ML20147B544

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Intervenor Coulee Region Energy Coalitions 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)


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NUCLEAR REGULATORY _ COMMISSION g

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NRC PUBLIC DOCUMENT ROOM I

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In'the Matter'of

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Docket No.30-409

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Amendment.to Provisional' DAIRYLAND POWER COOPERATIVE'

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Operating License (Lacrosse Boiling Water Reactor)

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(Spent Fuel Pool) l

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INTERV5NOR COULEE REGION ENERGY C0ALITION'S INTERROGATORIES

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(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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These interrogatories are hereby expressly

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infor=ation is acquired through the time of the evidentiary

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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.

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of interrogatories is addressed to those cententions of the g

.I CRSC which are' 11sted in the Prehearing Conference Orders dated 4

1 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) has been " voided," including a description of all tritten and

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k 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

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

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terminate that contract.

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

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

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receipt by NFS of spent fuel fren the IAC3WR reactor.

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(a) Describe in detail each and every instance in which

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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

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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 4 l alternative to the compaction of spent fuel within the existing pool?

(b) If so, describe fully the physical details of.such an alternative, the financial cost, the environmental impacts, and l

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workers resulting from implementation of such an alternative..

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(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

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

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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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y on-site or off-site as an alternative to the compaction of spent jj

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

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referring to.this alternative.

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

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determination not to pursue this alternative.

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

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7 (a) Has the Applicant considered and analyzed the

'M possibility of implementing any other alternatives to the proposed

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-A (b) If so, describe such analysis and any written documents referring to such alternatives,

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

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s 8.

(a) In what' year, according to the Applicant's projections, t.

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.-

4 (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?

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(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

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

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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-6, would requh'e removal of spent fuel.

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(a) Assuming that 'there is no place to ship. spent fuel when the expanded capacity under the requested amendment has been v.

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

4i (b) Describe the environmental'and health and safety Ii implications of each such alternative, and. the financial cost of f

each such alternative.

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

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conclusion that none of the alternatives discussed in answering l

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

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(a) Identify and describe 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.

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

lc 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 -

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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 fr:

plant radwaste treatment system, g

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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

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}J Fuel Pool Cleanup System?

c 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.

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,.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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9 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 i

7 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 y)

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

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8) what a new reprocessing facility would cost the utilities

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

N 25 Describe in detail the operating and maintenance costs y

which would be involved in the storing of spent fuel on site

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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?

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(a) Describe in detail the manner in which the new spent q

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fuel racks will be moved into their final positions in the spent It

fuel pool' 1:

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(b) Indicate major equipment to be used, specific access g,

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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

'N eor R. Nygaar 4

lM An N K. Morse Dated:

September 18, 1978

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R\\g EEMTED CO;UlESpog.

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UNITED STATES OF AMERICA

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. NUCLEAR REGULATORY COMMISSION Ygb...f WIE,

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Docket No. 5

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Amendment to i

DAIRYLAND POWER COOPERATIVE

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Provisional Operating:

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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:

Ivan W. Smith, Esq.. Chairman Docketing & Service Section

,1 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

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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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1 Cambridge, Maryland 21613' Washington, D.C. 20036 d

Dr. George C. Anderson Colleen Woodhead, Esq.

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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 R. Nygaprd V

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Dated: September 18, 1978 i