ML20206B670
| ML20206B670 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 04/21/1999 |
| From: | Gaukler P AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#299-20319 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9904300027 | |
| Download: ML20206B670 (1) | |
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! 243/9 SHAW PITTMAN POTISeTROWBRIDGE DOCKETED USNPc 2300 N Screet. N.W.
Wadungton. DC 20037 1i28
.m APR 29 P4 :16 202.663.8000 Facsimile 202.663.8007 PAUL. A. CAUKLEA New York OF;4d,l..
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April 21,1999 Secretary of the Comnussion U. S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint North Rockville, MD 20852-2738 Attn: Docketing & Services Branch Re:
Private Fuel Storage - Docket No. 72 ASLBP No. 97-732-02 i
To the Secretary of the Commission:
Enclosed please find (1) the original Affidavit and Verification of John D. Parkyn filed in conjunction with Applicant's Objections and Responses to the State of Utah's First Set of Discovery Requests and (2) the original of the Afridavit of William Hennessy filed in support of Applicant's Motion for Summary Disposition with respect to Contention Utah C.
The affidavits filed with both of these documents on April 21 were facsimile copies.
Please call me at 202-663-8304 if you have any questions.
Sincerely, aok4 Paul A.Gaukler cc: (Without enclosure)
G. Paul Bollwerk.Ill, Esq.
Dr. Jerry R. Kline Dr. Peter S. Lam Adjudicatory File, Atomic Safety and Licensing Board Panel Sherwin Turk, Esq.
Denise Chancellor, Esq.
Diane Curran, Esq.
John Paul Kennedy, Sr., Esq.
Richard E. Condit, Esq Joro Walker, Esq.
Danny Quintana, Esq.
9904300027 990421 PDR ADOCK 07200022 C
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensine Board in the Metter of
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PRIVATE FUEL STORAGE LLC.
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Docket No. 72 22
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(Private Fuel Storage Facility)
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AFFIDAVIT AND VERIFICATION OF JOHN D. PARKYN CITY OF LA CROSSE
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STATE OF WISCONSIN
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John D. Parkyn, being duly sworn, states as follows:
I am Chairman of the Board of Private Fuel Storage L.L.C. (PFS), a limited liability company organized and existing under the laws of the State of Delaware with its principal oflice currently located in La Crosse, Wisconsin. I have read the foregoing answers to the State's interrogatories and requests for admission and verify that the same are true to the best of my information and belief.
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7ohn D. ParkyV l
Sworn to before me this l
21st day of April,1999 0
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,,Apr J1-88 02:38se Fros-5 HAW PITTIN 2C26630087 T-550 P E6/:0 F-?D7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board la the Mauer of
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PRIVATE FUEL STORAGE L.L.C.
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Docket No. 72-22
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(Private Fuel Storage Facility)
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AFFIDAVIT OF WILLIAM HENNESSY l
CITY OF CitARLOTTE
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STATE OF NORTH CAROLINA
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William Hennessy, being duly sworn, states as follows:
1.
I am the Assistant Project Manager and Lead Licensing Fape with Stone &
Webster Engineering Corporation (Stone & Webster) for the Private Fuel Storage Facility (PFSF). Stone & Webster is the architeet-engineer for the PFSF. My professional and educational experience is summarized in the curriculum vitae attached as Exhibit 1 to this affidavit.
2.
In my capncity as Stone & Websect Assistant Project Manager and Lead Licensing Engineer for the PFSF, I oversaw the preparation and am knowledgeable of the radiation dose calculations prepared on behalf of Private Fuel Storage, L.L.C. (PFS) for the licensing of the PFSF by the Nuclear Regulatory Commission (NRC). I am also familiar with Contention Utah C raised by the State of Utah in the NRC licensing hearing for the PFSF.
3.
Based on then existing NRC Staff guidance, the PFS initial License Application dated June 20,1997, analyzed the dose consequences for a postulated loss of confinement accident assuming a hypothetical, non-mechanistic breach of a canister storing spem fuel at the S$oculpi} 4g
.Ap4ble.Ot:40ss Fene-5 W PIT 7 W 2026630007 T-553 P97/89 F-787 PFSF. The fission product release fractions from NUREG-1536 were used in performing this calculation. It was further asstaned, based on information from SandiaNational Laboratories Report SAND 80-2124 " Transportation-Accident Scenarios for Corsdal Spent Fuel," that 90 percent of the particulate and volatile fittian products of various radionuclides (Co-60, Sr-90, I-129, Ru-106, Cs-134, and Cs-137) released from spent the fuel assemblies would be held up within the breached canister and would not escape to the a=-mmc. PFSF Safety Analysis Report (SAR), Section 8.2.7.2. It was also assumed, based on information from SAND 80-2124, that only 5 percent of the isotopes Co-60 and St-90 were of a size that would be respirable by a person. SAR at Section 8.2.7.3. On that basis, PFS alW the total effective dose equivalent resulting from this hypothetical canister breach to an individual assumed to be located at the closest point on the boundary of the Owner Controlled Area front nhalatian of radionuclides in i
the plume and exposure to direct radiation from the plume (submersion). Secondary enviic s.1 pathways, such as direct exposure to contaminated soil, inhalation and ingestion of cantamiaaned soil, and ingestion of milk and beef from animals that have grazed on grass / fodder grown in co==ta~d soil, were not included in this calculation because the comribution from such pathways was believed to be negligible.
In its second round Requests for Additional Information (RAI) dated December 4.
10,1998, the NRC requested PFS in RAI 7-1 to analyze the dose consequences for a, Wad loss of canh*=*ar accident in accordance with the most recent Staff guidance provuled in Interim Staff Guidance 5 (ISG 5)(October 6,1998) which provides for the calculation of radiation doses resulting from canister leakage, with the leak rate based in part on the closure lid weld helium leak test acceptance criteria. PFS performed the analysis of the canister leak f
accident in accordance with lSG-5 for hypothetical accident conditions, and submitted the results of this analysis (which constituses the new PFSF licensing basis for accident dose consequenc in its.spensc to RAI 7-1. PFS's response to RAI 7-1, filed under cover lener dated February 10,1999,is =-hed as Exhibit 2 to this affidavit. A copy of PFS's w:==- to the second round RAIs, including PFS's respotise to RAI 7-1, was sent to the State of Utah via overnight mailon February 11,1999. A copy of the calculations and other backup to PFS's responses, including the backup calculations for PFS's r-* to RAI 7-1, were sent to the State for next j
business day delivery on February 13,1999.
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I have reviewed the State's bases underlying the three subparts of Contention Utah C as well as the comention itself. PFS's new calculation of radiadon doses described in PFS's response to RAI 7-1 addresses the issues raised in each ofthe three subpans of Utah C.
6.
In subpart 1 of Utah C, the State claims that PFS's original calculation W selective and inappropriate use of data firom NUREG-1536 for the fission product release fraction." PFS's new calculation, however, no longer uses the fission product release fraction from NUREG-1536, but now relies on NUREG 1617 for the release fraction in accordance with ISO-5. Nor does PFS's new calculation rely on NUREG-1536 in any other respect. In its bases to subpart 1 of Utah C, State specifically takes issue with the assumption used in PFS's original j
calculation that 90 percent of the volatile fission products assumed to be released from the spent fuel would plateout or holdup in the canister and therefore could not escape into the j
environment. In PFS's new calculation, however, *[n]o credit was taken for holdup (planeout, deposition, etc.) of particulates or volatile tission products released from the fuel inside the j
canister." Response to RAI 7-1, at 2. Rather, the cMeian conservatively assumes that 100%
of these radionuclides assumed to be released frosn the spent fuel rods are available for release from the canister.
7.
In subpan 2 of Utah C, the State takes issue with the assumption used in PFS's i
original calculation that only 5 percent of the isotopes Co-60 and Sr-90 released from the spent fuel will be of respirable size. PFS's new calculation no longer uses, however, the assumption contained in SAND 80-2124 that only five percent of the isotopes Co-60 rad Sr-90 released from the spent fbel will be respirable, nor does it rely on SAND 80-2124 in any other respect. Rather, in PFS's new calculation "the respirable fraction of the material released for all radionuclides is i
assumed to be 1.0," or 100 percent. Response to RAI 7-1, at 2.
8.
In subpart 3 of Utah C, the State takes issue with PFS's original calculation ha-it did not consider dose pathways from direct radiation and ingestion of food and water.
PFS's new calculation, however does calculate the potmanal radinian doses from applicable ense =ed pathways following the deposition of radioactive material in the plume from an accident, in addition to doses from inhalarion and direct shine from the passing plume. Response to RAI 7-1, at 3-4. The new calculation -includes direct exposure to comaminated ground, 3
o -.4r41-90 02:41m Free-5HMF PITTIN 2026631387 T-553 P CS/39 F-?a7 inhalation of resuspended radioactive material, ingestion of milk and beef following gr ingestion of soil." Response to RAI 7-1, at 4. Water was not included as an applica pathway because such a pathway would need to involve surface drinking wate significance. As stated in Section 2.5.1 of the PFSF Environmental Report, howe are no public or private surface drinking water supplies in the PFSF vicinity.... C there is no potable surface water supply that could be subject to nonnal or accidenta from the facility.
f William Hennessy Sworn to before me this M _ day of April 1999.
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