute recess and 13 I will discuss this with the other parties.
14 JUDGE WOLFE:
All right. We will have a five-15 minute recess.
16 (Recess taken.)
17 JUDGE WOLFE:
All right,,back on the record.
18 MR. McGURREN:
Your Honor, first I would like 19 to clarify.
Did you say April 12, 1982 or April 12, 19857 20 JUDGE WOLFE:
April 12, 1985.
21 MR. McGURREN:
Thank you.
Your Honor, the parties 22 have met and discussed this and the parties have agreed that 23 the environmental assessment for the Surry ISFSI be received i
24 into evidence.
Ae how i hp.nwi Inc.
i 25 And let me at this time request that a document
357 Sim 5-4 1
which consists of a cover letter dated April 12, 1985 from 2 Leland Rouse to Virginia Electric Power and Power Company, 3
which covers a document entitled " United States Nuclear 4
Regulatory Commission, Docke t No. 72-2, (50-280. and -281) 5 Virginia Electric and Power Company, Notice of Issuance of 6
Environmental Assessment and Finding of No Significant Impact 7
for the Surry Dry Cask Independent Spent Fuel Storage 8
Installation at the Surry Power Station,"
and attached to 9
that finding is the third part of this document, which is tbe 10 "U.S.
Nuclear Regulatory Commission, Office of Nuclear Material Il Safety and Safeguards, Environmental Assessment Related to the 12 Construction and Operation of the Surry Dry Cask Independent 13 Spent Fuel Storage, Installation, Docket No. 72-2, Virginia 14 Electric and Power Company, April 1985."
15 Your Honor, at this time I asked that this 16 be marked for identifi' cation as Staff Exhibit 3, and I also 17 at this point ask that it be received into evidence.
18 I will give the court reporter three copies 19 of this document.
20 JUDGE WOLFE:
Do you have a spare copy for the 21 Board as well?
f 22 (A copy of the document was handed to the 23 Board.)
24 (The document referred to was ke Federal Reporten, Inc.
25 marked Staff Exhibit No. 3 for identification.)
1 358
$10 5-5 MR. McGURREN:
Just a minute, Your Honor.
)
(Pause.)
2 JUDGE WOLFE:
Any dbjection?'
3 MIG DOUGHERTY:.
No objection.
4 MR. MAUPIN':.' No objection.
5 JUDGE WOLFE:
Staff Exhibit.3 is admitted into 6
evidence.
7 (Staff Exhibit No.
3, previously 8
marked for identification, was 9
admitted into evidence.)
10 JUDGE WOLFE:
Cross, Mr. Maupin?
INDEX jj CROSS-EXAMINATION 12 BY MR. MAUPIN:
13 ja Q
Now as I understand it, you have done an 15 environmental assessment on the proposal to receive and 16 store Surry fuel at North Anna and that has resulted in a j7 finding of no significant impact; is that correct?
18 A
(Witness Roberts)
No.
You are referring to 19 receive and store Surry fuel at North Anna?
20 Q
Yes.
That is an exhibit in this case.
- Now, 21 as I also understand it from your testimony, the document 22 that has just been admitted as Staff Exhibit 3, the 23 environmental assessment of the ISFSI proposal for Surry, 24 and that has resulted in a finding of no signflicant impact; AceJedwal Reportws, Inc.
25 isn't that correct?
l l
I
- Sim 5-6 A
Yes.
359 j
Q Is it also true that if the staff reviews f
2 I
independent projects and reaches, as in this case, findings 3
in both cases of no significant impact, does it customarily 4
try t c mpare the insignificance of those effects?
5 A
No.
6 MR. MAUPIN:
That is all I have.
7 JUDGE WOLFE Redirect, Mr. McGurren?
g MR. McGURREN:
The staff has no redirect, 9
Y ur Honor.
10 JUDGE WOLFE:
All right, the witnesses are jj excused.
You are excused permanently.
12 (The NRC panel of witnesses was 13 permanently
- excused.)
j4 (Board conferring.)
15 JUDGE WOLFE:
All right.
I take it that the 16 presentations by the parties is now complete; iP that j7 Correct?
jg MR. McGURREN:
I am sorry, Your Honor, I j9 20 didn't hear you.
JUDGE WOLFE:
I say the presentations of the 21 Parties are now concluded; is that correct?
22 MR. McGURREN:
Yes, Your Honor.
23 MR. MAUPIN:
Yes, dir.
24 Ae Federal Reporters, Inc.
JUDGE WOLFE:
All right.
It is now time 25
360 sim 5-7 1
for, and before closing of the record in the case, for me 2
to give instructions and directions on the preparation and 3
submission of proposed findings, conclusions of law and 4
briefs.
S Have the parties discussed the scheduling, 6
the timing for the several submissions of the parties 7
beginning with the licensee?
8 MR. MAUPIN:
As a matter of fact, I don't think 9
we have.
10 JUDGE WOLFE Well, I am prepared to set a 11 schedule, but I don't know what your problems are or what 12 other business you have outstanding.
I am perfectly prepared 13 to have another short recess for the attorneys to get 14 together and make a decision on the dates for the preparation 15 and submission of the licensee's proposed findings, et cetera 16 those of the intervenor, those of the staff, and finally e
17-the timing of the reply submission by the licensee.
18 So if you can agree on those dates, fine.
19 How much time do you think you will need to come to some 20 agreement on that?
21 MR. McGURREN:
Well, Your Honor, I would be 22 willing to meet, and I don't think it would take very long.
23 MR. DOUGHERTY:
I think three to five minutes.
24 would do it, Judge, w d n.p.me, w 25 JUDGE WOLFE:
All right.
Well, we will stand
361 Sia 5-8 1
in place and have a recess.
2 Go right ahead and talk off the record.
3 (Recess.)
cnd Sim 4
Joe fois 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 w w.,ofhp.n.ri,tu.
25 l
x.
N g
i-1-Wal-6
-: s 362 N
- N
.j JUDGE WOLFE:
All right.
2 MR.'s!AUPIN:
Judge Wolfe, the parties agreed ~
~
3 to the following schedule and recommend'it to you.
4 Licensee will file its findings of fact and 5
conclusions of law and its transcr'ipt corrections by June 21.
6 JUDGE WOLFE All right.
s
'7, MR. MAUPIN:
The Co'ncerned Citizens of Louisa t
g County would file its propo' sed findings and ccnclusions of 9
law and its transcript corrections,-if any, on or before to,
July;1.
11 JUDGE WOLFE All right.
i n
MR. MAUPIN:
The Staff will file its transcript u
corrections and its proposed findings on or before July lith.
I s,
. Also, on or before July lith, the Licensee would 13 reply to th'e proposed findings of Concerned citizens of n
Louisa County, and on or before July 19, the Licensee would e
1r file its reply to the propose 4 findings filed by the Staff.
l i
18 l',
JUDGE WOLFE All right.
The direction of the I
i 1
Board is that pursuant' to 10 CFR Section 2.754, the parties i
20 are directed to fil,_o and will,be deemed in default if they 21 do not file proposed findings of fact and conclusions of law, i
y 22 briefs.anda propose ( form of order or decision.
I 23 The Licensee shall file by June 21, 1985 its 24 proposed findings of fact and conclusions of law and briefs, am-sens n===ee, inn.
25 and a proposed form of order or decision.
6.2-WO1 363 1
The Intervener, Concerned Citizens of Louisa 2
Co'inty, will file by July 1,1985 its proposed findings and 3
conclusions of law and briefs.
4 The Staff shall file by July lith the above 5
referred to and identified submissions.
1 6
The Licensee shall reply by July lith to the 7; filings of the -- of CCLC, and shall file its response by 8
July 19 to the Staff's submissions.
l 1
9 My instructions are as follows:
The proposed i
l 10 [ findings of fact and proposed conclusions of law shall follow 1
11 the ' format in Section 2.754 (c).
Further, proposed findings; i
M one, shall not summarize pleadings and filing dates; two, they 12 should not summarize the testimony; three, they should not l
U summarize prior rulings in the case except where necessary; i
!5 four, they should be set forth in declarative sentences, and i
le use the active voice; five, uncontraverted-findings shall be U
set forth first; sixth, ultimate findings of fact shall be l
18 !! supported by subsidiary findings; and seven, those parties I
L
'i filing after the Licensee should, wherever possible, incorporate 20- by reference the Licensee's proposed findings with which they t
21 really do not disagree.
l t
22 Parties should file a brief discussing the important!
t d3! issues and how they should be resolved.
The brief should set 2iI forth'the captioned contentions.
Discuss the reason why the 4
n w.
25 contentions, or as here the contention, should be resolved in
6-3-W31 364 1
favor of the submitting party, and should cite controlling 2
statutes and case law, and should cite supporting findings 3
by number.
4 As you can see, we are directing that not only 5
should proposed findings on other things be filed, but that 1
6 a supporting brief which among other things cites the proposed I
7' findings supporting your legal conclusions be submitted to the 1:
8 l; Board.
t 9 !!
I take it you are all aware of that practice?
At 10,
least by some of the Boards.
I 1)
MR. MAUPIN:
I am now.
9 JUDGE WOLFE:
All right.
You, Mr. Dougherty?
's MR. DOUGHERTY:
(Nods head affirmatively.)
JUDGE WOLFE:
And you, Mr. McGurren?
Mr. McGurren, U
you are awarei?.of this Chairman's desires with respect to that?
M MR. McGURREN:
I have never done it that way before, Your Honor, but will be glad to do it that way.
l 18 g JUDGE WOLFE:
All right.
Anything else left to i;
be discussed?
+-
S 20.
fNo respone.',
I I!
21 EUDGE WOLFE:
If not, the record is formally 22 { closed.
Thank you.
i.
23.
(Whereupon, the hearing was concluded at 10:37 a.m, L
24 Wednesday, May 22, 1985.)
- ~.,.
25 i
J__.____-_____.___--
CERTIFICATE OF OFFICIAL REPORTER This is to eartify that the attached proceedings before the UNI'PFD STATES NUCLEAR REGULATORY COMMISSISON in the matter of:
NAME OF PROCEEDING:
Virginia Electric & Power Company j
(North Anna Power Station, Units 1 & 2)
DOCKET NO.:
50-338-OLA-1 50-339-OLA-1 PLACE:
Charlottesville, VA DATE:
Wednesdav, May 22, 1985 i
were held herein appears, and that this is the official transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt)
//
i (TYPED)
//
GARRETT J. W74SH, JR.
(sigt) M
, 7/, MOA&M&j (TYPED) 'MY5 E T TRANLOR (sigt)
Af M a, _
(TYPED 7
//
MARY W.
SIMONS Official Reporters I'
l Reporter's Affiliation e
._-- - ____