ML20147C770

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Forwards Third Round of Discovery Questions.Observes NRC Has Not Responded to First Set of Interrogs.W/Encl Request to Produce & Cert of Svc
ML20147C770
Person / Time
Site: 07002623
Issue date: 11/15/1978
From: Blum S
CAROLINA ENVIRONMENTAL STUDY GROUP
To: Ketchen E, Porter W
DUKE POWER CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 7812180399
Download: ML20147C770 (9)


Text

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}4 C'PUBLIC DOCUW RQO38 NE CAROUNA EN\\llRONMENTAL STLDY GROUL November 15, lj78;;,3 0,._

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Mr. William L. Porter Edward G. Ketchen

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Duke Power Compan7 llRC Staff Counsel N[

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h22 South Church Street Office of the Executive Legal D 9 to 9

e US iluclear Regulatory Commissio g

  1. g % s' M, Charlotte, NC 282h2 Washington DC 0555 gp.,,#

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Dear Mr. Porter and Mr. Ketchen:

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b Docket No. 70-2623 2

4 Herewith a third round of discovery questions in the indicated docket.

s taff-parties CESG is copying and petitioner with these questions and, in b

and staff the interest of expediting the proceeding, proposes that Duke, provide answers similarly. We request that your answers be posted no later than two weeks after the receipt of these questions, similarly in the interest of expediting proceedings.

We wish'to call to your attention thtt we have not yet received the accident test data referred to in your response of October 26 "which we will be able to provide by October 16, 1978". ilote that the.'IRC has not responded to the first set of interrogatories.

hh. Provide the reasons for the following shipments of Oconee spent fuel through North Carolina:

1-18-78 -Oconee to MW, Lynchburg, Va. via I-85 and US-29 1-25-78 1-28 -78 MW, Lynchburg, Va. to Oconee via US-29 and I-85 3-12-78 I-85

" US-29 3-lh-78 Oconee to MW; Lynchburg, Va.

ft ff Il 18 ft ft il II ft I-85

" US-29 "

3-28-78 MW, Lynchburg, Va. to oconee

" I-85

" US-29 h-21-78 Oconee to MW, Lynchburg, Va.

h5 What real property value does Duke assign to an Oconee spent fuel assembly? Is spent fuel assigned a negative salvage value? What effect j

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854 HENLEY PLACE C+4RLOTTE NORTH CAROLINA 98907 - (704) 375 4349 1

m, will the transfer' ~of spent fuel to McGuire from Oconee have on taxes paid locally in South Carolina and to the State?

What impact will the presence of.0 cones spent fuel at McGuire have on tax obligations to Charlotte, Mecklenburg County,. and the State of North Carolina?

h6. What have Duket s tax obligations for the Oconee plant been, all' levels in state,1973 to date? What, specifically, have been the taxes for unused nuclear fuel stored on site? What tax obligation does Duke anticipate for each assembly of unused fuel stored at McGuire? What in-state, i.e. city, does Duke county, and state tax obligations / anticipate for McGuire through 19837 Provide a comparison of valuation for tax purposes against a suitable reference value, replacement cost, "fdr Nue", market value; and tax rates for Seneca, Oconee County, South Carolina; Charlotte, Mecklenburg County, and North Carolina for the period 1973, 1978 inclusive.

j h7.. Provide a plan drawing of structures, roads, and terrain as relevant showing the present Oconee fuel storage structures, related buildings,

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and features said to limit fu:ther fuel storage construction at this site.

Provide a drawing of the entire Oconee site showing roads, structures, bodies of water, railroad tracks and such other features as would bear on the construction of additional fuel storage facilities.

hB. What capacity, in terms of number of assemblies, did Duke consider in its response to item h on October 26? What cost figures.has Duke specific-ally generated for the construction of new storage facilities by site, including site cost, preparation including roads, and catusponding tax obligation?

ho. Account for the e:ctremely large variation shown in beta /gaxta mR/hr, 5 to 125, at a' distance of 1", response 10, October 26, 1978. Was the radiation ; detector placed at the base of the cooling fin or at its farthest

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j extension? Was the same instrument used for all readings? When was the instrument calibrated? before reading?

after?

Was just one cask used?

Were a number of assemblics used, each of which has been stored 9.7 monbhs?

50. Provide copies of the correspondence, Duke /NRC, in which the NRC

-l indicated that the transport of fuel aged less than 270 days would not be j

i acceptable?

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51. In reference to the October 26 response to question h, what are the

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specifics in the cost compar1 son developed by Duke which would show that it is more economical to transport spent fuel to McGuire than to provide an independent spent fuel storage facility. Provide all assumptions made.

52. Provide the actual charges paid for the spent fuel shipments designated in question bh.
53. What are Duke's contingency plans for spent fuel storage after h-1-837 5h. Does Duke have any informatiod regarding tractor trailer accidents at the interchange from I-85 to I-777 If so, please provide.

Has Duke developed any plans or positions in regard to transporting spent fuel through this intersection?

55. What are the full particulars of the NRC quality assurance program for individual spent fuel casks? Does this program include malittenance and pretests before individual shipments? If so, provide full details.
56. In response to question 31, calculated radietion levels were provided for spent fuel at one meter in air from the axial center line at four fuel ages. Noting the factor 25 range of measured values, response 10, October 26,- what is the uncertainty of the numbers in response 317

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57 Referring to response 20, do the " current design standards" referred

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to apply to Duket s NSI-b casks? Wa't were the differences between the l

design standards referred to and those for the DOE test casks? Was the same, i.e. the identical cask used in each of the DOE tests?

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58. What was the c t for each NSF-h (NAC-1) cask purchased by Duke to date?

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What price information did Duke obtain for the cost of the cask (s) used in the DOE crash tests?

59.

Define regions of wear and/or fatigue in the repeated use of an NSF-b cask?. What program is in effect for monitoring physical changes in the cask?

What means are used to effect the s'eal of the borated water in the cask?

Is the spent fuel assembly in the cask immersed in water?

If so, is the water borated or otherwise modified? If so, what sealing system is employed?

60. Provide the mean cask temperature as a function of time for extreme 0

summer weather. Assume an ambient temperature of 100 F and full July solar rad'ation incidence for this solar region (SC/NC).~. Provide the temperature -

t1 function under similar conditions for the borated water. If the assembly 1

ater immersed, provide information as foregoing. What is the corresponding time-temperature function for the hattest fuel pellet; for the fuel rod sheath?

61. Wat steady state, maximum sheath temperature will be reached in a niel l

assembly in ambient air at 100 F which is subj ect only to natural radiative 1

and convective cooling?

62.

Describe each accident to date involving the motor transport of spent fuel giving time, place, driving conditions, and extent of whatever damages

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occurred.

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63. What. screening and testing is applied to drivers to be utilized?-

Wat minimum qualifications are imposed? Wat restrictions are placed on driver operation such as elapsed time since. lasb trip, sleep in the 2h hour period preceding the trip, continuous driving time in any trip segment, maximum driving time in any 2h hour period, condition in regard to drugs, intoxicants, physical tone, alertness, coordination, emotional state, etc.

6h. What is the estimated cost of the Catawba fuel pool and support facilities?

At what date.is it scheduled to be operable? What is its capacity for spent fuel assemblies? Is it compounded storage?

65. Wat means of communication are provided for drivers of spent fuel vehicles?

Is there a monitor to assure.a continuous communication capability? -

Is the transport crew a driver?

Is a relief driver or helper assigned?-

66. - What is the average mass of Pu-239 present in a representative spent fuel assembly? What is the mass of total radionuclides (excluding actinides)?

What is the mass of. volatile radionuclides? Historically, what percentage of Oconee fuel rods have been " leakers"?

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67. Describe the shielding provided for the driver; specify the radiation attenuation factor. What is the hourly dose rate? (270 day aged fuel)
68. What training is the driver given in regard to emergencios involving l

the leakage of radioactive materials?

69. What is the maximum internal pressure the cask is designed to maintain?

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. How, and how often, is the cask tested in regard to meeting this reqairement?

f Does this cask contaiqhrovisions for thermal expansion of contents?

If so,

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, describe. -

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70. Will escort vehicles be regularly provided the transport vehicle?

Are any of the personnel to be armed? If so, provide detail.

71. Provide detail in regard to escort or surveiLiance by state patrol cars of the shipments referenced in question bh.

72 Provide a copy of the analysis of NAC-1, Docket No. 71-6698 and NRC Certificate of Compliance No. 6698.

73.

Produce documentation of "four impact tests and a fifth test conducted in 1977 and 1978 by Sandia Laboratories", cf. first paragraph f$regoing.

7h.

State the proposed possible or estimated cost of (a) a new fuel pool at Oconee adjacent to the unit 3 pool; (b) a fuel pool at Oconee detached from the other pools but on the reservation. Provide a detailed estimate for each part of construction of the indicated pools.

75.

(A)

State the full cost of moving one loaded cask of Oconee spent fuel to McGuire breaking the total down into subpart costs for (a) removal from pool and placing in cask (b) placing cask on truck (c) truckage cost from Oconee to McGuire (d) unloading cask from truck and placing spent fuel assembly in McGuire pool (e) guards _ on tho truck (B)

State the number of cask loads Duke anticipates moving.

76.

(A)

Have Duket s NAC-1 casks undergone Appendix 3 testa?

(B)

If so, describe tests and results.

(C)

If not, why not?

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' 77.

(A)

Does Duke have emergency plans in the event of an accidInt in which an irradiated fuel containing cask is breached?

(B)

If so, provide these plans in complete detail.

'I S.

Provide cost / benefit of the alternatives considered in the matter of spent fuel.

79.

Has Duke considered sabotage as a mechanism for effecting release of some or all of the radioactive content of a spent fuel cask? If so provide the particulars.

80. To what extent is Duke relying on the federal government for help in the event 'of a cask accident?

For cleanup after an accident?

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81. To what extent is Duke relying on South Carolina and North Carolina state goverments in the event of a cask accident? For post accident cleanup?
82. What does Duke see to be the role of county an city goverments on the route in the event of an accident? In regard to cleanup?

8;. What insurance does Duke have against real damage in the event of m accident?

In the event of injuries?

Bh.

Is it' not true that the Interagency Review Group on the. Management of Nuclear Waste has taken a neutral position with regard to the future use of nuclegr generation?

Is it not true that the IEG mentions 1995 as the date at which it hopes to have a solution to the waste problem?

What does Duke plan to do with waste in..the interval 1983-1995?

Please send responses to both Jess Riley and Shelley Blum,

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UNITED STATES OF AMERICA-HUCLEAR REGULATORY COMMISSION in the Matter of

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DUKE POWER COMPANY

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(Amendment to Materials Lic-

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Docket No. 70-2623 ense SNM-1773 for Oconee Nuc-

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lear Station. Spent Fuel Trans-

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portation and Storage at Mc-

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Guire Neulear Station

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REQUEST TO PRODUCE To:

NRC and Applicant Produce at the addresses of Blum'and Sheely and of Jesse Riley, by mail:

(1) copies of the " June 2,1978 study" pertaining to the subject of cost and exposure estimates (the subject of an 11/7/78 note to files by B.S.

(2) all written clarifications of said study; and (3) all notes and calculations pertianing.to said study.

THIS IS A CONTINUING REQUEST.

Dated:

November /d,1978.

BLUM AND SHEELY by SHELCEY BLUM 418 Law Building 730 East Tra'de Street Charlotte, North Carolina 28202 (704) 376-6591 S

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%T4D Cor -...;,,..,

CERTIFICATE OF SERVICE I hereby' certify that copies of interrogatories and Request to Produce, se rved - upon dated November. 15, 1978 in the captioned matter, have been,h day of Nov-the following by deposit in the United States mall this 16t ember, 1978, Mr. Chase R. Stephens Docketing and Service Section

g8gggcy, cy Office of the Secretary-

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Q U.S. Nuclear Regulatory Commission

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gg7g Washington, D.C.

20555 7-William L Porter

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Duke Power Co.

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ed 422 S. Church St

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s Charlotte ilC 28242 s.

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Edward G. Ketthen Counsel for HRC Regulatory Staff Of fice of the Executive Legal Director ll.S. Nuclear Regulatory Commission Washington, D.C.

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~ JA4L SHELLEY BLUM

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