ML20147B544

Intervenor Coulee Region Energy Coalition'S Interrogatories to the Appl & Request for Production of Documents

ML20147B544
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	09/18/1978
From:	Morse A, Nygaard G AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7810110042
Download: ML20147B544 (10)

Text

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-UNITED' STATES OF AMERICA .

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NUCLEAR REGULATORY _ COMMISSION g p[++  % M.

NRC PUBLIC DOCUMENT ROOM I cpq N ,d)! L BEFORE THE ATOMIC SAFETY AND LICENSING BOARD e3 b 'O #

c In'the Matter'of ) Docket No.30-409

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) Amendment.to Provisional' Operating License DAIRYLAND POWER COOPERATIVE' )

(Lacrosse Boiling Water Reactor) ) (Spent Fuel Pool) l  ;

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INTERV5NOR COULEE REGION ENERGY C0ALITION'S INTERROGATORIES  ?

(SET NO.1) TO THE APPLICANT AND REQUESTS FOR ~ ,

PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R. 92.740(b) and in accordance with the .

schedule established during the Prehearing Conference of August'  : ,

17, 1978, Intervenor Coulae Region Energy Coalition (CREC) . f requests that the Applicant answer separately and fully in writing under oath, each of the following interrogatories. The CREC - ct further requests pursuant to 10 C.F.R. 82 741 that the' Applicant provide specific documents as requested herein. ,,

The CREC requests that the person or persons answering each ,

interrogatory be identified by: (1) name, (2) address, (3) current occupation, (4) education, including degrees and principle. disciplines '

studied, schools attended, title of master's and' doctoral dis- i sertation and (5) title, reference, and summarized content of his e or her published scientific articles and' books. In addition  !

CREC requests that the source of information be disclosed where an answer is based in whole or in part on information ,

other than the personal knowledge of the person or of the wfnMW -

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_ rrg persons answering. These interrogatories are hereby expressly .s made' continuing, requiring supplenental answers thereto.as TI [

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infor=ation is acquired through the time of the evidentiary -j e

hearing. Where the date of an event is requested, the response r

~should set forth the exact date, if possibles however, when no  :

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~ record, or memory of an exact date exists, the response should .

set forth the most precise approximation possible. fhis set

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. of interrogatories is addressed to those cententions of the g <

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CRSC which are' 11sted in the Prehearing Conference Orders dated ,

Sept'e=ber 5,1976.

1 1 (a) Descrite in detail the basis for the Applicant's 1

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conclusion that its contract with Nuclear Fuel Services (NFS) -? 3 l has been " voided," including a description of all tritten and [ f.

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verbal co==unications between the Applicant and NFS on this ,

sub. ject and 'a descriptien of all efforts by the Applicant to w2

• enforce its contract with NFS. ...

l (b) Specify each and every pcrtion of the Applicant's f  :.

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f contract with N?S which gave NFS the power to unilaterally .

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i terminate that contract. .4

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l (c) Provide. a copy of all written ec==unications

' described in answering Interrogatory 1(a), and a copy of al' p l

contracts between the Applicant and NFS which dealt with the proposed .-  ;

receipt by NFS of spent fuel fren the IAC3WR reactor. )

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2. (a) Describe in detail each and every instance in which l l

the Applicant has sought to obtain a contractual cc==itsent whereby .

f the Applicant eculd ship spent fuel for per=anent storage to either 3 P

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3-the General Electric Company's Midwest Fuel Recovery Plant (MFRP) at Morris, Illinois, or the Allied General Nuclear Services (AGNS) plant at Barnwell, South Carolina, including a substantive description of all written and verbal communications on that subject and each response by MFRP and AGNS. '

(b) Provid e a copy of each written communication described in answering Interrogatory 2(a).

3 Describe fully the basis for the letter (LAC-5266) of the Applicant in which it is stated that General Electric's ,

MFRP facility at Morris, Illinois, will not receive and store additional spent fuel for long term storage.

4 (a) Hac the Applicant considered and analyzed the possibility of returning spent fuel currently stored in the spent fue3 storage pool to the reactors for further burnup, as a means of decreasing the annual output of spent fuel at LACEWR7 -

(b) If so, describe such analysis and any written documents referring to this alternative.

(c) If not, provide the Applicant's reasons fx not -

considering and analyzing such a possibility.  ;

(d) Provide a copy of each written document descr.ibed in Applicant's answer to Interrogatory 4(b).

5 (a) Has the Applicant considered and analyzed the possibility of expanding the physical area of the existing storage pool as an  ;

4l alternative to the compaction of spent fuel within the existing pool? l (b) If so, describe fully the physical details of .such an l

alternative, the financial cost, the environmental impacts, and  !

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'r d .,ll the health, and safety effects, including occupational dosage to 3 workers resulting from implementation of such an alternative.. 'j 61.

(c) If not, provide the Applicant's reasons for not 's; Mi

. considering and analyzing such a possibility.

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.s (d) Provide a copy of each written document in which ,j

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- the Applicant has considered, analyzed, or referred to the

. as possibility of expanding the physical area of the existing ' J4 '

storage pool. .

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6. (a) Has the Applicant considered and analyzed the 4'.

possibility of constructing a separate spent fuel storage pool

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.V' on-site or off-site as an alternative to the compaction of spent jj fuel within the existing pool?

(b) If so, describe such analysis and any written documents "2 -

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", referring to.this alternative. ^I,

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(c) If not, describe the basis of the Applicant's -

.<:.<;j 9[ determination not to pursue this alternative. ,,74 s.

(d) Provide a copy of each written document described in l}

l , answering Interrogatory 6(b). </k l ' e:.

7 (a) Has the Applicant considered and analyzed the -

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possibility of implementing any other alternatives to the proposed

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action not included in Interrogatories 4 through 67 -A (b) If so, describe such analysis and any written documents referring to such alternatives, )

(c) Provide a copy of each written document described in answering Interrogatory 7(a).

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8. (a) In what' year, according to the Applicant's projections, .,

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will; shipment of. spent fuel from LACBWR commence?

l (b) Describe fully the basis for that pro.jecti~on, including a description of all written documents relied on by the Applicant - '

in reaching its; conclusion.-

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(c) If the ' Applicant has not conc 1'uded that sh'ipment of spent fuel from LACBWR will. commence in 1987 to 1991, has the  ;

Applicant concluded that the reactor will have to'be shut down. '

l in the future due to an absence of spent fuel storage capacity? (

(d) If the Applicant has concluded that the reactors will [

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not be forced to shut'down in the~ future due to an absence of .

v spent fuel storage capactly, state the basis for such conclusion.  ;

9.- Describe in. detail each and every instance in which h

• the applicant has sought to obtain a contractual commitment in which the Applicant could ship spent fuel for temporary storage. -

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during the proposed construction and during any emergency which h

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10. (a) Assuming that 'there is no place to ship . spent fuel

. when the expanded capacity under the requested amendment has been ,.

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exhausted, describe all alterna"tives to reactor shutdown at N that time .

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(b) Describe the environmental'and health and safety Ii implications of each such alternative, and. the financial cost of f each such alternative.  :

conclusion (c) Describe in detail the basis for the Applicant's

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that none of the alternatives discussed in answering

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'l Interrogatories 10(a) and 10(b) should be implemented now, rather than the project currently proposed. d

11. (a) Identify and describe "f,

the substance of all documents 1.

in which the Applicant has considered, analyzed, or referred to ,

a possible future need to store more than 440 spent fuel assemblies 1

on-site and methods for accomplishing such storage. \,.

v (b) Provide a copy of each document identified in I, Interrogatory 11(a).

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12. Discuss in detail the reason why the proposed rack capacity '

j was selected over. rack designs with greater. or lesser fuel assembly "

capacities.

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13 (a) Provide a detailed analysis to support the statement ,

at page 1 of the letter LAC-5341 that the time to reach saturation '

1-is 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> in the eventof a loss of cooline power.

y (b) Describe in detail the steps which would have to - [,'

a be taken to restore cooling, the time during which such steps .

would have to be taken, and the occupational exposures which .

would be involved. . ".

14. Provide a simplified diagram or diagrams sh.cwing all sources and all pathways of makeup water for the spent fuel pool and' indicating'which sources and pathways meet Seismic Category I

, within the meaning of NRC Reg. Guide 1.13.C.8 (Rev.1, December,1975). i 15 Provide a simplified diagram of the Spent - Fbel Pool h Coolant ~ Cleanup System and the interconnections, if any, to the f plant radwaste treatment system, g r:

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16. What is the volumetric flow rate capability for coolant ,

diversion to the radwaste system? ,

17 What are the maximum and practical amounts of coolant q

contaminants, in mass and activity units, which would exhaust the .j removal capability of the filters and demineralizers of the Spent ')

c Fuel Pool Cleanup System?

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18. (a) Taking into account occupational exposure limits l';

i or LACBWR plant practice, state the minimum time between filter J.

1 or demineralizer replacement in the Spent Fuel Pool Cleanup b System.

(b) Give in detail the basis for this figure.

i (c) Does this figure include allowance for gross j fuel rod failure?

(d) If this figure does not include allowance for gross l fuel rod failure, explain why it does not. j

,.s 19 Taking all observed fuel cladding defects collectively,  :

how much radioactive matter has escaped from spent fuel into -

l the pool coolant? l

20. Assuming normal pool operating temperatures, what ,

fraction of radioactive contaminants contained in pool coolant is expected to be released to the environment? Distinguish .;

between gaseous and liquid releases.

21. Assuming the pool coolant is in a boiling condition, state the rate of release of radioactive contaminants contained in pool coolant to the environment. Distinguish between gaseous and liquid releases.

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22. (a) What is the maximum hcat load expected in the  ;,

modified spent fuel pool after a normal refueling resulting in f the pool being filled to. capacity? ,

(b) Specify the largest heat load experienced in the j spent fuel pool to date and describe the circumstances under 7 i

which this heat load was experienced. 7:'j 23 (a) In the event that the Component Cooling System is 3

not available to provide cooling service to the Spent Fuel Pool  ;(f ,

Cooling System, what are the feasible alternatives for providing

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cooling service to the pool? j (b) Describe in detail how each alternative would be ,' ;

accomplished and the length of time it would take to put the alternative into operation. ,

24. Describe (if not already covered under Interrogatory [j

8) what a new reprocessing facility would cost the utilities ' N.

per year per BWR space, and provide a copy of all documents in which the Applicant has analyzed this cost. .

Describe in detail the operating and maintenance costs N 25 y which would be involved in the storing of spent fuel on site *l at LACBWR in the modified spent fuel pool for a pe5iod of ten 9 years.

26. (a) Has the Applicant contracted fora supply of new .

spent fuel racks?

(b) If so. has the supplier begun or completed fabrication of the racks?

(c) If so, where are the racks at the present time?

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(d) If so, what will the total cost be for the new racks? ) l

.+1 (a) Describe in detail the manner in which the new spent 4l

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fuel racks will be moved into their final positions in the spent It fuel pool' 1: 4 (b) Indicate major equipment to be used, specific access E/

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l' and setdown areas.

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• (c) Indicate when and where any major assembly is to a

be done. ,

28. Identify each person whom the Applicant expects to call I as an expert witness giving, for each, (1) name, (2) address, (3) current occupation, (4) education, degrees and schools attended; title of master's thesis or doctoral dissertation, (5) title, reference, and summary of his or her published, relevant  :

scientific articles, papers, or books; also identify each person in terms of the subject matter of his or her testimony and the i r i

substance of his or her testimony.

Respectfully submitted, fM414 Aho eor R. Nygaar 'N 4 lM '

An N K. Morse .

Dated: September 18, 1978

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EEMTED CO;UlESpog.

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S E UNITED STATES OF AMERICA /f '4 l

. NUCLEAR REGULATORY COMMISSION

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W %Ygb...f WIE, _

,, p r 3 l In the Matter of ) Docket No. 5 -  % - -

) Amendment to i DAIRYLAND POWER COOPERATIVE ) Provisional Operating: -

I

) License No.-DPR 45 l' (La Crosse-Boiling Water'Heactor )

. CERTIFICATE OF SERVICE -

' Service has on this day been effected by personal ,

delivery or first class mail on the following persons: ,

Docketing & Service Section ,1 Ivan W. Smith, Esq.. Chairman Atomic Safety and Licensing Office of the Secretary ' 7, .

Board Panel U.S. Nuclear Regulatory- ,

U.S. Nuclear Regulatory Commission .

Commission Washington, D.C.. 20555 /

e Mr. Ralph S. Decker O. S. Hiestand, Esq'. .

Route 4 Morgan, Lewis & Bockius  :;l Box 190D 1800 M Street, N.W. .

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Cambridge, Maryland 21613' Washington, D.C. 20036 . ;'

d Dr. George C. Anderson Colleen Woodhead, Esq. ,3. -

CDepartment of Oceanography Office of Executive Legal d University of. Washington Director  ; j

' Seattle, Washington- 98195 U.S. Nuclear Regulatory *

Commission Washington, D.C. 20555 ,"

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/Geez%e V R. Nygaprd

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Dated: September 18, 1978 i