ML20196F720

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Transcript of 880209 Hearing in Rockville,Md Re Spent Fuel Capacity at Plant.Pp 1-36.Related Documentation Encl
ML20196F720
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Site: Vermont Yankee Entergy icon.png
Issue date: 02/09/1988
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Atomic Safety and Licensing Board Panel
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UNn ED STATES l- NUCLEAR REGULATORY COMMISSION

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4 In the Matter of: )

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SPENT FUEL CAPACITY AT VERM01Tr )

YANKEE NUCLEAR PLANT )

Pages: 1 through 36 Place: Rockville, Maryland l

Date: February 9, 1988 i

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! UNITED STATES NUCLEAR REGULATORY COMMISSION

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~2 ATOMIC SAFETY AND LICENSING BOARD PANEL 3

4 In the Matter of:

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5 SPENT FUEL CAPACITY AT VERMONT YANKEE NUCLEAR-PLANT )

6 7 Tuesday February 9,19 88 8

U.S. Nuclear Regulatory 9 Commission 11555 Rockville Pike 10 1 Whtie Flint North 16th Floor, Room 11 11 Rockville, MD 20852 12 The above entitled matter came on for hearing,

( 13 pursuant to notice, at 10:09 a.m.

14 IS APPEARANCES:

16 On Behalf of Vermont Yankee Nuclear Plant:

17 DON REID DAVE McELWAY 18 JOHN DEVINCENTIS JOHN HOFFMAN 19 JAY THAYER CHRIS HANSEN 20 BOB CAPSTICK JOHN RITSHER 21 e

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APPEARANCES (Continued) 2 On Behalf of the State of Vermont:

3 PHIL PAULL 4 On Behalf 'of 'ne State of Massachusetts:

4 5

GEORGE DEAN 6 On Behalf of the' Nuclear Regulatory Commission:

7 VERNON ROONEY DICK'WESSMAN

, g .GUS LAINAS

. JACK KUDRICK 9 JERRY WERMIEL JOHN RIDGELY 10 ANN HODGDON JOE RUTBERG gj . BOB WEISMAN ASHOK THADANI 12 JOE SCINTO

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3 1 PR0CEEDINGS 2 MR. ROONEy: This is a meeting between the staff and 3 Vermont Yankee to consider information needed to complete the 4 4 staff's review of the Vermont Yankee spent fuel proposal.

5 It is a public meeting. We have public 6 representatives here presently and we may have some more, I 7 believe. The public is present as observers, not participants.

8 If members of the public have questions or comments, would you 9 hold them till the end, and I will try to deal with them if you 10 direct them to me, and we will try to do what we can, as we 11 usually do, to deal with tnose matters at that time.

12 But we want to focus today on trying to get as much 13 mileage and communications on resolving the longstanding fuel 14 pool proposal that we are dealing with.

15 The meeting's being transcribed, and, so, a 16 transcription will be issued fairly soon after the meeting. So, 17 if, when you have something to say, would you please identify 18 yourself for the reporter and, further, if those at the side of 19 the room, and there may be some participating, will come t

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20 forward, we will try to make way so you have access to a mike, 21 so you can be entered into the record. And, of course, don't 22 everybody speak at once.

23 I guess with these preliminaries, I would like to ask

( 24 Dick Wessman, my boss, if he has any comments, i

25 MR. WESSMAN: No, I don't, Vern. I think we have one l HeritageRegortingCorporation (20 ) 625-4888

1 4

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( 1 additional person that has come in. If you would identify A i 2 yourself, please? I 3 MR. DEAN: George Dean, Assistant Attorney General

. 4 for the Commonwealth of Massachusetts.

5 MR. WESSMAN: Okay. Glad to have you, George.

6 I would suggest to the Vermont Yankee folks, we may 7 lose at least a couple of managers around 11:00 because of 8 another commitment. If you have some -- you know, we want to 9 get the best part of your message at the front end of the 10 session and work technical details later.

11 You know, we will be here as long as we need to work 12 the problem, and, Ashok or Gus, do you have anything else that

('

13 you want to cover before we get started?

14 MR. THADANI: I don't.

15 MR. WESSMAN: Okay. Vern, let's go ahead and get on 16 with it.

17 MR. ROONRY: Okay. Well, I guess, Warren, you --

18 I'll turn it over to you for presentation of such information 19 as you have.

i 20 MR. MURPHY: Okay. I'll immediately lateral the  ;

21 football to Den Reid to give the introductory remarks and then 22 go on to John Hoffman.

23 MR. REID: Okay. I guess we'd first like to show you

(~ 24 the topics we intended to cover today, at least to start out.

25 We're going to provide an introductory statement.

Heritage (202 Re p)rting Corporation 628-4888

5 1 John Hoffman, to my right, is going to go 2 .specifically through your open items listed in your previous 3 letter or your last letter, and then we'll talk about where

$ 4 we're going to go from here, at least from our point of view, 5 and then hopefully we'll get into any discussions or questions 6 you may have at the end of our presentation.

7 MR. WESSMAN: Do you all have handouts that you're 8 going to be able to give to us to help us take notes and attach 9 to the transcript?

10 MR. REID: I don't believe so, other than --

11 MR. HOFFMAN: We can make copies of the viewgraphs 12 later.

(

13 MR. REIN: I guess we'll make copies of the 14 viewgraphs.

15 MR. WESSMAN: I think we'd like to get a copy of the 16 viewgraphs for the record.

17 MR. REID: Okay. I guess I'd like to start out by 18 saying we appreciate this opportunity to directly address the 19 outstanding technical issues and answer any questions you may 20 still have relative to our licensing request.

21 Our proposal is to gain your approval to expand the 22 storage capacity of our spent fuel pool from 2000 assemblies to 23 2870 assemblies, using a slightly higher density fuel rate than

(- 24 that which presently exists.

25 We wish to make it extremely clear today that it is Heritage(202 Rep)rting Corporation 628-4888 l

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e 1 our intent to finally resolve these outstanding issues to the k

2 satisfaction of the NRC staff, and to clarify any other areas 3 that still appear to involve some misunderstand 1ngs.

. 4 Our presentation today will provide you with a firm 5 basis upon which you can issue a timely and satisfactory safety 6 evaluation report and the accompanying amendments which would 7 identify no outstanding concerns.

8 In order to facilitate a conclusion to this long-9 active licensing effort, we wish to present a solution that 10 will, without question, address and satisfy all the outstanding 11 concerns. This solution is presented despite the fact that we 12 still fully believe and support the adequacy of our present

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13 license amendment request.

14 We wish to emphasize that our new proposed solution 15 is being offered solely to expedite and facilitate closure on 16 an issue critical to Vermont Yankee that has been pending for 17 almost two years.

18 In order to break this licensing logjam, we are 19 willing to make a major commitment that will clearly resolve 20 all the outstanding staff concerns. We are willing to commit 21 to design and install a completely redundant seismic fuel pool 22 cooling systen: prior to the time that we reach 2000 bundles 23 stored in the fuel pool, h- 24 This will have sufficient capacity to preclude any 25 concerns with the use of the residual heat removal system.

Heritage(202 Rep)rting Corporation 628-4888

7

, 1 At this time, there are many options available to 2 accomplish this design objective. Hence, the seismic fuel pool 3 cooling system could be a wholly new system or it could be a e 4 combination of some new components and modifications of some 5 existing sections of the system.

6 The final system design will comply with the 7 appropriate criteria of your standard review plan and, of 8 course, be available for your review and inspection at any 9 stage of the process.

10 John Hoffman, like I mentioned previously, will have 11 more to say about that as well as specifically addressing the 12 concerns ir. your January 21st letter.

13 As I indicated previously, this commitment is offered 14 in support for you to complete your review and issue a timely 15 safety evaluation report and the amendment.

16 Finally, we wish to make it clear that Vermont Yankee 17 continue <; to have a high commitment to operate and maintain the 18 safe nuclear power plant. This includes compliance with all 19 the applicable rules and regulations. We are available and 20 wish to fully be cooperative with the NRC in bringing this 21 issue to its conclusion.

22 We would be happy to address any questions following 23 the remaining presentations.

h- 24 John?

25 MR. HOFFMAN: John Hoffman.

Heritage(202 Rep)rting Corporation 628-4888

8 1 What we'd like to do is present a viewgraph that 2 shows the design criteria that we'll be using in the design of 3 the fuel pool cooling system that Don just mentioned.

1

, 4 The Seismic Category 1, safety class system. Seismic 4 5 Category 1, cooling system. Single active failure proof.

6 Detectors for loss of function and designed for the appropriate 7 licensing criteria, detection and isolation of leaks, flooding, 8 internal and external missiles, in-service testing, the 9 installation will have the appropriate considerations at the 10 time of the project as well as fire protection concerns.

11 As Don indicated, the design details have not been 12 worked out, but these are the criteria that will be used and

(- 13 would help in the following discussion of the open items to 14 keep those criteria in mind as we go through the open items and 15 show how the new system as well as the existing plan fully 16 complies with your open items.

17 Okay. What we have done is extracted from your 18 February letter the open items that you folks had at the back, 19 and we have broken them down into five open items. The first l

20 one relates to heat removal capability, and the items the NRC l

21 had questioned in that letter was the use of the 1971 ANS draft 1'

f 22 standard, the DK heat generation, questioned the basis for the l

23 9.1 million BTUs per hour that we used as a heat load, and an

(- 24 apparent discrepancy between the FSAR capacity of the heat 25 exchangers and the fuel pool cooling system and what we are Heritage (202 Rep)rting Corporation 628-4888

9 1 using in our evaluation.

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2 On Item'A, ANS draft standard, that was only used in 3 a specific scenario where we used it to calculate the decayed s 4 heat in the reactor vessel. All fuel pool heat loads are 5 calculated ir accordance with standard review plan 6 requirements.

7 In that particular scenario was a loss of fuel pool 8 cooling where we were going between cooling the reactor vessel 9 and the fuel pool with the RHR system. So, we don't believe 10 there is any conflict with your requirements in what we have 11 done in that evaluation.

12 The next slide, please. This slide is, for

( 13 information, a comparison of your heat load calculations which 14 came out of a response that you provided to an intervenor

! 15 interrogatory and our heat load calculations, and they are

( 16 essentially the same, within second decimal point.

17 I do not think there is any problem with how we're l

l l 18 calculating heat load and that it is in compliance with your i

19 requirements.

20 Next viewgraph, please. The following viewgraph is a 21 curve of heat exchanger performance as a function of days and 22 this is from an internal calculation that we've done and have 23 benchmarked several of the values that you folks have come up,

(- 24 and I think it explains our capacity situation.

25 The one bent, the top curve, with the square box, is Heritage(202 Rep)rting Corporation 628-4888

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.- 1 a one pump /one heat exchanger. We come up with essentially 2 seventy days for a 150 degree temperature limit in the pool.

3 You folks report sixty-nine days. So, we're right on track

= 4 there.

5 The second curve with the pluses is a one pump /two 6 heat exchanger mode of operation where the two heat exchangers 7 are valved la parallel and that produces at a 150 degrees a 8 ten-day heat removal capacity. The third curve is two 9 pumps /two heat exchangers.

10 In the scenario we used for evaluating use of RHR, 11 the 9.1 million BTUs per hour was an arbitrary assumption.

.. Unat it is is the capacity at ten days. It's the point at which

( ,: one pump /two heat exchangers would be capable of cooling the 14 fuel pool. We have committed that we would not operate the 15 plant without that capability. So, we took that as an upper 16 bound heat load.

17 In reality, the heat load would be significantly 18 less. We don't feel we could ever start the plant up ten days 19 following a refueling, that that was picked as an arbitrary 20 upper bound, as an adequate assumption for that evaluation.

21 The 2.23 million BTUs per hour is really the one 22 train /one pump /one heat exchanger capacity for a given set of 23 inlet conditions. The same calculation that was used to

(' 24 generate thcse data also produces the 2.23 million BTUs at the 25 appropriate operating conditions.

Heritage(202 Rep)rting Corporation 628-4888

11 1 So, all numbers are correct. It's just which point 2 you assume and what the different performance parameters of the 3 fuel pool cooling system is. So, we don't believe there are

, 4 any conflicts really with your requirements, the independent S evaluations you folks have performed.

6 Go back to.the first one?

7 MR. WESSMAN: Can we agree to that? We might as well 8 offer the comment, if we could. Do we have any problem with the 9 numbers that we see here, John?

10 MR. RIDGELY: I don't know that there's any conflict 11 because the 2.23 was what, as I was saying, the specific 12 conditions at match point. He did not calculate, recalculate 13 those specific conditions, but based on information that's 14 here, I would expect that those really are the -- that the 15 curve would go to that data point.

16 MR. HOFFMAN: In conclusion, then, we feel that your 17 opan items are clearly addressed by our current submittal and 18 certainly the new fuel pool cooling system would have the same 19 compliance with those requirements.

20 So, we would say that the first open item in your 21 letter is resolved.

22 Item 2 was identified as the temperature limit in the 23 spent fuel pool. Your concern was that there is no fuel pool

(- 24 temperature monitoring when the spent fuel pool cooling system 25 is not operating.

Heritage(202 Rep)rting Corporation 628-4888

12 1 Strictly speaking, that .. correct. The monitor for 2 fuel pool temperature is in the fuel pool cooling line and, 3 therefore, if both trains are not operating, there would be no

. 4 monitoring.

5 Your concern was with the fact that without a 6 monitor, we wouldn't know when to isolate the minera11zers, the 7 fuel pool system is not operating, there's no flow, therefore 8 there would be no need to isolate the mineralizers.

9 MR. RIDGELY: More than just the mineralizers is the 10 fact that you don't know when you get to a 150 degrees, you 11 have to enter your tech spec.

12 MR. HOFFMAN: Okay. I will -- let me correct that.

( 13 I mean, let me address that next.

14 The first concern was related to the mineralizers. We 15 have indicated in our letter we do have an alarm in the control 16 room at a 125 degrees. So, we know when the pool hits a 125 17 degrees. That's an administrative limit at which point the 18 plant would take corrective action to ensure we do not exceed 19 the 150 degree tech spec.

20 If, at any time, we found that one train of the fuel .

21 pool cooling system was inoperable, the licensee is committed -

22 to augmented monitoring, where they have an operator go up and 23 monitor the pool on a four-hour basis. So, we would all times 24 know the temperature and the trending of the pool within a

(}7 25 four-hour time period, essentially, and the heat-up rate is l HeritageRef)rtingCorporation (2o ses-dess

13 I such that we don't believe we'd ever be in a mode of exceeding 2 a 150 degrees without knowing it.

3 So, we feel we have appropriate actions although they

, 4 are operator actions. We at all times would know the 5 temperature of the fuel pool.

6 The new system being as its seismic and single 7 failure approval, there will always be flow through that 8 system. We'll always be monitoring the fuel pool temperature 9 during normal operation. The only time when that system might 10 be secured would be during a refueling, when the gates were 11 open, and we were on RHR, at which point there are other 12 monitors in the plant to also monitor the temperatures.

13 So, we feel that with the existing system, we have 14 that capability. With the new system, it's built right into 15 it, we would always know the temperature and be able to take 16 the appropriate actions.

17 MR. McELWAY: Excuse me, Don.

18 I just want to make it clear that the new system we'd 19 be installing for fuel pool temperature monitoring.

20 MR. HOFFMAN: You folks have any comment on that 21 before we leave it?

22 (No response.)

23 MR. HOFFMAN: The third item was the capability of

(- 24 fuel pool cooling fo.11owing a seismic event, and the questions 25 you folks had asked related to the fire water connection to Heritage(202 Rep)rting Corporation 628-4888

14 1 service water, alternate cooling piping for the cooling tower 2 cell, and the RHR service water to RHR cross-connect piping.

3 All those systems are seismic or are isolated in the

, 4 case of the service water from a non-seismic piping to a 5 normally-shut manual value. I think were we to proceed on this 6 basis, I think, although it would be necessary for you folks if 7 you wanted to come up to review the calculations, review the a system boundaries, we have all that information available.

9 with the new system, those particular connections and 10 that would not be required and would be resolved completely by 11 the installation of the new system.

12 MR. WESSMAN: I'm assuming the new system will meet

(- 13 all the EQ and all the rest of the criteria, whatever is 14 appropriate in the codes and standards.

15 MR. HOFFMAN: That is correct, yes.

16 MR. WESSMAN: Okay.

17 MR. HOFFMAN: Item 4 was the radiological 18 consequences of boiling. This was a potential operating mode 19 with the existing fuel pool cooling system, and your open items 20 essentially requested that we provide the assumptions and the 21 dose for on-site. We have that information available.

22 It was a very conservative analysis that our people 23 did. Essentially, they assumed the pool boiled for thirty

(- 24 days. They took the boil-of f rate as the maximum boil-of f which 25 was about 16.6 GPM, assumed that lasted for the entire thirty Heritage(202 Rep)rting Corporation 628-4888

l 15 1 days.

2 For the off-site dose, it was an assumption of a 3 ground level unfiltered release and that came out to about six

- 4 percent of the Part 20 requirements.

5 For the on-site dose, similar assumptions were made.

6 Thirty days, and there was no provision of supplied air for the 7 personnel on site for recovery. It was also a very small 8 fraction of Part 20.

9 And for the new system, there will be no pool, 10 potential pool boiling events and the whole issue becomes moot.

11 The fifth open item was a concern that you folks 12 expressed on the particular scenario we presented for

( 13 supplemental pooling in the event of loss of the normal fuel 14 pool cooling system by some external event, and the two items 15 that were asked were the capability of parallel heat exchanger 16 operation and your feeling that the number of operator actions 17 were more than you felt was suitable.

18 The heat exchangers can be tied together in parallel.

19 In reviewing for this meeting last night, I did notice there 20 was a sketch that we provided in the back of our letter that 21 didn't explicitly show that cross-tie. That may have been a 22 source of confusion, but, indeed, the heat exchangers can be 23 tied together in parallel.

(' 24 Our evaluation was a very conservative evaluation, as 25 I indicated earlier, on the heat load. We just took the upper Heritage(202 Rep)rting Corporation 628-4888

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, 1 bounds that the pool could ever be at with the fuel pool 2 cooling system in service and demonstrated that the operators 3 could handle that event. It was, I believe, six pump starts

, 4 and approximately twelve operator actions.

5 That was discussed with the operating staff. They 6 feel that is a reasonable sequence of events. In reality, the 7 numbers would be much lower than that because it wouldn't be 8 the situation with the 9.1 million BTUs in the pool anyway.

9 So, we feel that that is a suitable mode of operation 10 for an extremely unlikely off-normal event. However, once 11 again, the new system completely does away with that potential 12 of events and would never require that operation.

(- 13 So, once again, we feel that we can address your 14 concerns with the existing system and our new proposal makes 15 the issue moot.

16 With that, if there's any comments, I would be glad 17 to answer them.

18 MR. KUDRICK: I have a question relative to the 19 documentation.

20 Jack Kudrick, Compliance Systems.

21 You provided quite a bit of information in response 22 to some of the concerns that we did not have on the pumps and 23 so forth.

(- 24 Were you planning to document that at all, other than 25 in the transcript of this meeting?

Heritage(202 Rep)rting corporation 628-4888

17 1 MR. HOFFMAN: I don't think we'd be planning on it 2 now because our new system proposal, for the ones that are no 3 longer applicable with the new system, I don't see we'd be

- 4 documenting them in detail.

5 MR. KUDRICK: Okay. So, you're strictly relying on 6 your new system.

7 MR. HOFFMAN: That's correct.

8 MR. WERMIEL: If the new system then goes to almost 9 every issue, as you have said, so if that's what you frame the 10 documents in, then I don't think we see a problem with that 11 proposal resolving these, 12 MR. WESSMAN: Let me make that clear. I think it la would be appropriate as you come in with that description of 14 the new system that you at least reference back to the 15 questions of our letter of January 21st and indicate how this 16 issue is resolved because a couple of sentences or whatever it 17 takos, and then go on to the discussion of the new system.

18 MR. HOFFMAN: That's correct.

19 MR. WESSMAN: Rather than in a debate on an old 20 system that was not there, but at least, you know, build the 21 link for us and for the public record of how the new system 22 makes these issues moot.

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23 MR. HOFFMAN: Right. That would be -- that's our

( 24 plan. We wouldn't be submitting detailed calculations.

25 MR. ROONEY: Let me just clarify my understanding.

Heritage(202 Rep)rting Corporation 628-4888

18 1 The theory bu13et in our January 21st letter was 2 provision for essentia] fuel pool cooling in case of single 3 failure, and as I understood what you were saying, is that the

- 4 reliance -- without the new system now, your reliance on the 5 RHR in all situations, you felt, as you described in the 6 scenario, that was something that could be donc, correct, but 7 with the new system, it was going to be redundant and single 8 failure proof.

9 MR. HOFFMAN: That is correct.

10 MR. THADANI: Ashok Thadani.

11 Clarification and question about the issue of single 12 failure.

13 Can you describe what your intention is in terms of 14 the single failure to be considered? Are these some active 15 failures or would they be consideration of passive failures?

16 MR. HOFFMAN: Active failures.

17 MR. THADANI: Thank you.

18 THE REPORTER: I'm afraid we're going to have to ger l

19 people to come up here. It's just not that good in the back.

20 I'm sorry.

21 MR. ROONEY: If anyone wants to come up to talk, I'll 22 step aside and yield the right-of-way, so you can have access 23 to my mike.

(" 24 MR. McELWAY: Any other questions pertaining to the 25 questions in the letter?

Heritage (202 Re s)rting Corporation 628-4888

19-1 (No response.)

2 MR. McELWAY: The next item -- my name in David 3 McElway.

. 4 The next item on our agenda was future actions 5 Vermont Yankee foresees.

6 I've put together a time line to try tc indicate the 7 proposed schedule that Vermont Yankee has developed.

8 Certainly, the first item that we need to reach closure on is 9 the licensing approval.

10 Our next task will be to come up with a conceptual 11 design which is scheduled to be completed by the end of Cycle 12 14. At the completion of the conceptual design, as-built  ;

( 13 dimensions being taken, a detailed design change would be 14 developed and put through the normal review process, both at 16 Yankee Atomic and the plant, during which time, early purchase 16 of long lead time equipment would be established, with the 17 final detailed design completed by the end of Cycle 15, and the

18 installation of the entire design change to take place during 19 Cycle 16, such that it is complete and fully operational at the 20 end of Cycle 16.

21 And as indicated on the time line, that's the time 22 frame in which the spent fuel pool will have approximately 1978 23 spent fuel assemblies in the racks.

24 MR. WESSMAN: Help me out. This is Dick Wessman.

([k 25 Help me out, if you would. Are you in Cycle 14 now?

Meritage(202 Rep)rting Corporation 828-4888

20 1 MR. McELWAY: We're in Cycle 13 now.

2 MR. WESSMAN: And when -- can you throw in at least 3 an estimate of the date on a couple of those so that we have a

. 4 feel of the number of years in the future that --

5 MR. McELWAY: Certainly.

6 MR. WESSMAN: -- you kind of estimate these things to 7 occur?

8 MR. McELWAY: Certainly. We're currently in Cycle 9 13, which is scheduled to end April 1st of 1989. The 10 conceptual design -- and these are the projected dates based on 11 our current schedules.

12 The Cycle 14 is scheduled to be completed in

( 13 September at 1990, and Cycle 15 is scheduled to be completed in 14 April of '92, and Cycle 16 is scheduled to be completed in 15 October of '93.

16 MR. WESSMAN: Thank you.

17 MR. McELWAY: And that brings us to the last item on 18 our agenda for today, which is a summary, and Warren?

19 MR. MURPHY: Okay. A very brief summary.

20 That is the extent of our presentation. It's rather l

21 brief, but I think you have heard a very significant commitment l 22 on our part.

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23 Let me say that we're extremely anxious to resolve

({- 24 the NRC staff concerns in our submittal. We made our submittal 25 in April of 1986. It's been almost two years. We think far too Neritage(202 Rep) rting Corporation 828-4888

b 21 1 Iong a time period to resolve this particular issue.

2 During that two-year time period, we've had to incur 3 significant expenses to make alternative plans and provisions 4 for the spent fuel that we'd generate. If we're going to spend S any more money on this project, we want to spend it in a more 6 meaningful way than in the short-term interim solutions, and 7 that's why we're willing to commit to make this very a significant commitment to additional fuel pool cooling system.

9 And we do it with the, first of all, notion that we 10 still believe that the submittal that we made two years ago was 11 valid, that we can technically defend our submittal and our 12 plans. However, we're willing to go one step further to 13 alleviate the looming concerns that apparently you have that we 14 can't make go away otherwise.

1: Either you're not listening or we're not speaking 16 correctly, and I think maybe I sense a little bit of both.

17 But, in any event, we're more than willing to make

~

18 this commitment and hope that it does solve your concerns, that 19 we can get some sort of a verbal commitment from you folks 20 today that, in your opinion, in fact, does address all of these 21 concerns.

22 And I think by doing this, we will avoid prolonging 23 the debate and the continuing analyses and so forth to try to i 24 prove fine points. We're willing to give up that approach and 25 solve the problems in one fell swoop here.

Meritage Re m rting Corporation (202) eas-4 ass

22 1 So, with that, that's all we have to say today. We 2 certainly would like to have your reaction, if you have one, 3 and look forward to an SCR at the nearest possible opportunity.

. 4 MR. WESSMAN: Why don't we seek to explore whether, 5 .in the room here, do we think that we have questions that we 6 need to explore to see whether it resolves our concerns and 7 then perhaps we need to chat for a moment amongst ourselves and 8 try and develop a scenario of the activitics that we would have 9 and you would have in the next, you know -- that meets with 10 your fucI cycles and our review of the documentation that would 11 be appropriate.

12 John, do you and Jerry, what are your thoughts on how C.. 13 this wou]d resolve the concerns that we've raised?

14 MR. WERMIEL: My thinking is that their commitment 15 conceptually and the criteria that identified it would satisfy 16 our concerns.

17 MR. RIDGELY: I have a question. Is there any 18 particular reason why you're going to wait on conceptual design 19 until Cycle 147 20 MR. REID: Just because this year is pretty well 21 already accounted for and the resources are assigned. We'd 22 have to divert them to already planned and on-going activitics.

23 MR. RIDGELY: So, you're saying then, in essence, l- 24 that you won't have the resources until after April of '89 to 25 really start working on this?

Heritage(202 Rep)rting Corporation 628-4888

23 1 MR. REID: Yes. To the next sphere. We're already f

2 budgeted and work and everything else has alread/ begun for 3 '88. We wou'.d have to significantly interrupt that.

. 4 Based on the schedule and when we really need the 5 racks, which is what our amendment calls for above 2000, there 6 doesn't appear to be a need to do it.

7 MR. WESSMAN: I'm under the -- excuse me. Do you 8 have another question?

9 MR. WERMIEL: No.

10 MR. UESSMAN: I guess I'm under the impression, 11 Warrsn, from chatting with Vern that as an interim basis, you 12 would have to do some modification to the existing racks to get 13 you a)) through the next two-three cycles, is that correct?

14 Can you address that for me or hcip me out on that?

t 15 MR. MURPHY: Well, our plans are that we can go ahead 1

16 and install the new racks, and the thing that we will not do 17 before wa install the new system is exceed the capacity 2000 18 fuel annombly.

l i 19 We've designed and are building new racks that we're i

! 20 ready to install this year. First of all, don't confuse our

. 21 completion date of the new system with the point in time when 22 we need the new racks. We need the new racks considerably 23 before that because the problem we have is getting the new f 24 racks in with the amount of fluid we have in the pool.

25 That is, we have less than 2000 assemblies in the Heritage(202 Rep)rting Corporation 623-4888

1 l

24 1 pool now, with a limited amount of space to get new racks in, 2 to shuffin the fuel from old racks to new racks. We can't go 3 up to the 2000 limit and then install the new racks. We have to

, 4 do that considerably before that.

5 So, what we're seeking here is the okay to go ahead 6 and install the new racks. However, the constraint on us is to 7 not exceed 2000 fuel assemblies in that pool until such time as 8 we have that new system installed.

9 MR. WESSMAN: Okay. So, one of the things that you 10 need agreement from the staff on then is your plan to go ahead 11 and put in the new racks as this Interim measure, --

12 MR. MURPHY: That's right.

k 13 MR. WESSMAN: -- getting you to 2000.

14 MR. MURPHY: Yes.

15 MR. WESSMAN: And another thing that you need is an 16 agreement from the staff on the conceptual design. I'm 17 separating the twe major activities then, is that right?

18 MR. MURPHY: Well, I don't know. Well, the two 19 different issues. We're hoping that you give us the okay to 20 put a new rack on the basis of the commitment to install the 21 new system with the design criteria that we outlined.

22 I guess we have to determine yet to what extent you 23 want to review the design as we go along in terms of looking at (1 + 24 the conceptual or waiting till the final design. Certainly it 25 will be there and available to you to review.

Meritage(202 Rep)rting Corporation 628-4888

25 1 MR. WESSMAN: Okay.

2 For the record, we have just added one more guy to 3 the gathering. This is Joe Sointo from OGC.

4 MR. SOINTO: Not for long.

5 MR. WESSMAN: Not for long.

6 MR. ROONEY: Are there any other questions that we 7 have for the licensee?

8 I think this is the next step to be sure we 9 understand all the facets of what's been proposed.

10 MR. WESSMAN: Are there any other questions you all 11 have of us because then I think we will break up in caucus for 12 a moment and then offer some thoughts to you?

13 MR. REID: I guess our basic question is how do we 14 get here to the end?

15 MR. ROONEY: For . Toe's benefit, since he just came 16 in, I think - you want me to - okay. You pretty much know i

17 where we are. We junt completed the final questioning to 18 confirm our understanding.

19 MR. PAULL: Vern, could I ask a question?

20 MR. ROONEY: Phil, could you wait till the end? T'd 21 like to get these matters dealt with first, please.

22 Okay. Thank you. Would you hold it till after wi= get 23 these things wound up?

b 24 Ashok, do.you have --

75 MR. THADANT: I have no acre questions.

Meritage Peperting Corporation (nor) sea-4ess

26 1 MR. ROONEY: You have no more? Well, perhaps we 2 ought to take a break at this time. We'd like to caucus and 3 consider what we've heard. We may have additional questions

. 4 following.

4 5 7 think the best way would be or you guya to take a 6 rest room break at this point.

7 MR. WESSMAN: You guys go to the cool space. Let's 8 go off the record, please.

9 (Whercupon, a recess was taken.)

10 MR. ROONEY: Do we have present everyone we need?

11 MR. MURPHY: You got the guy who can sign the SER, 12 Vern?

(.' 13 MR. ROONEY: We aren't that far.

14 We are in agreement that what ';au've presented deale 15 with the technical innuen which we c.a d identiff;d as the

(~

16 unresolved technical issues in ou" letter to you, and, f urt2;er, 17 technically, we're able to react very positively to what you've 18 told us as being substantial enhancement and very good.

19 As you might appreciate, we probably have yet to work 20 out and were unab2e to quickly work out the procedural aspects l

l ,

21 of these matters.

22 7 guess that. =s you know, we proceeded fairly far 23 along wi th our re'rse.? in the process on the Proposed 2870 with

( 24 these NES racks, and we have -- we are at a point that we 25 expect that we -- if you come in with a proposal, the thing you Meritage(2n2Rep)wting 823-4888 Corporation

27 1 have given us in this meeting, in writing, we'd expect you to 2 submit this in writing, we would expect to be able to fairly 3 shortly issue the aspects that we have reviewed already and

. 4 document them.

5 Now, we have the bulk thermal hydraulic 6 considerations that your enhanced fuel pool cooling system 7 deals with. We understand that the details of that's not going 8 to be worked out until the end of Cycle 14.

9 We see a second submittal from you when you have 10 that.

11 MR. MURPHY: Excuse me. Tn terms of our language, --

12 MR. ROONEY: Yeah.

( 13 MR. MURPHY: -- is that -- are we talking about the 14 conceptual design phase of this new system? Is that what in you're saying?

16 MR. WESSMAN: Yes, Warren. I think you are.

17 r,pr me summarize how I think the flow of paper is 18 likely to happen, if I may butt in on you for juni a necond, 19 please.

20 MR. ROONEY: Certainly.

21 MR. WESSMAN: After you all go home from this session 22 today, what we're suggesting that you do in you come back to us 23 with the request that basically, to some degree, modifies the i 24 amendment requent that you have on the books today because that 25 it' an amendment request taking up to the 2800 number of fuel MeritageReE)rtingCorporation (so sas-4ess

J-i 28 1 assemblies and based upon originally the existing system that 2 you have.

3 You need to tell us that you're headed in a different

. 4 direction with giving some indication of the criteria and the 5 concept of the mod:fied system, which is pretty much what 6 you've said to us t3 day, and that in the interim, you expect to 7 use the new fuel racks up to the 2000 capacity to carry you 8 forward until you've completed the work on the new system and 9 you have staff apprGval on the new system.

10 I think that's a Jetter that relatively easy you can 11 send to us in the not- to-distant future.

12 Now, the next step then from us is a response and the

( 13 evaluation we've done on the rack design that we've done for 14 your 2800 fuel assembly proposal, we're essentially done with 15 that. So, c. courso, we should be able to respond back to you 26 in a timely canner allowing you to get on with putting in the 17 ratks to carry you forserd for the next couple of cycles while la the rest of the work goes on.

19 The only potentially untidy aspect of that is, it may 20 require a resholly because you are now doing a rack activity 21 that is different than a rack and spent fuel cooling system 22 activity.

23 We don't know the answer to that today, but you see,

( 24 you are proceeding down slightly a different path than was 25 originally done, and I just don't know how that will go.

HeritageRef)rtingCorporation (2o sas-4ses

29

, 1 Then, some time in the future, I guess it's on your 2 cycle 14 that you say is when you would actually come with us 3 with essentially the details of your conceptual design, a year

. 4 and a half from now, whenever you've got that conceptual 5- design, and that's when we should be able to, based upon that 6 reasonably good knowledge of that conceptual design, we would 7 expect probably to get pretty well done with the SER process on 8 that, which then gets you in a position to go forward, 9 MR. MURPHY: Okay. Let me say something about that, 10 if I can.

11 Our plans are to design and install n new system 12 under 5059 and it's our opinion that it doesn't require a 13 license amendment to do that.

14 We will submit the design to you, if you ask to look 15 at it, but we don't see that as a requirement if we do it on 16 the 5059.

17 MR. WESSMAN: Okay. When you say the design of the 18 system, what do you mean by "design of the system"? Are you 19 talking about the entire additional train that you're talking 20 about, the concept?

21 MR. MURPHY: Yes, yes. We see that design 22 modificacion as being done under 5059 and not requiring the 23 tech spec change or a license amendment, l- 24 MR. WESSMAN: Okay. I'm not sure that va agree with 25 you at this point in time. I think our perception was that Heritage(202 Rep)rting Corporation 628-4888

sc 30 1 that would involve the amendment process.

2 MR. MURPHY: Okay. What's the basis for that? Why do 3- you feel that way?

. 4 MR. WESSMAN: Well, I think it's -- of course, one, 5 we're a little bit talking on something that's going to come 6 because you're talking a conceptual configuration, and I guess i

7 we don't know enough about your conceptual configuration and 8 how it may or may not tie into the plant as designed and as 9 reviewed.

10 I think early in the session, we talked about using 11 some portions of the old system or a wholly new system. I 12 don't think -- you know, you don't know or we don't know 13 exactly how it ties in, but it sounds like it's going to have 14 some relation to the plant as designed, as originally reviewed, 15 and that would move it into our review spaca.

16 Am I saying it right, technical folks? Help me out.

17 MR. MURPHY: It's not necessarily true.

18 MR. THADANI: I think -- it seems to me that the 19 termination of 5051 is up to you. You make that decision. You 20 can make a modification under 5059. We may or may not agree 21 with you, and at this stage, at least, I can't say for sure g 22 that we believe there is an unreviewed safety question,  ;

23 therefore you must come in with a submittal. I don't think we i 24 know the answer, at least I don't.

25 Does anybody else want to comment on that?

Heritage(202 Rep)rting Corporation 628-4888

31

, 1 MR. WEISMAN: Well, 2Dok, maybe I can be perfectly 2 clear here.

3 What we're trying to say is, at least from today's

. 4 meeting, we believe from a technical point of view, your i

5 submittal can be justified for fuel stcrage up to 2000 6 elements. That's v' hat we think.

7 For storage up to 2800 elements, I believe, which is l l

8 what you'd like to have in the future, it's dependent on a new i

9 design. So, the exact legal procedures, what you follow from 10 here on'in, is still under discussion by us, but as far as the II 5059, I got one question for you.

12 Do you have a license condition now limiting the

( 13 number of elemento you can store on site, fucI clements?

14 MR. MURPHY: That's right.

15 MR. WEISMAN: WeII, if you go to 2800, it would seem 16 to me that that would require some sort of an amendment.

17 MR. MURPHY: Oh, it -3oco, and we've applied for that.

18 That's what we're 19 MP, WEISMAN: The approval that we would give you at 20 this stage of the game would be to 2000 elements. That's what 21 we're trying to tell you. All right. We understand your I 22 criteria for future expansion under the system, and we think 23 it's a good criteria, all right, but how you get there for the i 24 final resolution of.the 2800 from a legal point of view as was 25 said by Vern and all, it may need a renotice or resholly, i

i Heritage Reprting Corporation (202) 828-4888

32 1 We haven't determined that.

2 MR. MURPHY: Okay. Fair enough, and we may conclude, 3 in fact, it'needs a license submittal or amendment.

. 4 MR. WEISMAN: Right.

5 MR. MURPHY: The other thing I wanted to make clear 6 in that our plans, if you agree with this, when we install the 7 new racks, we want to install,-for a number of reasons, we want 8 to install the capacity of 2870, but be limited to a use of 9 2000.

10 MR. WEISMAN: Right.

11 MR. MURPHY: Okay. Is that clear 7 12 MR. WESSMAN: Okay. I understood that clearly.

13 You're saying if you do work on the racks in the next 14 six months, the next year or two, you want to install all the 15 way to 2870, but have the limita tion of use to 2000.

16 MR. MURPHY: That's right.

17 MR. WESSMAN: So that, basically, you've finished 18 that portion of the work for the romprehensive change that you 19 want.

20 MR. REID: We aircady have the limit to use of 2000.

21 MR. WESSMAN: I understand. We're going to have to 3 22 think on that. I'm not sure we fully appreciate it exactly 23 because I thought you were actually going to modify a corner of 24 the pool to get yourselves up conveniently to 2000 and in a 25 sense, it may be that the license ccndition is all it takes.

Heritage(202 Rep)rting Corporation 828-4888

33 1 But let's think on that. I don't think I can answer i

2 that today, but I understand what you're saying.

3 MR. MURPHY: It's a just more much efficient way to

. 4 do the job.

5 MR. WESSMAN: Certainly. I understand that. Okay.

6 MR. THADANI: I don' t see -- does anyone see any 7 problem with that? At least I don't.

8 MR. WERMIEL: No. I was going to say --

9 MR. RIDGELY: Not from a technical standpoint.

10 MR. WERMIEL: Not from a technical standpoint.

11 There's no prob 1cm with that.

12 MR. WESSMAN: Okay. Well, maybe we have our answer.

13 We want to think a little bit and be sure that we're 14 comfortable with that just by virtue of you have a capability 15 to do more than the license says, and yet you are bound by what 16 the license s.iys, and yet is there some other issue about a 17 heavy load over another one of these racks somewhere e]rie, but 18 it sounds like we're saying it's okay.

19 Okay. What cise? You had another question on what we 20 started to say or did you finish summarizing, Vern?

21 MR. MURPHY: I made the two points that I wanted to 22 make.

23 MR. ROONEY: You made the -- okay. Very good.

4 24 So, I think we would expec t a submi t tal shortly af ter 25 this meeting from you, putting on the record what you have told HeritageRef)rtingCorporation (so s2s-4ses

34 1 us.

(

2 We intend to issue a safety evaluation covering those 3 portions of the review we've completed to this point shortly.

- 4 We would expect you to provide further detail on the new system 5 when you've reached the point that you can speak more 6 specifically to it, and I guess we would like that in the form 7 of a submittal at the end of conceptual design.

8 Am I speaking correctly for the staff here?

9 MR. MURPHY: Okay. Regardless of the determination 10 of 5059 and the license amendment?

11 MR. WESSMAN: That's the determination that's 12 described in your schedule.

13 MR. ROONEY: Yeah. We have yet to work out the 14 procedural aspects.

15 Staff, have I let anything major out? I hope not.

16 MR. WESSMAN: Any other thoughts, Warren, at this 17 time?

18 MR. MURPHY: Again, I just want to be clear that if 19 we give you our proposal in writing, basically tell you in 20 writing what we told you today, the result of that will be an 21 SER that would allow us to install the new racks?

22 MR, WESSMAN: That's our expectation.

23 MR. ROONEY: I guess this completes the matter we I 24 sought to accomplish in this meeting.

25 Now, I think that we ought to -- I'm open to Heritage(202 Rep)rting Corporation 628-4888

35 1 questions from members of the public or commento at this point, 2 and we'll do what we can to answer them, as we said.

3 MR. WESSMAN: And, John', do you or Phil have anything

. 4 else you wanted to ask the staff at this time?

5 MR. RIDGELY: No. I have a question, but I've had it 6 answered.

7 MR. ROONEY: Okay. Very good. Joe?

8 MR. DEAN: The only question I have -- George Dean.

9 THE REPORTER: The gentleman has got to come up.

10 MR. DEAN: Would be whether the staff intends to do a Il new environmental impact statement with respect to this new 12 proposal in consideration of the alternatives.

( 13 It seems to me that this is an entirely new proposal 14 Lu get the 2800 on the floor, which is going to involve an 15 additional substantial sum of money being expended, i

1 16 MR. WESSMAN: Okay, I don't know that the staff has 17 decided how to do the environmental aspect. We've got your 18 queution and let us think on it.

l 19 MR. SOINTO: Yeah. I -- let me interject. It's our l

20 position that we have it. It is not necessary to do an 21 environmental impact statement for the application we sought.

22 We've been doing an environmental impact appraisal. I would be 23 surprioed if this change changed that basic position. I would b 24 be surprised to see us do an environmental impact appraisal on 25 this, but in view of the position we took in the proceeding, I Heritage(202 Rep)rting Corporation 628-4888

36 1 would be surprised to see us do an environmental lupact 2 statement.

O-3 MR. DEAN: That answers my question.

. 4 MR. ROONEY: Are there further questions?

5 (No response.)

6 MR. ROONEY: Meeting adjourned.

7 Thank you for coming in.

8 (Whereupon, at 11:30 a.m., the hearing was t

9 adjourned.)

10 11 12 (f

13 14 15 16 17 18 19 l 20 21 22 23

(- 24 25 Heritage Reporting Corporation (202) 628-4888

l 1

l REPORTER'S CERTITICATE i 2  !.

3 DOCKET NUMBER: 1 4 CASE TITLE: Spent Fuel Capacity at Vermont' Yankee Nuclear Plan i

5 HEARING DATE: February 9', 1988 e 6 LOCATION: RockVille, MD 7

I hereby certify that the proceedings and evidence 8

are contained fully and accurately on the tapes and notes i I

9 reported by me at the hearing in the above case before the l 10  !

United States Nuclear Regulatory Authority. i 11 -

12  ;

I 13

(. . Date: 2-9-88 u -

l lE  ;

. t 16 ggg {

Official Reporthz l l' ,

gg HERITAGE REPORTING CORPORATION j 1220 L Street, N.W. j gg Washington, D.C. 20005  !

4 j 20 1 ,

21 l i;

22 1 23 ,

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! HERITAGE REPORTING CORPORATION (202)623-4358

. . . . . - ~ . . .

my L 'J,

.. a\A _

UNntU STATES c NUCLEAR REGULATORY COMMISSION In the Matter of: )

)

SPENT FUEL CAPACITY AT VERMONT )

YANKEE NUCLEAR PLANT )

Pages: 1 through 36 Place: Rockville, Maryland Date: February 9, 1988 Heritage Reporting Corporation Officiel Reporters 1220 L Strut. N.W.

Wun:agton. D.C. 2000$

1202)62 M

1 i UNITED STATES NUCLEAR REGULATORY COMMISSION

(.

2 ATOMIC SAFETY AND LICENSING BOARD PANEL 3

4 In the Matter of: )

)

$ SPENT FUEL CAPACITY AT VERMONT YANKEE NUCLEAR-PLANT )

6 7 Tuesday February 9, 1988 8

U.S. Nuclear Regulatory 9 Commission 11555 Rockville Pike 10 1 Whtie Flint North 16th Floor, Room 11 11 'j Rockville, MD 20852 12 The above entitled matter came on for hearing,

(' 13 pursuant to notice, at 10:09 a.m.

14 15 APPEARANCES:

16 On Behalf of Vermont Yankee Nuclear Plant:

17 DON REID DAVE McELWAY 18 JOHN DEVINCENTIS JOHN HOFFMAN 19 JAY THAYER CHRIS HANSEN 20 BOB CAPSTICK JOHN RITSHER 21 22

. 23

(~ 25 Heritoge Reporting Corporation m-

2 s

APPEARANCES (Continued) k 2 On Behalf of the State of Vermont  ;

PHIL PAULL

[* 3 4 On Behalf of the State of Massachusetts:

5 GEORGE DEAN 6 On Behalf of the Nuclear Regulatory Commission: ,

7 VERNON ROONEY DICK WESSMAN g GUS LAINAS JACK KUDRICK 9 JERRY WERMIEL ,

JOHN RIDGELY 10 ANN HODGDON JOE RUTBERG l 3g BOB FEISMAN ASHOK THADANI 12 JOE SCINTO

( 13 14 15 16 17 18 o

19 20 l 21 i e i 22 l l

23 t

24

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25 i

Heritage Reporting Corporation l

< = > -  ;

3 PROCEEDINGS

{ 1 2 MR. ROONEY: This is a meeting between the staff and

(- 3 Vermont Yankee to consider information needed to complete the

. 4 staff's review of the Vermont Yankee spent fuel proposal.

5 It is a public meeting. We have public 6 representatives here presently and we may have some more, I 7 believe. The public is present as observers, not participants.

8 If members of the public have questions or comments, would you 9 hold them till the end, and I will try to deal with them if you 10 direct them to me, and we will try to do what we can, as we 11 usually do, to deal with those matters at that time.

12 But we want to focus today on trying to get as much 13 mileage and communications on resolving the longstanding fuel 14 pool proposal that we are dealing with.

15 The meeting's being transcribed, and, so, a 16 transcription will be issued fairly soon after the meeting. So, 17 if, when you have something to say, would you please identify 18 yourself for the reporter and, further, if those at the side of 19 the room, and there may be some participating, will come 20 forward, we will try to make way so you have access to a mike, 21 so you can be entered into the record. And, of course, don't 22 everybody speak at once.

23 I guess with these preliminaries, I would like to ask

( 24 Dick Wessman, my boss, if he has any comments.

25 MR. WESSMAN: No, I don't, Vern. I think we have one t HeritageRef)rtingCorporation (zo s2s-4ses

4 1 additional person that has come in. If you would identify 2 yourself, please?

4 3 MR. DEAN: George Dean, Assistant Attorney General

, 4 for the Commonwealth of Massachusetts.

5 MR. WESSHAN: Okay. Glad to have you, George.

6 I would suggest to the Vermont Yankee folks, we may 7 lose at least a couple of managers around 11:00 because of 8 another commitment. If you have some -- you know, we want to 9 get the best part of your message at the front end of the 10 session and work technical details later.

11 You know, we will be here as long as we need to work 12 the problem, and, Ashok or Gus, do you have anything else that

(

13 you want to cover before we get started?

14 MR. THADANI: I don't.

15 MR. WESSMAN: Okay. Vern, let's go ahead and get on 16 with it.

17 MR. ROONEY: Okay. Well, I guess, Warren, you --

18 I'll turn it over to you for presentation of such information 19 as you have 20 MR. MURPHY: Okay. I'll immediately lateral the 21 football to Don Reid to give the introductory remarks and then 22 go on to John Hoffman.

23 MR. REID: Okay. I guess we'd first like to show you (r 24 the topics we intended to cover today, at least to start out.

25 We're going to provide an introductory statement.

Heritage(207 Rep)rting Corporation 628-4888

5 1 John Hoffman, to my right, is going to go 2 specifically through your open items listed in your previous 3 letter or your last letter, and then we'll talk about where

. 4 we're going to go from here, at least from our point of view, 5 and then hopefully we'll get into any discussions or questions 6 you may have at the end of our presentation.

7 MR. WESSMAN: Do you all have handouts that you're 8 going to be able to give to us to help us take notes and attach 9 to the transcript?

10 MR. REID: I don't believe so, other than --

11 MR. HOFFMAN: We can make copies of the viewgraphs 12 later, k

13 MR. REID: I guess we'll make copies of the 14 viewgraphs.

15 MR. WESSMAN: I think we'd like to get a copy of the 16 viewgraphs for the record.

17 MR. REID: Okay. I guess I'd like to start out by 18 saying we appreciate this opportunity to directly address the 19 outstanding technical issues and answer any questions you may 20 still have relative to our licensing request.

21 Our proposal is to gain your approval to expand the 22 storage capacity of our spent fuel pool from 2000 assemblies to l' 23 2870 assemblies, using a slightly higher density fuel rate than

(' 24 that which presently exists.

25 We wish to make it extremely clear today that it is l

Heritage(202 Rep)rting Corporation i

628-4888 1

6 1 our intent to finally resolve these outstanding issues to the 2 satisfaction of the NRC staff, and to clarify any other areas 3 that still appear to involve some misunderstandings.

. 4 Our presentation today will provide you with a firm 5 basis upon which you can issue a timely and satisfactory safety 6 evaluation report and the accompanying amendments which would 7 identify no outstanding concerns.

8 In order to facilitate a conclusion to this long-9 active licensing effort, we wish to present a solution that 10 will, without question, address and satisfy all the outstanding 11 concerns. This solution is presented despite the fact that we 12 still fully believe and support the adequacy of our present

( 13 license amendment request.

14 We wish to emphasize that our new proposed solution 15 is being offered solely to expedite and facilitate closure on 16 an issue critical to Vermont Yankee that has been pending for 17 almost two years.

18 In order to break this licensing logjam, we are 19 willing to make a major commitment that will clearly resolve 20 all the outstanding staff concerns. We are willing to commit 21 to design and install a completely redundant seismic fuel pool c

22 cooling system prior to the time that we reach 2000 bundles 23 stored in the fuel pool.

(- 24 This will have sufficient capacity to preclude any 25 concerns with the use of the residual heat removal system.

Neritage(202 Rep)rting Corporation 628-4888

7 1 At this time, there are many options available to

(

2 accomplish this design objective. Hence, the seismic fuel pool 3 cooling system could be a wholly new system or it could be a

. 4 combination of some new components and modifications of some 5 existing sections of the system.

6 The final system design will comply with the 7 appropriate criteria of your standard review plan and, of 8 course, be available for your review and inspection at any 9 stage of the process, 10 John Hoffman, like I mentioned previously, will have 1

11 more to say about that as well as specifically addressing the 12 concerns in your January 21st letter.

i 13 As I indicated previously, this commitment is offered 14 in support for you to complete your review and issue a timely 15 safety evaluation report and the amendment.

16 Finally, we wish to make it clear that Vermont Yankee 17 continues to have a high commitment to operate and maintain the 18 safe nuclear power plant. This includes compliance with all 19 the applicable rules and regulations. We are available and 20 wish to fully be cooperative with the NRC in bringing this 21 issue to its conclusion.

22 We would be happy to address any questions following 23 the remaining presentations.

( 24 John?

25 MR. HOFFMAN: John Hoffman.

HeritageReE)rtingCorporation (so sas-4ses

8 1 What we'd like to do is present a viewgraph that 2 shows the design criteria that we'll be using in the design of 3 the fuel pool cooling system that Don just mentioned.

. 4 The Seismic Category 1, safety class system. Seismic 5 Category 1, cooling system. Single active failure proof.

6 Detectors for loss of function and designed for the appropriate 7 licensing criteria, detection and isolation of leaks, flooding, 8 internal and external missiles, in-service testing, the 9 installation will have the appropriate considerations at the 10 time of the project as well as fire protection concerns.

11 As Don indicated, the design details have not been 12 worked out, but these are the criteria that will be used and

( 13 would help in the following discussion of the open items to 14 keep those criteria in mind as we go through the open items and ,

15 show how the new system as well as the existing plan fully 16 complies with your open items.  :

i 17 Okay. What we have done is extracted from your 18 February letter the open items that you folks had at the back, ,

1 i 19 and we have broken them down into five open items. The first ,

20 one relates to heat removal capability, and the items the NRC l 21 had questioned in that letter was the use of the 1971 ANS draft j e

22 standard, the DK heat generation, questioned the basis for the 23 9.1 million BTUs per hour that we used as a heat load, and an

(" 24 apparent discrepancy between the FSAR capacity of the heat 25 exchangers and the fuel pool cooling system and what we are HeritageReE)rtingCorporation (so sas-4ses

9 1 using in our evaluation.

? On Item A, ANS draft standard, that was only used in 1

3 a specific scenario where we used it to calculate the decayed 4 heat in the reactor vessel. All fuel pool heat loads are 5 calculated in accordance with standard review plan 6 requirements.

7 In that particular scenario was a loss of fuel pool 8 cooling where we were going between cooling the reactor vessel 9 and the fuel pool with the RHR system. So, we don't believe 10 there is any conflict with your requirements in what we have 11 done in that evaluation.

12 The next slide, please. This slide is, for k- 13 information, a comparison of your heat load calculations which 1

14 came out of a response that you provided to an intervenor 15 interrogatory and our heat load calculations, and they are 16 essentially the same, within second decimal point.

17 I do not think there is any problem with how we're 18 calculating heat load and that it is in compliance with your j 19 requirements.

. 20 Next viewgraph, please. The following viewgraph is a l 21 curve of heat exchanger performance as a function of days and 22 this is from an internal calculation that we've done and have I

23 benchmarked several of the values that you folks have come up, a

(- 24 and I think it explains our capacity situation.

25 The one bent, the top curve, with the square box, is MeritageReE)rtingCorporation (no sas-4ssa

10 1 a one pump /one heat exchanger. We come up with essentially 2 seventy days for a 150 degree temperature limit in the pool.

I' 3 You folks report sixty-nine days. So, we're right on track

. 4 there.

5 The second curve with the pluses is a one pump /two 6 heat exchanger mode of operation where the two heat exchangers 7 are valved in parallel and that produces at c 150 degrees a 8 ten-day heat removal capacity. The third curve is two 9 pumps /two heat exchangers.

to In the scenario we used for evaluating use of RHR, 11 the 9.1 million DTUa per hour was an arbitrary assumption.

12 What it is is the capacity at ten days. It's the point at which

( 13 one pump /two heat exchangers would be capabit of cooling the 14 fuel pool. We have committed that we would not operate the 15 plant without that capability. So, we took that as an upper 16 bound heat load.

17 In reality, the heat load would be significantly 18 less. We don't feel we could ever start the plant up ten days 19 following a refueling, that that was picked as an arbitrary 20 upper bound, as an adequate assumption for that evaluation.

21 The 2.23 million BTUs per hour is really the one 22 train /one pump /one heat exchanger capacity for a given set of 23 inlet conditions. The same calculation that was used to

(- 24 generate these data also produces the 2.23 million BTUs at the 25 appropriate operating conditions.

MeritageReE)rtingCorporation (so sas-4ses

11 i i So, all numbers are correct. It's just which point 2 you assume and what the different performance parameters of the i

3 fuel pool cooling system is. So, we don't believe there are 4 any conflicts really with your requirements, the independent ,

5 evaluations you folks have performed.

6 Go back to the first one?

7 MR. WESSMAN: Can we agree to that? We might as well t

8 offer the comment, if we could. Do we have any problem with the 9 numbers that we see here, John?

10 MR. RIDGELY: I don't know that there's any conflict 11 because the 2.23 was what, as I was saying, the specific 12 conditions at match point, We did not calculate, recalculate 13 those specific conditions, but based on information that's 14 here, I would expect that those really are the -- that the 15 curve would go to that data point.

16 MR. HOFFMAN: In conclusion, then, we feel that your 17 open items are clearly addressed by our current submittal and 18 certainly the new fuel pool cooling system would have the same 19 compliance with those requiremente.

20 So, we would say that the first open item in your 21 letter is resolved.

22 Item 2 was identified as the temperature limit in the 23 spent fuel pool. Your concern was that there is no fuel pool 9

(- 24 temp 9tature monitoring when the spent fuel pool cooling system  !

25 is not operating.

Neritage(202 Rep)rting Corporation 624-4888

12 1 Strictly speaking, that is correct. The monitor for 2 fuel pool temperature is in the fuel pool cooling line and, ,

3 therefore, if both trains are not operating, there would be no

. 4 monitoring.

5 Your concern war with the fact that without a 6 monitor, we wouldn't know when to isolate the minera11zers, the 7 fuel pool system is not operating, there's no flow, therefore 8 there would be no need to isolate the minera112ers, b

9 MR. RIDGELY: More than just the minera112ers is the 10 fact that you don't know when you get to a 150 degrees, you 11 have to enter your tech spec.

12 MR. HOFFMAN: Okay. I will -- let me correct that.

( 13 I mean, let me address that next.

14 The first concern was related to the minera112ers. We 16 have indicated in our letter we do have an alarm in the control 1

i 16 room at a 125 degrees. So, we know when the pool hits a 125 17 degrees. That's an administrative limit at which point the 18 plant would take corrective action to ensure we do not exceed 19 the 150 degree tech spec.

20 If, at any time, we found that one train of the fuel 21 pool cooling system was inoperable, the licensee is committed l 22 to augmented monitoring, where they have an operator go up and 23 So, "e would all times monitor the pool on a four- hour basis. (

(- 24 know the temperature and the trending of the pool within a 25 four-hour time period, essentially, and the heat-up rate as [

r Meritage(202 Rep)rting Corporation sas-4sse  :

13 I such that we don't believe we'd ever be in a mode of exceeding 2 a 150 degrees without knowing it.

3 So, we feel we have appropriate actions although they 4 are operator actions. We at all times would know the 5 temperature of the fuel pool.

6 The new system being as its seismic and single 7 failure approval, there will a?; ways be flow through that 8 system. We'll always be monitoring the fuel pool temperature 9 during normal operation. The only time when that system might to be secured would be during a refueling, when the gates were 11 open, and we were on RHR, at which point there are other 12 monitors in the plant to also monitor the temperatures.

13 So, we feel that with the existing system, we have 14 that capability. With the new system, it's built right into 10 it, we would always know the temperature and be able to take 16 the appropriate actions.

17 PR. McELWAY: Excuse me, Don.

18 I just want to make it clear that the new system we'd 19 be installing for fuel pool temperature monitoring.

20 MR. HOFFMAN: You folks have any comment on that 21 before we leave it?

22 (No response.)

23 MR. HOFFMAN: The third item was the capability of

(- 24 fuel pool cooling following a seismic event, and the questions

25 you folks had asked related to the fire water connection to HeritageRef)rtingCorporation (so s2s-4ssa

i  !

14 1 service water, alternate cooling piping for the cooling tower  ;

2 cell, and the RNR service water to RHR cross-connect piping.

3 All those' systems are seismic or are isolated in the 4 case of the service water from a non-seismic piping to a 5 normally-shut manual value. I think were we to proceed on thin 6 basis, I think, although it would be necessary for you folks if f

7 you wanted to come up to review the calculations, review the a system boundaries, we have all that information available.

9 With the new system, those particular connections and 10 that would not be required and would be resolved completely by 11 the installation of the new system.

12 MR. WESSMAN: I'm assuming the new system will meet C 13 all the EQ and all the rest of the criteria, whatever is f

14 appropriate in the codes and standards. i r

15 MR. HOFFMAN: That is correct, yes.

16 MR. WESSMAN: Okay. l

[

17 MR. HOFFMAN: Item 4 was the radiological  ;

18 consequences of boiling. This was a potential operating mode r

19 with the existing fuel pool cooling system, and your open items  ;

20 essentially requested that we provide the assumptions and the r 21 dose for on-site. We have that information available. c 22 It war. a very conservative analysis that our people 23 Essentially, they assumed the pool boiled lor thirty l* did.

(.  ? 24 days. They took the boil-of f rate as the maximum boil-of f which 25 was about 16.6 GPM, assumed that lasted for the entire thir ty  ;

I ReritageReIIrtis2EEssasCorporation (20 u -.

! 15 l

L 1 days.

2 For the off-site dose, it was an assumption of a 3 ground level unfiltered release and that came out to about s2x

, 4 percer,t of the Part 20 requirements.

5 For the on-site dose, similar assumptions were made.

6 Thirty days, and there was no provision of supplied air for the 7 personnel on site for recovery. It was also a very small 8 fraction of Part 20.

9 And for the new system, there will be no paol, 10 potential pool boiling events and the whole issue becomes moot.

11 The fifth open item was a concern that you folks 12 expressed on the particular scenario we presented for

( 13 supplemental pooling in the event of loss of the normal fuel 14 pool cooling system by some external event, and the two items 15 that were asked were the capability of parallel heat exchanger 16 operation and your feeling that the number of operator actions 17 were more than you felt was suitable.

18 The heat exchangers can be tied together in parallel.

t 19 In reviewing for this meeting last night, I did notice there 20 was a sketch that we provided in the back of our letter that t

t 21 didn't explicitly show that cross-tie. That may have been a i

22 source of confusion, but, indeed, the heat exchangers can be 23 tied together in parallel.

I

(- 24 our evaluation was a very conservative evaluation, as  ;

25 I indicated earlier, on the heat load. We just took the upper MeritageRef)rtingCorporation (2o s2s-4sse ,

16 1 bounds that the pool could ever be at with the fuel pool 2 cooling system in service and demonstrated that the operators 3 could hand.le that event. It was, I believe, six pump starts 4 and approximately twelve operator actions.

5 That was discussed with the operating staff. They 6 feel that is a reasonable sequence of events. In reality, the 7 numbers would be much lower than that because it wouldn't be 8 the situation with the 9.1 million BTUs in the pool anyway.

9 So, we feel that that is a suitable mode of operation 10 for an extremely unlikely off-normal event. However, once 11 again, the new system completely does away.with that potential 12 of events and would never require that operation.

13 So, once again, we feel that we can address your 14 concerns with the existing system and our new proposal makes 15 the issue moot.

16 With that, if there's any comments, I would be glad 17 to answar them.

38 MR. KUDRICK: I have a question relative to the 19 documentation.

20 Jack Kudrick, Compliance Systems, f, 21 You provided quite a bit of information in response 22 to some of the concerns that we did not have on the pumps and 23 so forth.

(- 24 Were you planning to document that at all, other than 25 in the transcript of this meeting?

HeritageRef)rtingCorporation (so sas-4sse

17 1 MR. HOFFMAN: I don't think we'd F3 planning on it 2 now because our new system proposal, for the ones that are no 3 longer applicable with the new system, I don't see we'd be 4 documenting them in detail.

5 MR. KUDRICK: Okay. So, you're strictly relying on 6 your new system.

7 MR. HOFFMAN: That's correct.

8 MR. WERMIEL: If the new system then goes to almost 9 every issue, as you have said, so if that's what you frame the 10 documents in, then I don't think we see a problem with that 11 proposal resolving these.

12 MR. WESSMAN: Lot me make that clear. I think it

( 13 would be appropriate as you come in with that description of 14 the new system that you at least reference back to the 15 questions of our letter of January 21st and indic.=*n iow this 16 issue is resolved because a couple of sentences or whatever it 17 takes, and then go on to the discussion of the new system.

18 MR. HOFFMAN: That's correct.

19 MR. WESSMAN: Rather than in a debate on an old 20 system that was not ther,, but at least, you know, build the 21 link for us and for the .ublic record of how the new system 22 makes these issues r.co' 23 MR. HOFFMAN Right. That would be -- that's our f 24 plan. We wouldn't be submitting detailed calculations.

25 MR. ROONEY: Let me just clarify my understanding.

Heritage (202 Rep)rting Cor poration 628-4868

18 1 The theory taullet in our January 21st letter was 2 provision for essential fuel pool cooling in case of single 3 failure, and as I understood what you were saying, is that the

. 4 reliance -- without the new system now, your reliance on the 5 RHR in all situations, you felt, as you described in the 6 scenario, that was something that could be donc, correct, but 7 with the new system, it was going to be redundant and single 8 failure proof.

9 MR. HOFFMAN: That is correct.

10 MR. THADANI: Ashok Thadani.

Il Clarification and question about the issue of single

12 failure.

13 Can you descrlhe what your intention is in terms of

14 the single failure to be considered? Are these some active 15 failures or would they be consideration of passive failures?

16 MR. HOFFMAN: Active failures.

17 MR. THADANT: Thank you.

18 THE REPORTER: I'm afraid we're going to have to get 19 people to ecmc up here. It's just not that good in the back.

20 I'm sorry.

21 MR. ROONEY: If anyone wants to come up to talk, I'll 22 step aside and yield the right-of-way, so you can have access 23 to my mike.

(- 24 MR. McELWAY: Any other questions pertaining to the 25 questions in the letter?

MeritageRef)rtingCorporation (2o s2s-4sse

19 1 (No response.)

2 MR. McELWAY: The next item -- my name is David 3 McElway.

4 The next item on our agenda was future actions 5 Vermont Yankee foresees.

6 I've put together a time line to try to indicate the 7 proposed schedule that Vermont Yankee has developed.

8 Certainly, the first item that we need to reach closure on is 9 the licensing approval.

10 Dur next task will be to come up with a conceptual 11 design which is scheduled to be completed by the end of Cycle 12 14. At the completion of the conceptual design, as-built 13 dimensions being taken, a detailed design change would be 14 developed and put through the normal review process, both at 15 Yankee Atomic and the plant, during which time, early purchase 16 of long lean time equipment would be established, with the 17 final detailed design completed by the end of Cycle 15, and the la installation of the entire design change to take place during 19 Cycle 16, such that it is complete and folly operational at the 20 end of Cycle 16.

21 And as indicated on the time line, that's the time 22 frame in which the spent fuel pool will have approximately 1978

[

i 23 spent fuel assemblies in the racks.

(- 24 MR. WESSMAN: Help me out. This is Dick We, man.

( 25 Help me out, if you would. Are you in Cycle 14 now?

i l

Heritage(202 Rep)rting 828-4888 Corporation

20 1 MR. McELWAY: We're in Cycle 13 now.

. (.

2 MR. WESSMAN: And when -- can you throw in at Icast 3 an estimate of the date on a couple of those so that we have a 4 feel of the number of years in the future that --

5 MR. McELWAY: Certainly.

6 MR. WESSMAN: --

you kind of estimate these things to 7 occur?

8 MR. McELWAY: Certernly. We're currently in Cycle 9 13, which is scheduled to end April 1st of 1989. The 10 conceptual design -- and these are the projected dates based on 11 our current schedules.

12 The Cycle 14 is scheduled to be completed in 35 September of 1990, and cycle 15 is scheduled to be completed in 14 April of '92, and Cycle 16 is scheduled to be completed in 15 October of '93.

16 MR. WESSMAN: Thank you.

17 MR. McELWAY: And that brings us to the last item on 18 our agenda for today, which is a summary, and Warren?

19 MR. MURPHY: Okay. A very brief summary.

20 That is the extent of our presentation. It's rather '

+

21 brief, but I think you have heard a very significant commitment .

i 22 on our part.

23 Let me say that we're extremely anxious to resolve

(}f 24 the NRC staff concerns in our submittal. We made our submittal 25 in April of 1986. It's been almost two years. We think far too Heritage Reprting Corporation (202) 628-4888

21 I long a time period to resolve thir particular issue.

2 During that two-year time period, we've had to incur 3 significant expenses to make alternative plans and provisions

. 4 for the spent fuel that we'd generate. If we're going to spend 5 any more money on this project, we want to spend it in a more 6 meaningful way than in the short-term interim solutions, and 7 that's why we're willing to commit to make this very 8 significant commitment to additional fuel pool cooling system.

9 And we do it with the, first of all, notion that we l

l 10 still believe that the submittal that we made two years ago was 11 valid, that we can technically defend our submittal and our 12 plano. However, we're willing to go one step further to

( 13 alleviate the looming concerns that apparently you have that we 14 can't make go away otherwise.

15 Either you're not listening or we're not speaking 16 correctly, and I think maybe I sense a little bit of both.

17 But, in any event, we're more than willing to make 18 this commitment and hope that it does solve your concerns, that 19 we can get some sort of a verbal commitment from you folks 20 today that, in your opinion, in fact, does address all of these l

I 21 concerns.

22 And I think by doing this, we will avoid prolonging 9

23 the debate and the continuing analyses and so forth to try to

( 24 prove fine points. We're willing to give up that approach and 25 solve the problems in one fell swoop here.

Heritage (202 Rep)rting Corporation 628-4888

22 1 So, with that, that's all we have to say today. We 2 certainly would like to have your reaction, if you have one, 3 and look forward to an SCR at the nearest possible opportunity.

. 4 MR. WESSMAN: Why don't we seek to explore whether, 5 in the room here, do we think that we have questions that we 6 need to explore to see whether it resolves our concerns and 7 then perhaps we need to chat for a moment amongst ourselves end 8 try and develop a scenario of the activitics that we would have 9 and you would have in the next, you know -- that meets wjth 10 your fuel cycles and our review of the documentation that would 11 be appropriate.

12 John, do you and Jerry, what are your thoughts on how C. ,

13 this would resolve the concerns that we've raised?

14 MR. WERMIEL: My thinking is that their commitment 15 conceptually and the criteria that identified it would satisfy 16 our concerns.

17 MR. RIDGELY: I have a question. Is there any 18 particular reason why you're going to wait on conceptual design 1

19 until Cycle 147 20 MR. REID: Just because this year is pretty well  ;

I 21 already accounted for and the resources are assigned. We'd t 22 have to divert them to already planned and on-going activitics.

23 MR. RIDGELY: So, you're saying then, in essence, I 24 that you won't have the resources until after April of '89 to 25 really start working on this?

Heritage(202 Rep)rting Corporation 628-4588

23 1 MR. REID: Yes. To the next sphere. We're already 2 budgeted and work and everything else has already begun for 3 '88. We would have to significantly interrupt that.

. 4 Based on the schedule and when we really need the 5 racks, which is what our amendment calls for above 2000, there 6 doesn't appear to be a need to do it.

7 MR. WESSMAN: I'm under the -- excuse me. Do you 8 have another question?

9 MR. WERMIEL: No.

10 MR. WESSMAN: I guess I'm under the impression, 11 Warren, from chatting with Vern that as an interim basis, no 12 would have to do some mndif'. cation to the existing racks to get k la you all through the next two -three cycles, is that correct?

14 Can you address that for me or help me out on that?

15 MR. MURPHY: Well, our plans are that we can go ahead 16 and install the new racks, and the thing that we will not do 17 before wa install the new system is exceed the capacity 2000 la fuel asnembly.

19 We've designed and are building new racks that we're 20 ready to install this year. First of all, don't confuse our 21 completion date of the new system with the point in time when 22 we need the new racks. We need the new racks considerably 23 before that because the problem we have is getting the new i 24 racks in with the amount of fluid we have in the pool.

25 That is, we have less than 2000 assemblies in the Heritage(202 Rep)rting Corporation 628-4888 I

24 3 pool now, with a limited amount of space to get new racks in, 2 to shuffle the fuel from old racks to new racks. We can't go 3 up to the 2000 limit and then install the new racks. We have to

. 4 do that considerably before that.

5 So, what we're seeking here is the okay to go ahead 6 and install the new racks. However, the constraint on us is to 7 not exceed 2000 fuel assemblies in that pool until such time as 8 we have that new system installed.

9 MR. WESSMAN: Okay. So, one of the things that you 10 need agre:ement from the staff on then is your plan to go ahead 11 and put in the new racks as this interim measure, --

12 MR. MURPHY: That's right.

13 MR. WESSMAN: -- get ting you to 2000.

14 MR. MURPHY: Yes.

15 MR. WESSMAN: And another thing that you need is an 16 agreement from the staff on the conceptual design. I'm 17 separating the two major activities then, is that right?

18 MR. MURPHY: Well, I don't know. WeII, the two 19 different issues. We're hoping that you give us the okay to 20 put a new rack on the basis of the commitment to install the 21 new system with the design criteria that we outlined.

22 I guess we have to determine yet to what extent you 23 want to review the design as we go along in terms of Joaking at r waiting till the final design. Certainly it l

(~ - 24 the conceptual 25 will be there and available to you to review.

Heritage(202 Rep)rting Corporation 628-4888 1

25 1 MR. WESSMAN: Okay.

2 For the record, we have just added one more guy to 3 the gathering. This is Joe Sainto from OGC.

4 MR. SOINTO: Not for long.

5 MR. WESSMAN: Not for long.

6 MR. ROONEY: Are there any other questions that we 7 have for the licensee?

8 I think this is the next step to be sure we 9 understand all the facets of what's been proposed.

10 MR. WESSMAN: Are there any other questions you all 11 have of us because then I think we will break up in caucus for 12 a moment and then offer some thoughts to you?

(' 13 MR. REID: I guess our basic question is how do we 14 get here to the end?

15 MR. ROONEY: For . Toe's benefit, since he just came 16 in, I think - you want me to - - okay. You pretty much know 17 where we are. We just completed the final questioning to 18 confirm our understanding.

19 MR. PAULL: Vern, could I ask a question?

20 MR. ROONEY: Phil, could you wait tisa the end? T'd 21 like to get these matters dealt with first, please.

22 Okay. Thank you. Would you hold it till after we ger 23 these things wound up?

( 24 Ashok, do you have --

25 MR. THADANT: I have no more questions.

'.!aritage (202 Rep) rting Corporation 628-4888

26 1 MR. ROONEY: You have no more? Well, perhaps we 2 aught to take a break at this time. We'd like to caucus and 3 consider what we've heard. We may have additional questions

. 4 following.

5 I think the best way would be for you guys to take a 6 rest room break at this point.

7 MR. WESSMAN: You guys go to the cool space. Let's 8 go off the record, please.

9 (Whercupon, a recess was taken.)

10 MR. ROONEY: Do we have present everyone we need?

11 MR. MURPHY: You got the guy who can sign the SER, 12 Vern?

(? 13 MR. ROONEY: We aren't that far.

14 We are in agreement that what you've presented de-1s 15 with the technical issues which we had identified as the 16 unresolved technical issues in our letter to you, and, further, 17 technica]Iy, we're able to react very positively to what you've 18 told us as being substantial enhancement and very good.

19 As you might appreciate, we probably have yet to work 20 out and were unable to quickly work out the procedural aspects

, 21 of these matters.  ;

22 I guess that, as you know, we proceeded fairly far 23 along with our review in the process on the Proposed 2870 with

( 24 these NES racks, and we have -- we are at a point that we 25 expect that we -- if you come in with a proposal, the thing you Heritage (202 ReN)rting Corporation 628-4888

27 I have given us in~this meeting, in writing, we'd expect you to 2 submit this in writing, we would expect to be able to fairly 3 shortly issue the aspects that we have reviewed already and

. 4 document them.

5 Now, we have the bulk thermal hydraulic 6 considerations that your enhanced fuel pool cooling system 7 deals with. We understand that the details of that's not going 8 to be worked out until the end of Cycle 14.

9 We see a second submittal from you when you have 10 that.

11 MR. MURPHY: Excuse me. In terms of our language, 12 MR. ROONEY: Yeah.

13 MR. MtIRPHY: -- is that -- are we talking about the 14 conceptual design phase of-this new system? Is that what in you're saying?

16 MR. WESSMAN: Yes, Warren. T think you are.

17 T.e t me summarize how I think the flow of pappr is 18 likely to happen, if I may butt in on you for junt a second, 19 please.

20 MR. ROONEY: Certainly.

21 MR. WESSMAN: After you all go home from this session

, 22 today, what we're suggesting that you do is you come back to us 23 with the request that basically, to some degree, modifies the I 24 amendment request that you have on the books today because that 25 is an amendment request taking up to the 2800 number of fuel Heritage(202 Rep)rting Corporation 628-4888

28 1 assemblies and based upon originally the existing system that 2 you have.

3 You need to tell us that you're headed in a different 4 direction with giving some indication of the criteria and the 5 concept of the modified system, which is pretty much what 6 you've said to us today, and that in the interim, you expect to 7 use the new fuel racks up to the 2000 capacity to carry you 8 forward until you've completed the work on the new system and 9 you have staff approval on the new system.

10 I think that's a letter that relatively easy you can 11 send to us in the not- to-distant future.

12 Now, the next step then from us is a responce and the l

l (l 13 evaluation we've done on the rack design that we've done for

! 14 your 2800 fuel assembly proposa], we're essentially done with 15 that. So, of course, we should be able to respond back to you 16 in a timely manner allowing you to get on with putting in the 17 racks to carry you forward for the next couple of cycles while the rest of the work goes on. l 18 -

1 19 The only potentially untidy aspect of that is, it may 20 require a reshelly because you are now doing a rack activity 23 that is different than a rack and spent fuel cooling system 22 activity.

23 We don't know the answer to that today, but you see,

( 24 you are proceeding down slightly a different path than was 25 originally done, and I just don't know how that will go.

Heritage(202 Rep)rting Corporation 628-4888

29 1 Then, some time in the future, I guess it's on your 2 Cycle 14 that you say is when you would actually come with us 3 with essentially the details of your conceptual design, a year 4 and a half from now, whenever you've got that conceptual 5 design, and that's when we should be able to, based upon that 6 reasonably good knowledge of that conceptual design, we would 7 expect probably to get pretty well done with the SER process on 8 that, which then gets you in a position to go forward.

9 MR. MURPHY: Okay. Let me say something about that, 10 if I can.

11 Our plans are to design and install a new system 12 under 5059 and it's our opinion that it doesn't require a

(- 13 license amendment to do that.

14 We will submit the design to you, if you ask to look 15 at it, but we don't see that as a requirement if we do it on 16 the 5059.

17 MR. WESSMAN: Okay. When you say the design of the 18 system, what do you mean by "design of the system"? Are you 19 talking about the entire additional train that you're talking 20 about, the concept?

21 MR. MURPHY: yes, yes. We see that design 22 modification as being done under 5059 and not requiring the 23 tech spec change or a license amendment.

I 24 MR. WESSMAN: Okay. I'm not sure that we agree with 25 you at this point in time. I think our perception was that Heritage(202 Rep)rting Corporation 628-4888

30 1 that would involve the amendment process.

2 MR. MURPHY: Okay. What's the basis for that? Why do 3 you feel that way?

. 4 MR. WESSMAN: Well, I think it's -- of course, one, 5 we're a little bit talking on something that's going to come 6 because you're talking a conceptual configuration, and I guess 7 we don't know enough about your conceptual configuration and 8 how it may or may not tie into the plant as designed and as 9 reviewed.

10 I think early in the session, we talked about using 11 some portions of the old system or a wholly new system. I 12 don't think -- you know, you don't know or we don't know

(: 13 exactly how it ties in, but it sounds like it's going to have 14 some relation to the plant as designed, as origina]Iy reviewed, 10 and that would move it into our review space.

16 Am I saying it right, technical folks? Help me out.

17 MR. MURPHY: It's not necessarily true.

18 MR. THADANI: I think -- it seems to me that the 19 termination of 5059 is up to you. You make that decision. You 20 can make a modification under 5059. We may or may not agrse 21 with you, and at this stage, at least, I can't say for sure 22 that we believe there is an unreviewed safety question, 23 therefore you must come in with a submittal. I don't think we

( 24 know the answer at Icast I don't.

25 Does anybody else want to comment on that?

Heritage(202 Rep)rting Corporation 628-4888 I

31

, 1 MR. WEISMAN: Well, look, maybe I can be perfectly 2 clear here.

3 What we're trying to say is, at least from today's

. 4 meeting, we believe from a technical point of view, your 5 submittal can be justified for fuel storage up to 2000 6 elements. That's what we think.

7 For storage up to 2800 elements, I believe, which is 8 what voc :ike to have in the future, it's dependent on a new 9 design. So, the exact legal procedures, what you follow from 10 here on in, is still under discussion by us, but as far as the 11 5059, I got one question for you.

12 Do you have a license condition now limiting the 13 number of elements you can store on site, fuel elenients?

14 MR. MURPHY: That's right.

15 MR. WEISMAN: Well, if you go to 2800, it would seem 16 to me that that would require some sort of an amendment.

17 MR. MURPHY: Oh, it does, and we've applied for that.

18 That's what we're --

19 MR. WEISMAN: The approval that we would give you at 20 this stage of the game would be to 2000 elements. That's what 21 we're trying to tell you. All right. We understand your 22 criteria for future expansion under the system, and we think 23 it's a good criteria, all right, but how you get there for the I 24 final resolution of the 2800 from a legal point of view as was 25 said by Vern and all, it may need a renotice or resholly.

Heritage(202 Rep)rting Corporation 628-4888

32 1 We haven't-determined that.

2 MR. MURPHY: Okay. Fair enough, and we may conclude, 3 in fact, it needs a license submittal or amendment.

. 4 MR. WEISMAN: Right.

5 MR. MURPHY: The other thing I wanted to make clear 6 10 that our plans, if you agree with this, when we install the 7 new racks, we want to install, for a number of reasons, we want 8 to install the capacity of 2870, but be limited to a use of 9 2000.

10 MR. WEISMAN: Right.

11 MR. MURPHY: Okay. Is that clear?

12 MR. WESSMAN: Okay. I understood that clearly.

13 You're saying if you do wotk on the racks in the next 14 six months, the next year or two, you want to install all the 15 way to 2870, but have the limitation of use to 2000.

16 MR. MURPHY: That's right.

17 MR. WESSMAN: So that, basically, you've finished 18 that portion of the work for the comprehensive change that you 19 want.

20 MR. REID: We already have the limit to use of 2000.

21 MR. WESSMAN: I understand. We're going to have to 22 think on that. I'm not sure we fully appreciate it ex:tetly 23 because I thought you were actually going to modify a corner of

/ 24 the pool to get yourselves up conveniently to 2000 and in a 25 sense, it may be that the license condition is all it takes.

Meritage(202 Rek)rting Corporation 628-4888

33 1 But let's think on that. I don't think I can answer 2 that today, but I understand what you're saying.

3 MR. MURPHY: It's a just more much efficient way to 4 do the job.

5 MR. WESSMAN: Certainly. I understand that. Okay, 6 MR. THADANI: I don't see - does anyonc see any 7 problem with that? At least I don't.

8 MR. WERMIEL: No. I was going to say --

9 MR. RIDGELY: Not from a technical standpoint.

10 MR. WERMIEL: Not from a technical s tandpoint.

11 There's no prob 1cm with that.

12 MR. WESSMAN: Okay. Well, maybe we have our answer.

C- 13 We want to think a little bit and be sure that we're 14 comfortable with that just by virtue of you have a capability 15 to do more than the license says, and yet you are bound by what 16 the license says, and yet is there some other issue about a 17 heavy load over another one of these racks somcwhere eine, but 18 it sounds like we're saying it's okay.

19 Okay. What cise? You had another question on what we 20 started to say or did you finish summarizing, Vern?

21 MR. MURPHY: I made the two points that I wanted to 22 make.

23 MR. ROONEY: You made the -- okay. Very good.

. 24 So, I think we would expect a submittal shortly after 25 this meeting from you, putting on the record what you have told Heritage(202 Rep)rting Corporation 628-4888

_ --= _

34 1 us.

2 We intend to issue a safety evaluation covering those 3 portions of the review we've completed to this point shortly.

. 4 We would expect you to provide further detail on the new system 5 when you've reached the point that you can speak more 6 specifically to it, and I guess we would like that_in the form 7 of a submit tal a t the end of conceptual design.

8 Am I speaking correctly for the staff here?

9 MR. MURPHY: Okay. Regardless of the determination 10 of 5069 and the license amendment?

11 MR. WESSMAN: That's the determination that's 12 described in your schedule.

13 MR. ROONEY: Yeah. We have yet to work out the 14 procedural aspects.

15 Staff, have I let anything major out? I hope not.

16 MR. WESSMAN: Any other thoughts, Warren, at this 17 time?

18 MR. MURPHY: Again, I just want to be clear that if 19 we give you our proposal in writing, basically tell you in i

20 writing what we told you today, the result of that will be an l

,. 21 SER that would allow us to install the new racks?

22 MR. WESSMAN: That's our expectation. l 23 MR. ROONEY: I guess this completes the matter we I 24 sought to accomplish in this meeting.

25 Now, I think that we ought to -- I'm open to Heritage(202 Rep)rting Corporation 628-4888

35

, i questions from members of the public or comments at this point, 2 and we'll do what we can to annwcr them, as we said, i.

3 MR. WESSMAN: And, John, do you or Phil have anything

. 4 else you wanted to ask the staff at this time?

5 MR. RIDGELY: No. I have a question, but I've had it 6 answered.

7 MR. ROONEY: Okay. Very good. Joe?

8 MR. DEAN: The only question I have -- Georgo Dean.

9 THE REPORTER: The gentleman has got to come up.

10 MR. DEAN: Would be whether the staff intends to do a 11 new environmental impact statement with respect to this new 12 proposal in consideration of the alternatives.

( 13 It seems to me that this is an entirely new proposal 14 to get the 2800 on the floor, which is going to involve an 15 additional substantial sum of money being expended.

16 MR. WESSMAN: Okay. I don't know that the staff has 17 decided how to do the environmental aspect. We've got your 18 question and let us think on it.

19 MR. SOINTO: Yeah. I -- Jet me interject. It's our 20 position that we have it. It is not necessary to do an

. 21 environmental impact statement for the application we sought.

22 We've been doing an environmental impact appraisal. I would be 23 surprised if this change changed that basic position. I would I 24 be surprised to see us do an environmental impact appraisal on 25 this, but in view of the pocition we took in the proceeding, I ,

Heritage(202 Rep)rting Corporation 628-4888 l-

36

, I would be surprised to see us do an environmental impact 2 statement.

-3 MR. DEAN: That answers my question.

. 4 MR. ROONEY: Are there further questions?

5 (No response.)

6 MR. ROONEY: Meeting adjourned.

7 Thank you for coming in.

8 (Whereupon, at 11:30 a.m., the hearing was 9 adjourned.)

10 11 12 13 14-15 16 17 18 19 20 21 22 23 f 24 25 Meritage(202 Rep)rting Corporation 628-4888

I REPORTER'S CERTIFICATE 2  !

3 DOCKET NUMBER: l 4 CASE TITLE: Spent Fuel Capacity at Vermont' Yankee Nuclear Plan 5 HEARING DATE: February f, 1988 '

6 LOCATION: RockVille, MD 7

I hereby certify that the proceedings and evidence 8 .

are contained fully and accurately on the tapes and notes l 9  ;

reported by me at the hearing in the above case before the  !

10  :

United States Nuclear Regulatory Authority. l 11 I

i l

( 13 Date: 2-9-88 l 14 l 15 i .

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UNn EU STATES L' NUCLEAR REGULATORY COMMISSION l e.........=..........=............................................................

In the Matter of: )

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l SPENT FUEL CAPACITY AT VERMONT)

YANKEE NUCLEAR PLANT )

s Pages: 1 through 36 Place: Rockville, Maryland Date: February 9, 1988 i

Heritage Reporting Corporation  !

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' 1120 L Strwt. N.W.

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  1. 3 . UNITED STATES NUCLEAR REGULATORY COMMISSION 2 ATOMIC SAFETY AND LICENSING BOARD PANEL I

-3 4 In the Matter of: )

)

5 SPENT FUEL CAPACITY AT VERMONT YANKEE NUCLEAR PLANT )

6 7 Tuesday  ;

February 9,19 88 8

U.S. Nuclear Regulatory 9 Commission 11555 Rockville Pike 10 1 Whtie Flint' North 16th Floor, Room 11 11 Rockville, MD 20852 12 The above entitled matter came on for hearing,

( 13 oursuant to notice, at 10:09 a.m.

14 15 APPEARANCES:

16 On Behalf of Vermont Yankee Nuclear Plant:

17 DON REID DAVE McELWAY 18 JOHN DEVINCENTIS JOHN HOFFMAN 19 JAY THAYER CHRIS HANSEN 20 BOB CADSTICK JOHN RITSHER 21 22

. 23 24 25 Heritoge Reporting ~ Corporation

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APPEARANCES (Continued)'

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On Behalf of the State of Vermont:

2 3 PHIL,PAULL 4

On Behalf of the State of Massachusetts:

5 GEORGE DEAN ,

6 On Behalf of the Nuclear Regulatory Commission: ,

7 VERNON ROONEY

DICK WESSMAN 8 GUS LAINAS JACK KUDRICK 9 JERRY WERMIEL JOHN RIDGELY 10 ANN HODGDON JOE RUTBERG 3g BOB WEISMAN ASHOK THADANI 12 JOE SCINTO

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3 1 PROCEEDINGS 2 MR. ROONEY: This is a meeting between the staff and 3 Vermont Yankee to consider information needed to complete the

. 4 staff's review of the Vermont Yankee spent fuel proposal.

5 It is a public meeting. We have public 6 representatives here presently and we may have some more, I 7 believe. The public is present as observers, not participants.

8 If members of the public have questions or comments, would you 9 hold them till the end, and I will try to deal with them if you 10 direct them to me, and we will try to do what we can, as we 11 usually do, to deal with those matters at that time.

12 But we want to focus today on trying to get as much r

13 mileage and communications on resolving the longstanding fuel 14 pool proposal that we are dealing with.

15 The meeting's being transcribed, and, so, a I

16 transcription will be issued fairly soon after the meeting. So, l

17 if, when you have something to say, would you please identify i

18 yourself for the reporter and, further, if those at the side of 19 the room, and there may be some participating, will come i

20 forward, we will try to make way so you have access to a mike, 21 so you can be entered into the record. And, of course, don't 22 everybody speak at once.

23 I guess with these preliminaries, I would like to ask

( 24 Dick Wessman, my boss, if he has any comments.

25 MR. WESSMAN: No, I don't, Vern. I think we have one Heritage(202 Rep)rting Corporation 628-4888

4 1 additional person that has come in. If you would identify 2 yourself, please?

3 MR. DEAN: George Dean, Assistant Attorney General

, 4 for the Commonwealth of Massachusetts.

5 MR. "AESSMAN: Okay Glad to have you, George.

6 I would suggest to the Vermont ankee folks, we may 7 lose at least a couple of managers around 11:00 because of 8 another commitment. If you have sorne -- you know, we want to 9 get the best part of your message at the fvtat end of the 10 session and work technical details later.

11 You know, we will be here as long as we need to work 12 the problem, and, Ashok or Gus, do you have anything else that

(~

13 you want to cover before we get started?

14 MR. THADANI: I don't.

15 MR. WESSMAN: Okay. Vern, let's go ahead and get on 16 with it.

17 MR. PDONEY: Okay. Well, I guess, Warren, you --

18 I'll turn it over to you for presentation of such information 19 as you have.

20 MR. MURPHY: Okay. I'll immediately lateral the 21 football to Don Reid to give the introductory remarks and then 22 go on to John Hoffman.

23 MR. REID: Okay. I guess we'd first like to show you (I 24 the topics we intended to cover today, at least to start out.

25 We're going to provide an introductory statement.

Heritage (202 Rep)rting Corporation 628-4888

5 1 John Hoffman, to my right, is going to go 2 specifically through your open items listed in your previous 3 letter or your last letter, and then we'll talk abot>t where

. 4 we're going to go from here, at least from our point of view, 5 and then hopefully we'll get into any discussions or questions 6 you may have at the end of our presentation.

7 MR. WESSMAN: Do you all have handouts that you're 8 going to be able to give to us to help us take notes and attach 9 to the transcript?

10 MR. REID: I don't believe so, other than --

11 MR. HOFFMAN: We can make copies of the viewgraphs 12 later.

i' 13 MR. REID: I gueva we'll make copies of the 14 viewgraphs.

15 MR. WESSMAN: I think we'd like to get c copy of the 16 viewgraphs for the record.

17 MR. REID: Okay. I guess I'd like to start out by 18 saying we appreciate this opportunity to directly address the 19 outstanding technical issues and answer any questions you may 20 still have relative to our licensing request.

21 Our proposal is to gain your approval to expand the

22 storage capacity of our spent fuel po-1 it
2 ;;00 Sasemblien to l

l' i

23 2870 assemblies, using a slightly nigher density fuel rate than j

(- ' 24 that which presently. exists.

25 We wish to make it extremely clear toja; that it is Meritage( Rep)rting Corporation 2 )2 B28-4886

+- -p -

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7 6

1 our intent to finally resolve these outstanding issues to the 2 satisfaction of the NRC staff, and to clarify any other areas 3 that etill appear to involve some misunderstandings.

. 4 our presentation today will provide you with a firm 5 basis upon which you can issue a timely and satisfactory safety 6 eval ation report and the accompanying amendments which would 7 .denti;?y no outstanding concerns.

8 In order to facilitate a conclusion to this long-9 active licensing effort, we wish to present a solution that 10 will, without question, address and satisfy all the outstanding 11 concerns. This solution is presented despite the fact that we 12 still fully believe and support the adequacy of our present

(

13 license amendment request.

14 We wish to emphasize that our new proposed solution 15 is being offered solely to expedite and facilitate closure on 16 an issue critical to Vermont Yankee that has been pending for 17 almost two years.

18 In order to break this licensing logjam, we are 19 willing to make a major commitment that will c.early resolve 20 all the outstanding staff concerns. We are willing to commit 21 to design and install a completely redundant seismic fuel pool 22 cooling system prior to the time that we reach 2000 bundles 23 stored in the fuel pool.

(- 24 This will have sufficient capacity to preclude any 25 concerns with the use of the residual heat removal system.

Heritage(202 Rep)rting Corporation 628-4888

7 f 1 At this time, there are many optitns available to t

2 accomplish this design objective. Hence, the seismic fuel pool 3 cooling system could be a wholly new system or it could be a

, 4 combination of some new components and modifications of some 5 existing sections of the system.

6 The final system design will comply with the 7 appropriate criteria of your standard review plan and, of 8 course, be available for your review and inspection at any 9 stage of the process, 10 John Hoffman, like I mentioned previously, will have 11 more to say about that as well as specifically addressing the 12 concerns in your January 21st letter.

(

13 As I indicated previously, thle commitment is offered 14 in support for you to complete your review and issue a timely 15 safety evaluation report and the amendment.

16 Finally, we wish to make it clear that Vermont Yankee 17 continues to have a high commitment to operate and maintain the 18 safe nuclear power plant. This includes compliance with all 19 the applicable rules and regulations. We are available and 20 wish to fully be cooperative with the NRC in bringing this 21 issue to its conclusion.

22 We would be happy to address any questions following 23 the remaining presentations.

( 24 John?

25 MR. HOFFMAN: John Hoffman.

Meritage(202 Rep)rting Corporation 828-4888

8 1 What we'd like to do is present a viewgraph that 2 shows the design criteria that we'll be using in the design of C

3 the fuel pool cooling system that Den just mentioned.

. 4 The seismic Category 1, sy*.ty class system. Seismic 5 Category 1, cooling system. Single active failure proof.

6 Detectors for loss of function and designed for the appropriate 7 licensing criteria, detection and isolation of leaks, flooding, 8 internal and external missiles, in-service testing, the 9 installation will have the appropriate considerations at the 10 time of the project as well as fire protection concerns.

11 As Don indicated, the design details have not been 12 worked out, but these are the criteria that will be used and

( 13 would help in the following discussion of the open items to 14 keep those criteria in mind as we go through the open items and 15 show how the new system as well as the existing plan fully 16 complies with your open items.

17 Okay. What we have done is extracted from your 18 February letter the epon items that you folks had at the back, 19 and we have broken them down into five open items. The first 20 one relates to heat removal capability, and the items the NRC 21 had questioned in that letter was the use of the 1971 ANS draft 22 standard, the DK heat generation, questioned the basis for the 23 9.1 million BTUs per hour thct we used as a heat load, and an

( 24 apparent discrepancy between the FSAR capacity of the heat 25 exchangers and the fuel pool cooling system and what we are HeritageRef)rtingCorporation (so eas-dess

9 1 using in our evaluation.

2 On Item A, ANS draft standard, that was only used in 3 a specific scenario where we used it to calculate the decayed 4 heat in the reactor vessel. All fuel pool heat loads are 5 calculated in accordance with standard review plan 6 requirements.

7 In that particular scenario was a loss of fuel pool 8 cooling where we were going between cooling the reactor vessel 9 and the fuel pool with the RHR system. So, we don't believe 10 there is any conflict with your requirements in what we have 11 done in that evaluation.

12 The next slide, please. Thic slide is, for 13 information, a comparison of your heat load calculations which 14 came out of a response that you provided to an intervence 15 interrogatory and our heat load calculations, and they are 16 essentially the same, within second decimal point.

17 I do not think there is any problem with 1.ow we're 18 calculating heat load and that it is in compliance with your 19 requirements.

20 Next viewgraph, please. The following viewgraph is a 21 curve of heat exchanger performance as a function of days and 22 this is from an internal calculation that we've done and have 23 benchmarked several of the values that you folks have come up,

(- 24 nnd I think it explains our capacity situation.

25 The one bent, the top curve, with the square box, is Heritage(202 Rep)rting Corporation 628-4888

10 j 1 a one pump /one heat exchanger. We come up with essentially 2 seventy days for a 150 degree temperature limit in the pool.

3 You folks report sixty-nine days. So, we're right on track

. 4 there.

5 The second curve with the pluses is a one pump /two 6 heat exchanger mode of operation where the two heat exchangers 7 are valved in parallel and that produces at a 150 degrees a 8 ten-day heat removal capacity. T*ie third curve is two 9 pumps /two heat exchangers.

10 In the scenario we used for evaluating use of RHR, 11 the 9.1 m1.111on BTUs per hour was an arbitrary assumption.

12 What it is is the capacity at ten days. It's the point at which 13 one pump /two heat exchangers would be capable of cooling the 14 fuel pool. We have committed that we would not operate the 15 plant without that capability. So, we took that as an upper 16 bound heat load.

17 In reality. the heat load would be significantly 18 less. We don't feel we could ever start the plant up ten days 19 following a refueling, that that was picked as an arbitrary 20 upper bound, as an adequate assumption for that evaluation.

21 The 2.23 million BTUs per hour is really the one 22 train /one pump /one heat exchanger capacity for a given set of 23 inlet conditions. The same calculation that was used to

(' 24 generate these data also produces the 2.23 million BTUs at the 25 appropriate operating conditions.

Heritage Re orting Corporation l

i (20 ) 628-4888

11 1 So, all numbers are correct. It's just which point 2 you assume and what the different performance parameters of the 3 fuel pool cooling system is. So, we don't believe there are

. 4 any conflicts really with your requirements, the independent S evaluations you folks have performed.

6 Go back to the first one?

7 MR. WESSMAN: Can we agree to that? We might as well 8 offer the comment, if we could. Do we have any problem with the 9 numbers that we see here, John?

10 MR. RIDGELY: I don't know that there's any conflict 11 becau=e the 2.23 was what, as I was saying, the specific 12 conditions at match point. We did not calculate, recalculate 13 those specific conditions, but based on information that's 14 here, I would expect that those really are the -- that the 15 curve would go to that data point.

16 MR. HOFFMAN: In conclusion, then, we feel that your 17 open items are clearly addressed by our current submittal and 18 certainly the new fuel pool cooling system would have the same 19 compliance with those requirements.

20 So, we would say that the first open item in your 21 letter is resolved.

22 Item 2 was identified as the temperature limit in the 23 spent fuel pool. Your concern was that there is no fuel pool

(* 24 temperature monitoring when the spent fuel pool coolitig system 25 is not operating.

Heritage(202 Rep)rting Corporation 628-4888

l 12 1 Strictly speaking, that is correct. The monitor for 2 fuel pool temperature is in the fuel pool cooling line and, 3 therefore, if both trains are not operating, there would be no 4 monitoring.  ;

i 5 Your concern was with the fact that without a 6 monitor, we wouldn't know when to isolate the minera112ers, the  ;

l 7 fuel pool system is not operating, there's no flow, therefore  !

8 there would be no need to isolate the minera112ers.

9 MR. RIDGELY: More than just the mineralizers is the 10 fact that you don't know when you get to a 150 degrees, you 11 have to enter your tech spec.

12 MR. HOFFMAN: Okay. I will -- let me correct that.

13 I mean, let me address that next.

14 The first concern wee related to the minera112ers. We 15 have indicated in our letter we do have an alarm in the control 16 room at a 125 degrees. So, we know when the pool hits a 125 17 degrees. That's an administrative limit at which point the 18 plant would take corrective action to ensure we do not exceed l 19 the 150 degree tech spec.

I l

20 If, at any time, we found that one train of the fuel 21 pool cooling system was inoperable, the licensee is committed 22 to augmented monitoring, where they have an operator go up and 23 monitor the pool on a f our- hour basis . So, we would all times 24 know the temperature and the trending of the pool within a (1

25 four-hour time period, essentially, and the heat-up rate is Heritage(202 Rep)rting Corporation 628-4888

13 1 sucn that we don't believe we'd ever be in a mode of exceeding 2 a 150 degrees without knowing it.

3 So, we feel we have appropriate actions although they 4 are operator actions. De at all times would know the 5 temperature of the fuel pool.

6 The new system being as its seismic and single 7 failure approval, there will alnays be flow through that 8 system. We'll always be monitoring the fuel pool temperature 9 during normal operation. The only dme when that system might 10 be secured would be during a refueling, when the gates were j 11 open, and we were on RHR, at which point there are other 12 monitors in the plant to also mon 2 tor the temperatures.

13 So, we feel that with the existing system, we have 14 that capability. With the new system, it's built right into 15 it, we would always know the temperature and be able to take 16 the appropriate actions.

17 MR. McELWAY: Excuse ma, Don.

4 18 I just want to make it cles- that the new system we'd 19 he installing for fuel pool temperature monitoring.

20 MR. HOFFMAN: You folks have any enament on that 21 before we leave it?

22 (No response.)

23 MR. HOFFMAN: The third item was the capability of

(- 24 fuel pool cooling following a seismic event, and the questions 25 you folks had asked related to the fire water connection to Heritage(202 Rep)rting Corporation 628-4888

14 1 service water, alternate cooling piping for the cooling tower 2 cell, and the RHR service water to RHR cross-connect piping.

3 All-those systems are seismic or are isolated in the

. 4 case of the service water from a non-seismic piping to a 5 normally-shut manual value. I think were we to proceed on this 6 basis, I think, although it would be necessary for you folks if 7 you wanted to come up to review the calculations, review the 8 system boundaries, we have all that information available.

9 '41 th the new system, those particular connections and 10 that would not be required and would be resolved completely by 11 the installation of the new system.

12 MR. KESSMAN
I'm assuming the new system will meet

( all the EQ and all the rest of the criteria, whatever is 13 14 appropriate in the codes and standards, 15 MR. HOFFMAN: That is correct, yes.

16 MR. WESSMAN: Okay.

17 MR. HOFFMAN: Item 4 was the radiological 18 consequences of boiling. This was a potential operating mode 19 with the existing fuel pool cooling system, and your open items 20 essentially requested that we provide the assumptions and the 21 dose for on-site. We have that information available.

22 It was a very conservative analysis that our people 23 did. Essentially, they assumed the pool boiled for thirty

(- 24 days. They took the boil-off rate as the maximum boil-off which 25 was about 16.6 GPM, assumed that lasted for the entire thirty Heritage(202 Rep)rting Corporation 628-4888

15 1 days.

2 For the off-site dose, it was an assumption of a 3 ground level unfiltered release and that came out to about six

. 4 percent of the Part 20 requirements.

5 For the on-site dose, similar assumptions were mad.w.

6 . Thirty days, and there was no provision of supplied air _for the 7 personnel on site for recovery. It was also a very small 8 fraction of Part 20.

9 And for the new system, there will be no pool, 10 potential pool boiling ever.ts and the whole issue becomes moot.

11 The fifth open 1+.a was a concern that you folks 12 expressed on the particular scenario we presented for

( 13 supplemental pooling in the event of loss of the normal fuel 15 pool cooling syste;.i by some c:nernal event, and the two items 15 that wera asked were the capenility of parallel heat exchanger 16 operat ion and your .'e< sling that the number of operator actions 17 were more than you felt was suitable.

18 The heat exchr.ngors can be tied together in parallel.

19 In reviewing for this meeting last night, I did notice there 20 was a sketch that we provided in the back of our letter that 21 didn't explicitly show that cross-tie. That may have been a 22 source of confusion, but, indeed, the heat exchangers can be 23 tied together in parallel.

( 24 our evaluation was a very conservative evaluation, as 25 I indicated earlier, on the heat load. We just took the upper  ;

Heritage(202 Rep)rting Corporation 628-4888

. __ __ -. __ ,m.

16 1 bounds that the pool could ever be at with the fuel pool 2 cooling system in service and demonstrated that the operators 3 could handle that event. It was, I believe, six pump starts

. 4 and approximately twelve operator actions.

5 That was discussed with the operating staff. They 6 feel that is a reasonable sequence of events. In reality, the 7 numbers would be much lower than that because it wouldn't be 8 the situation with the 9.1 million BTUs in the pool anyway.

9 So, we feel that that is a suitable mode of operation 10 for an extremely unlikely off-normal event. However, once 11 again, the new system completely does away with that potential 12 of events and would never require that operation.

13 So, once again, we feel that we can address your 14 concerns with the existing system and our new proposal makes 15 the issue moot.

16 With that, if there's any comments, I would be glad 17 to answer them.

18 MR. KUDRICK: I have a question relative to the 19 documentation.

20 Jack Kudrick, Compliance Systems.

21 You provided quite a bit of information in response 22 to some of the concerns that we did not have on the pumps and ,

23 so forth.

I 24 Were you planning to document that at all, other than 25 in the transcript of this meeting? i Neritage(202 Rep)rting Corporation 628-4888

17 I

, 1 MR. HOFFMAN: I don't think we'd be planning on it

(

2 now because our new system proposal, for the ones that are no 3 longer applicable with the new system, I don't see we'd be I

4 documenting them in detail.

5 MR. KUDRICK: Okay. So, you're strictly relying on 6 your new system.

7 MR. HOFFMAN: That's correct.

8 MR. HERMIEL: If the new system then goes to almost 9 every issue, as you have said, so if that's what you frame the 10 documents in, then I don't think we see a problem with that 11 proposal resolving these.

12 MR. WESSMAN: Lot me make that clear. I think it 13 would be appropriate as you come in with that description of 14 the new system that you at least reference back to the 15 questions of our letter of January 21st and indicate how this 16 issue is resolved because a couple of sentences or whatever it 17 takes, and then go on to the discussion of the new system.

18 MR. HOFFMAN: That's correct.

19 MR. WESSMAN: Rather than in a debate on an old 20 system that was not there, but at least, you know, build the 21 link for us and for the public record of how the new system 22 makes thesc issues moot.

23 MR. HOFFMAN: Right. That would be -- that's our

. 24 plan. We wouldn't b.e submitting detailed calculations.

25 MR. ROONCy: Let me just clarify my understanding.

i

' Neritage(202 Rep)rting Corporation 628-4888

18 1 The theory bullet in our January 21st letter was 2 provision for essential fuel pool cooling in case of single 3 failure, and as I understood what you were saying, is that the 4 reliance -- without the new system now, your reliance on the 5 RHR in all situations, you felt, as you described in the 6 scenario, that was something that could be done, correct, but 7 with the r.ew system, it was going to be redundant and single 8 failure proof.

9 MR. HOFFMAN: That is correct.

10 MR. THADANI: Ashok Thadani.

11 Clarification and question about the issue of single 12 failure.

13 Can you describe what your intention is in terms of 14 the single failure to be considered? Are these some active 15 failures or would they be consideration of passive failures?

16 MR. HOFFMAN: Active failures.

17 MR. THADANI: Thank you.

18 THF REPORTER: I'm afraid we're going to have to get i

19 people to come up here. It's just not that good in the back.

20 I'm sorry.

c 21 MR. ROONEY: If anyone wants to come up to talk, I'll 22 step aside and yield the right-of-way, so you can have access 23 to my mike.

I 24 MR. McELWAY: Any other questions pertaining to the 25 questjons in the letter?

Heritage(202 Rep)rting Corporation 628-4888

f' l

19 l , 1 (No response.)

2 MR. McELWAY: The next item -- my name is David I.

3 McElway.

. 4 The next item on our agenda was future actions 5 Vermont Yankee fofesees.

6 I've put together a time line to try to indicate the 7 proposed schedule that Vermont Yankee has developed.

8 Certainly, the first item that we need to reach closure on is 9 the licensing approval.

10 Dur next task will be to come up with a conceptual 11 design which is scheduled to be completed by the end of Cycle 12 14. At the completion of the conceptual design, as-built 13 dimensions being taken, a detailed design change would be 14 developed and put through the normal review process, both at 15 Yankee Atomic and the plant, during which time, early purchase 16 of long lead time equipment would be established, with the 17 final detailed design completed by the end of Cycle 15, and the la installation of the entire design change to take place during 19 Cycle 16, such that it is complete and fully operational at the 20 end of Cycle 16.

21 And as indicated on the time line, that's the time l.

l 22 frame in which the spent fuel pool will have approximately 1978 23 spent fuel assemblies in the racks.

( 24 MR. WESSMAN: Help me out. This is Dick Wessman.

25 Help me out, if you would. Are you in Cycle 14 now?

Heritage(202 Rep)rting Corporation 628-4888

20 1 MR. McELWAY: We're in Cycle 13 now.

2 MR. WESSMAN: And when -- can you throw in at least 3 an estimate of the date on a couple of those so that we have a 4 feel of the number of years in the future that --

5 MR. McELWAY: Certainly.

6 MR. HESSMAN: -- you kind of estimate these things to 7 occur?

8 MR. McELWAY: Certainly. We're currently in Cycle 9 13, which is scheduled to end April 1st of 1989. The 10 conceptual design -- and these are the projected dates based on 11 our current schedules.

12 The Cycle 14 is scheduled to be completed in 13 September of 1990, and Cycle 15 is scheduled to be completed in 14 April of '92, and Cycle 16 is scheduled to be completed in 15 October of '93.

16 MR. WESSMAN: Thank you.

17 MR. McELWAY: And that brings us to the last item on l

18 our agenda for today, which is a summary, and Warren?

I 19 MR. MURPHY: Okay. A very brief summary.

20 That is the extent of our presentation. It's rather 21 brief, but I think you have heard a very significant commjtment 22 on our part.

23 Let me say that we're extremely anxious to resolve i 24 the NRC staff concerns in our submittal. We made our submittal 25 in April of 1986. It's been almost two years. We think far too Neritage(202 Rep)rting Corporation 628-4888

21 1 long a time period to resolve this particular issue.

2 During that two-year time period, we've had to incur 3 significant expenses to make alternative plans and provisions 4 for the spent fuel that we'd generate. If we're going to spend 5 any more money on this project, we want to spend it in a more 6 meaningful way than in the short-term interim solutions, and 7 that's why we're willing to commit to make this very 8 significant commitment to additional fuel pool cooling system.

9 And we do it with the, first of all, notion that we lo still believe that the submittal that we made two years ago was il valid, that we can technically defend our submittal and our 12 plann. However, we're willing to go one step further to

(- 13 alleviate the looming concerns that apparently you have that we 14 can't make go away otherwise.

15 Either you're not listening or we're not speaking 16 corrently, and I think maybe I sense a little bit of both.

17 But, in any event, we're more than willing to make 18 this cnmmitment and hope that it does solve your concerns, that 19 we can get some sort of a verbal commitment from you folks 20 today that, in your opinion, in fact, does address all of these i 21 concerns.

22 And I think by doing this, we will avoid prolonging 23 the debate and the continuing analyses and so forth to try to i 24 prove fine points. We're willing to give up that approach and 25 solve the problems in one fell swoop here. f MeritageRegortingCorporation (20 ) ass-4ssa

22 1 So, witn that, that's all we have to say today. We 2 certainly would like to have your reaction, if you have one, 3 and look forward to an SCR at the nearest possible opportunity.

4 MR. WESSMAN: Why don't we seek to explore whether, 5 in the room here, do we think that we have questions that we 6 need to explore to see whether it resolves our concerns and 7 then perhaps we need to chat for a moment amongst ourselves and 8 try and develop a scenario of the activitics that we would have 9 and you would have in the next, you know -- that meets with to your fuel cycles and our review of the documentation that would 11 be appropriate.

12 John, do you and Jerry, what are your thoughts on how C'. 13 this would resolve the concerns that we've raised?

14 MR. WERMIEL: My thinking is that their commitment 15 conceptually and the criteria that identified it would satisfy 16 our concerns.

17 MR. RIDGELY: I have a question. Is there any 18 particular reason why you're going to wait on conceptual design 19 until Cycle 147 20 MR. REID: Junt because this year is pretty well ,

21 already accounted for and the resources are assigned. We'd ,

22 have to divert them to already planned and on-going activitics, l

23 MR. RIDGELY: So, you're saying then, in essence, f- 24 that you won't have the resources until after April of '89 to 25 really start working on this?

I Heritage(202 Rep)rting Corporation 628-4888 L

23 1 MR. REID: Yes. To the next sphere. We're already 2 budgeted and work and everything else has already begun for t,

3 '88. We would have to significantly interrupt that.

. 4 Based on the schedule and when we really need the 5 racks, which is what our amendment calls for above 2000, there 6 doesn't appear to be a need to do it.

7 MR. WESSMAN: I'm under the -- excuse me. Do you 8 have another question?

9 MR. WERMIEL: No.

10 MR. WESSMAN: I guess I'm under the impreanion, 11 Warren, from chatting with Vern that as an interim basin, you 12 would have to do some mndification to the existing racks to get la you all through the next two three cycles, is that correct?

14 Can you address that for me or help me out on that?

15 MR. MURPHYr Well, our plans are that we can go ahead 16 and install the new racks, and the thing that we will not do 17 before we install the new system is exceed the capacity 2000 18 fuel annembly.

19 We've designed and are building new rackn that we're 20 ready to install this year. First of all, don't confuse our 21 completion date of the new system with the point in time when 22 we need the new racks. We need the new racks considerably 1

23 before that because the problem we have is getting the new

( 24 racks in with the amount of fluid we have in the pool.

25 That is, we have less than 2000 assemblics in the  !

Heritage(202 Rep)rting Corporation 628-4888

24 1 pool now, with a limited amount of space to get new racks in, 7

2 to shuffic the fuel from old racks to new racks. We can't go 3 up to the 2000 limit and then install the new racks. We have to

- 4 do that considerably before that.

5 So, what we're seeking here is the okay to go ahead 6 and install the new racks. However, the constraint on us is to 7 not exceed 2000 fuel assemblies in that pool until such time as 8 we have that new system installed.

9 MR. WESSMAN: Okay. So, one of the things that you 10 need agreement from the staff on then is your plan to go ahead 11 and put in the new racks A. this interim measure, --

12 MR. MURPHY: That's right.

13 HR. WESSMAN: -- getting you to 2000.

14 MR. MURPHY: Yes.

15 MR. WESSMAN: And another thing that you need is an 16 agreemen* from the staff on the conceptual design. I'm 17 separating the two major activities then, is that right?

18 MR. MURPHY: Well, I don't know. Well, the two 19 different issues. We're hoping that you give us the okay to 20 put a new rack on the basis of the commitment to install the i

. 21 new system with the design criteria that we outlined.

22 I guess we have to determine yet to what extent you 23 want to review the design as we go along in terms of 1 coking at i 24 the conceptual or waiting till the final design, certainly it 25 will be there and available to you to review.

HeritageRef)rtingCorporation (2o s2s-4ssa

l 25 1 MR. WESSMAN: Okay.

l 2 For the record, we have just added one more guy to 3 the gathering. This is Joe Sointo from OGC.

4 MR. SOINTO: .Not for long.

5 MR. WESSMAN: Not for long.

6 MR. ROONEY: Are there any other questions that we 7 have for the licensee?

8 I think this in the next step to be sure we 9 understand all the facets of what's been proposed.

10 MR. WESSMAN: Are there any other questions you all 11 have of us because then I think we will break up in caucus for 12 a moment and then offer some thoughts to you?

(- 13 MR. REID: I guess our basic question is how do we l

14 get here to the end?

15 MR. ROONEY: For . Toe's benefit, since he just came 16 in, I think - you want me to - okay. You pretty much know 17 where we are. We junt completed the final questioning to 18 confirm our understanding.

19 MR. PAULL: Vern, could I ask a question?

20 MR. ROONEY: Phil, could you wait till the end? T'1 ,

21 like to get these mattera dealt with first, please.

22 Okay. Thank you. Would you hold it till after we get ,

23 these things wound up? -

( P4 Ashok, do you havr --

i 25 MR. THADANT: I have no more questions. [

l l

RevitageRef)rtingCorporation (so sas-4ses ,

l

26 3 MR. ROONEY: You have no more? Well, perhaps we 2 ought to take a break at this time. We'd like to caucus and 3 consider what we've heard. We may have additional questions 4 following.

5 I think the best way would be for you guys to take a 6 rest room break at this point.

7 MR. WESSMAN: You guys go to the cool space. Let's 8 go off the record, please.

9 (Whercupon, a recenn was taken.)

10 MR. ROONEY: Do we have present everyone we need?

11 MR. MURPHY: You got the guy who can sign the SER, 12 Vern?

(' 13 MR. ROONEY: We aren't that far.

14 We are in agreement that what you've presented deals 15 with the technical innuen which we had identified an the 16 unresolved technical issues in our letter to you, and, further, 17 technically, we're able to react very positively to what you've 18 told us as being substantial enhancement and very good.

19 As you might appreciate, we probably have yet to work 20 out and were unable to quickly work out the procedural aspects 21 of these matters.

22 I guess that, as you know, we proceeded fairly far 23 along with our review in the process on the Proposed 2870 with

(- 24 these NES racks, and we have -- we are at a point that we 25 expect that we -- if you come in with a proposal, the thing you HeritageRef)rtingCorporation (so sas-4 ass

i r

27 3 have given us in this meeting, in writing, we'd expect you to 2 nubmit thin in writing, we would expect to be able to fairly 3 shortly issue the aspects that we have reviewed already and

, 4 document them.

5 Now, we have the bulk thermal hydraulic t

6 considerations that your enhanced fuel pool cooling system 7 deals with. We understand that the details of that's not going

[

8 to be worked out until the end of Cycle 14.

9 We see a second subnitial from you when you have 10 that.

11 MR. MURPHY: Excuse me. Tn terms of our language, -

12 MR. ROONEY: Yeah.

( 13 MR. MURPHY: --

is that -- are we talking about the 14 conceptual design phase of this new system? In that what in you're saying?

1r MR. WESSMAN: Yes, Warren. I think you are.

17 f.e t nie summarize how I think the flow of paper is 18 likely in happen, if I may butt in on you for junt a second, l 19 please.

20 MR. ROONEY: Certainly.

21 MR. WESSMAN: After you all go home from this session 22 today, what we're suggesting that you do in you come back to un j 23 with the request that basically, to some degree, modifies the

( 24 amendment requent that you have on the books today because that 25 is an amendment request taking up to the 2800 number of fuel MeritageRef)rtingCorporation (so sas-4ssa

28 g

1 assemblies and based upon originally the existing system that 2 you have.

. I 3' You need to tell us that you're headed in a different i

4 direction with givjng some indication of the criteria and the i 5 concept of the modified system, which is pretty much what 6 you've said to us today, and that in the interim, you expect to 7 use the new fuel racks up to the 2000 capacity to carry you 8 forward until you've completed the work on the new system and 9 you have staff approval on the new system.  ;

10 I think that's a letter that relatively easy you can il send to un in the not to-distant future.

12 Now, the next step then from us is a response and the ,

k 13 evaluation we've done on the rack design that we've done for 14 your 2800 fuel assembly proposal, we're essentially done with 15 that. So, of course, we should be able to respond back to you 16 in a timely manner allowing you to get on with putting in the 17 racks to carry you forward for the next couple of cycles while 1

18 the rest of the work goes on.

19 The only potentially untidy aspect of that is, it may 20 require a resholly because you are now doing a rack activity 21 that is different than a rack and spent fuel cooling system s c 22 activity. l 23 We don't know the answer to that today, but you see, i 24 you are proceeding down slightly a different path than was  !

25 originally done, and I just don't know how that will go.

Heritage(2o2 Rep)rting sas-4ssa Corporation i

29 1 Then, some time in the future, I guess it's on your 2 Cycle 14 that you say is when you would actually come with us 3 with essentially the details of your conceptual design, a year

. 4 and a half from now, whenever you've got that conceptual 5 design, and that's when we should be able to, based upon that 6 reasonably good knowledge of that conceptual design, we would 7 expect probably to get pretty well done with the SER process on 8 that, which then gets you in a position to go forward.

9 MR. MURPHY: Okay. Let me say something about that, 10 if I can.

11 Our plans are to design and inotall a new system 12 under 5059 and it's our opinion that i t doesn' t require a 13 license amendment to do that.

14 We will submit the design to you, if you ask to look 15 at it, but we don't see that as a requirement if we do it on 16 the 5059, 17 MR. WESSMAN: Okay. When you say the design of the 18 system, what do you mean by "design of the system"? Are you 19 talking about the entire additional train that you're talking l

l 20 about, the concept?

I

. 21 MR. MURPHY: Yes, yes. We see that design l

22 modification as being done under 5059 and not requiring the 23 tech spec change or a license amendment.

I 24 MR. WESSMAN: Okay. I'm not sure that we agree with 25 you at this point in time. I think our perception was that HeritageRef)rtingCorporation (2o s2s-4ssa

30 1 that would involve the amendment process.

2 MR. MURPHY: Okay. What's the basis for that? Why do 3 you feel that way?

, 4 MR. WESSMAN: Well, I think it's -- of course, one, t

5 we're a little bit talking on something that's going to come 6 because you're talking a conceptual configuration, and I guess 7 we don't know enough about your conceptual configuration and 8 how it may or may not tie into the plant as designed and as 9 reviewed. .

10 I think early in the session, we talked about using 11 come portionc of the old system or a wholly new system. I 12 don't think -- you know, you don't know or we don't know ,

(A 13 exactly how it ties in, but it sounds like it's going to have 14 some relation to the plant as designed, as originally reviewed, 15 and that would move it into our review space.

16 Am I saying it right, technical folks? Help me out.

17 MR. MURPHY: It's not necessarily true.

18 MR. THADANI: I think -- it seems to me that the 19 termination of 5059 is up to you. You make that decision. You 20 can make a modificatiori under 5059. We may or may not agree 21 with you, and at this stage, at least, I can't say for sure i

22 that we believe there is an unreviewed safety question, 23 therefore you must come in with a submittal. I don't think we i 24 know the answer, at least I don't.

25 Does anybody else want to comment on that?

Heritage(202 Rep)rting Corporation 628-4888

31 1 MR. WEISMAN: Well, look, maybe I can be perfectly i 2 cicar here. I 3 What we're trying to say is, at least from today's i

, 4 meeting, we believe from a technical point of view, your 5 submittal can be justified for fuel storage up to 2000 6 elements. That's what we think.

7 For storage up to 2800 elements, I believe, which in 8 what you'd like to have in the future, it's dependent on a new 9 design. So, the exact legal procedures, what you follow from lo here on in, is still under discussion by us, but as far as the 1 11 5059, I got one question for you.

12 Do you have a license condition now limiting the 13 number of elements you can store on site, fuel elements?

14 MR. MURPHY: That's right.

15 MR. WEISMAN: Well, if you go to 2800, it would seem 16 to me that that would require some sort of an amendment. ,

L 17 MR. MURPHY: Oh, it does, and we've applied for that. [

L 18 That's what we're --

19 MR. WEISMAN: The approval that we would give you at 20 this stage of the game would be to 2000 elements. That's what 21 we're trying to tell you. All right. We understand your 22 criteria for future expansion under the system, and we think 23 it's a good criteria, all right, but how you get there for the I 24 final resolution of the 2800 from a legal point of view as was 25 said by Vern and all, it may need a renotice or reshally.

HeritageRef)rtingCorporation (2o s2s-4ssa

0 32

, 1 We haven't determined that.

l >

, 2 MR. MURPHY: Okay. Fair enough, and we may conclude, 3 in fact, it needs a license submittal or amendment.

. 4 MR. WEISMAN: Right.

5 MR. MURPHY: The other thing I wanted to make clear 6 10 that our plans, if you agree with this, when we install the 7 new racks, we want to install, for a number of reasons, wo want 8 to install the capacity of 2870, but be limited to a use of 9 2000.

10 MR. WEISMAN: Right.

11 MR. MURPHY: Okay. Is that clear?

12 MR. WESSMAN: Okay. I understood that clearly.

33 You're saying if you do work on the racks in the next 14 six montho, the next year or two, you want to install all the 15 way to 2870, but have the limitation of use to 2000.

16 MR. MURPHY: That's right.

17 MR. WESSMAN: So that, basically, you've finished 18 that portion of the work for the comprehensive change that you i

19 want. ,

i 20 MR. REID: We already have the limit to use of 2000.

21 MR. WESSMAN: I understand. We're going to have to 22 think on that. I'm not sure we fully appreciate it exactly 23 because I thought you were actually going to modify a corner of i 24 the pool to get yourselves up conveniently to 2000 and in a 25 sense, it may be that the license condition is all it takes.

MeritageRef)rtingCorporation (so sas-4ses

33 1 Sut let's think on that. I don't think I can answer 2 that today, but I u.:durstand what you're saying.

3 MR. MURPHY: It's a just more much officient way to 4 do the job.

5 MR. WESSMAN: Certainly. I understand that. Okay.

6 MR. THADANI: I don't see - does anyone see any 7 problem with that? At least I don't.

8 MR. WERMIEL: No. I was going to say --

9 MR. RIDGELY: Not from a technical standpoint.  ;

10 MP. WERMIEL: Not from a technical standpoint.

11 There'n no prob 1cm with that.

12 MR. WESSMAN: Okay. Well, maybe wn have our answer.

13 We want t o think a little bit and be sure that we're 14 comfortable with that just by virtue of you have a capability 15 to do more than the license says, and yet you are bound by what 16 the license says, and yet is there some other issue about a 17 heavy load over another one of these racks somewhere eine, but 18 it sounds like we're saying it's okay.

19 Okay. What cise? You had another question on what we 20 started to say or did you finish summarizing, Vern? ,

t 21 MR. MURPHY: I made the two points that I wanted to 22 make. ,

23 MR. ROONEY: You made the -- okay. Very good.  ;

i 24 so, I think we would expect a submittal shortly after 25 thic meeting from you, putting on the record what you have told i

Meritage(202 Rep)rting Corporation 624-4884

34 1 us.

2 We intend to issue a safety evaluation covering thoue 3 portions of the review we've completed to this point shortly.

. 4 We would expect you to provide further detail on the new system 5 when you've reached the point that you can speak more 6 specifically to it, and I guess we would like that in the form 7 of a submittal at the end of conceptual design.

8 Am I speaking correctly for the staff here?

9 MR. MURPHY: Okay. Regardless of the determination 10 of 5059 and the license amendment?

11 MR. WESSMAN: That's the determination that's 12 described in your schedule.

( 13 MR. ROONEY: Yeah. Wo have yet to work out the 14 procedural aspecto.

15 Staff, have I let anything major out? I hope not.

16 MR. WESSMAN: Any other thoughts, Warren, at this 17 time?

18 MR. MURPHY: Again, 7 just want to be el aus that if 19 we give you our proposal in writing, basically tell you in 20 writing what we told you today, the result of that will be an 21 SER that would allow us to install the new racks?

22 MR. WESSMAN: That's our expectation.

23 MR. ROONEY: I guess this coupletes the matter we

' 24 sought to accomplish in this meeting.

25 Now, I think that we ought to -- I'm open to

~

NeritageRef)rtingCorporation (ao sas-esse

35

, i questions from members of the public or comments at this point,  ;

2 and we'll do what we can to answer them, as we said.

3 MR. WESSMAN: And, John, do you or Phil have anything ,

. 4 else you wanted to ask the staff at this time?

5 MR. RIDGELY: No. I have a question, but I've had it 6 answered.

7 MR. ROONEY: Okay. Very good. Joe?

8 MR. DEAN: The only question I have -- Georgo Dean, t

9 THE REPORTER: The gentleman has got to come up.  !

10 MR. DEAN: Would be whether the staff intonds to do a ,

t 11 new environmental impact statement 91th respect to this new I r

i 12 proposal in consideration of the alternatives.

( 13 It seems to me that this is an entirely new proposal  !

14 to get the 2800 on the floor, which is going to involve an  !

t 15 additional substantial sum of money being expended. ,

16 MR. WESSMAN: Okay. I don't know that the staff has  ;

i 17 decided how to do the environmental aspect. We've got your  ;

I 18 question and let us think on it.

19 MR. SOINTO: Yeah. I -- let me interject. It's our r

l 20 position that we have it. It is not necessary to do an i

. 21 environmental impact statement for the application we sought.  !

22 We've been doing an environmental impact appraisal. I would be ,

i 23 surprised if this change changed that basic position. I would I'

l 24 be surpriced to see us do an environmental impact appraisal on 25 this, but in view of the por.ition we took in the proceeding, I HeritageRef)rtingCorporation (so sas-4ses i

> i

- - - - . . . , . - - m__.,. . . . , - , . _ . _ _ _-,m_, . .

36 1 would be surprised to see us do an environmental impact 2 statement.

-O 3 MR. DEAN: That answers my question.

4 MR. ROONEY: Arc there further questions?

5 (No response,)

6 MR. ROONEY: Moeting adjourned.

7 Thank you for coming in.

8 (Whereupon, at 11:30 a.m., the hearing was 9 adjourned.)

10 11 12 C, 13 14 -

15 16 17 18 19 20 21 22 [

l 23

(- 24 25 NeritageReE)rtingCorporation (so sis-4ssa

l t 1

1 1 l

_ REPORTER'S CER*IFICATE i< '

l 2 .

l 3 DOCKET NUMBER: j 4 CASE TITLE: Spent Fuel Capacity at Vermont' Yankee Nuclear Plan I

5 HEARING DATE: February f, 1988 6 LOCATION: Rock'ville, MD 7

I hereby certify that the proceed,ings and evidence 8 .

are contained fully and accure.tely on the tapes and notes j 9

reported by me at the hearing in the above case before the .

10 United States Nuclear Regulatory Authority. l 1

11 12  ;

i 13

( Date: 2-9-88 i

14  !

1E i o$lLM k .~' k h 5 Official Reportbr l 37 i HERITAGE REPORTING CORPORATION }

gg 1220 L Street, N.W. j' Washington, D.C. 20005 l gg .

i l 20 21 ,

I 22 l s '

1 I

23 ,

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25i, HER;TAGE REPORTING CORPORATION (202)623-4888

wz1s i

MEETING

SUMMARY

l DISTRIBUTION -

w Docket ~ File NRC Particoants NRC & Local PDRs VRooney PDI-3 R/F DWessman RWessman JRidgely OGC AThadani EJordan Glainas JPartlow JRutberg ACRS (10) AChu HBClayton JKudrick RWeisman AHodgdon

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