ML20206C436
| ML20206C436 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/10/1988 |
| From: | Ferster A HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| CON-#488-7492 OLA, TAC-65253, NUDOCS 8811160276 | |
| Download: ML20206C436 (14) | |
Text
,
YkE g, ELATED CURIESNNN November 19gdQ@
emc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'88 MN 14 P4 :12 Before the Atomic Safety and Licensing Board
.vrwr In the Matter of
)
)
Vermont Yankee Nuclear
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Power Corporation
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Docket No. 50-271-OLA
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(Vermont Yankee Nuclear
)
Power Station)
)
)
NECNP'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO VERMONT YANKEE ON THE NRC ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT - SPENT FUEL POOL EXPANSION, (TAC NO. 65253)
INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under cath by an employee, representative or agent of the Applicaqt with personal knowledge of the facts or information requested in each interrogatory.
For each question, please identify by name, job title and address each person who prepared or assisted in preparation of the response.
The following definitions shall apply to these inter-rogatories and document requests:
1)
"Document" shall mean any written or graphic matter of communication, however produced or reproduced, and is intended to be comprohonsive and include without limitation any and all cor-respondonce, lottors, tolograms, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, noticos, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microficho, charts, analyses, intra-corporate or intra-offico 8911160276 001110 PDR ADOCK 05000271 0
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communications, notebooks, diaries, sketches, diagrams, forms, manuals,. brochures, lists, publications, drafts, telephone
' minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.
2)
"Identifv" with respect to any document shall mean to state the following:
the document's title, its date, the author of the document, the person to whom to document was sent, all persons who receivsd or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies af the document.
3)
"Identifv" with respect to any action or conduct shall mean state the following regarding any such action or conduct:
i i
the pers,on or persons proposing and taking such action; the date such action was proposed and/or taken; all person 9 with knowledge or information about such action; the purpose or proposed effect i
of such action; and any document recording or documenting such I
action.
4)
"Identify" with respect to an individual shall mean stato the individual's name, address, employer, occupation, and titic.
5)
"Describe" with respect to any action or mattor shall i
mean state the following regarding such action or matter:
the substance or nature of such action or matter; the persons partic-ipating in or having knowledge of such action or matter; the cur-rent and past business positions and addresses of such porwans; i
~;
I 4 and the e:cistence and location of any and all ' documents relating to such action or matter.
6)
"VY"_or_"hpplicant" shall refer to the Vermont Yankee Nuclear Power Corporation.
7)
"Staff" shall refer to all persons employed by the NRC at headquarters or regional offices, including contractors hired by NRC.
8)
"Environmental Assessment" or "EA" shall refer to the "Environmental Assessment and Finding of No Significant Impact -
Spent Fuel Pool Expansion, Vermont Yankoo Nuclear Power Station (TAC No. 65253), issued by the NRC Office of Nuclear Reactor Regulation on July 25, 1988.
9)
"Pronospd Action" shall refer to Vermont Yankee's request,for an amendment to the Vermont Yankee Facility Operating Licenso DPR-28 to allow the expansion of the increased storage capacity of spent fuel in the spent fuel pool to 2870 fuel assem-blies, as described in Section 1.1 of the Environmental Assess-mont.
INTERROGATORIES AND DOCUMENT REOUESTS 1.
Pleare identify all persons who participated in the preparation of answers to those interrogatories, and identify the portions of your responso to which each person contributed.
Questions to Vermont Yankoo re Environmontal Assessment 2)
Identify and provido copies of all environmental reports or other information furnishod to the NRC for purposes of the proposed action, including but not limited to environmental reports submitted under 10 C.F.R. 55 51.41 or 51.60.
+
t t 3)
In its evaluation of alternative five (5) to the pro-l posed action, construction of a new independent spent fuel storage installation (ISFSI), identifying dry cask storage installation, the En'rironmental Assessment concluded that dry i
cask storage installation is not feasible as an alternative to 4-l the proposed license amendment because "this alternative could not be implemented in time to meet the need for. additional capac-l ity for the Vermont Yankee Plant" (EA, page 4, 5).
The following questions relate theretot State or provide an estimate of how much time (months a.
i
)
and years) it would take for VY to develop new site specific i
l dcsign and construction of a dry cask storage facility, i
I starting from the date a new license amendment application i
is, filed with the NRC, to the date (projected) cuch license f
' amendment will be approved by the NRC.
b.
State or provide an estimate of how much time (months and years) it will take for VY to implement the proposed action, starting from the date the license amendment l
r application was filed with the NRC (i.e. April 25, 1986), to l
[
the date the enhanced spent fuel pool cooling system will be designed, installed, and tested to demonstrate operability.
t I
Did VY or its contractors prepare or use any analysis, c.
study or otner document that compares the time it would take l
t to develop new site specific design and construction of a dry cask storage facility with the time it would take to develop and install all equipment necessary to implement the proposed action, includir.g the time necessary to design and
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4,
p install a spent fuel pool cooling systea that meets current NRC regulatory requirements.
If yes, please provide a copy of any documents containing such analysis.
If not, please explain the basis for the EA's conclusion that dry cask storage installation could not be designed and constructed in time to meet VY's need for additional capacity.
d.
Describe, by task, the economic costs (projected) to Vermont Yankee of designing and installing a dry cask storage facility, including bu,t not limited to the purchase of equipment and payments to outside con.
5 e.
Describe, by task, the economic costs (projected) to 4
Vermont Yankee of the proposed action, including but not limited to the costs of designing and installing the enhanced spent fuel pool cooling system, and the costs of participating in the instant, contested license amendment proceeding.
4)
In its evaluation of alternative five (5) to the pro-posed action, construction of a new independent spent fuel storage installLtion (ISFSI), identifying dry cask storage i
installation, the EA concluded that dry cask storage installation is not feasible as an alternative to the proposed license amend-ment because, inkgr alla, "the expansion of r5e existing pool is a resource that should be used".
The following questions relate thereto:
Identify and describe the "expansion" capacity of tne a.
existing pool, and state whether this expansion capacity assumes the use of high density racks, the installation of i'
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. 1 additional racks of the existing design, and/or the storage of an increased number of spent' fuel rod. assemblies beyond that authorized under Vermont Yankee's current technical specifications.
b.
Lescribe what the "expansion" capacity of the existing pool would be if no changes are made to the number of spent fuel rod assemblies authorized under Vermont Yankee's cur-rent technical specifications, c.
Is this statement based on an assessment of the eco-nomic costs of implementing the dry cask storage ald.arna-tive, as compared to the costs of using the "resource" of the existing pool?
If yes, please identify what those eco-nomic costs are.
- 5),
The EA (page 8) states that "By telephone conversations on July 7, 1988 the licensee informed the staff that the dose for installation of the enhanced spent fuel pool cooling system has been estimated very conservatively to add less than 10 person-rem to the original dose goal."
The following questions relate therato:
a.
Describe in detail what activities necessary or incident to the installation of the enhanced spent fuel pool cooling system added to this 10 person-rem addition to the dose goal.
b.
Identify and provide copies of all documents used or generated by the NRC or its contractors, including environmental reports and other information provided by Ver-mont Yankee, to assers, evaluate, or review the radiological
r
.c 7-y impact attributable to installation of the enhanced spent
- fuel pool cooling system.
6)
The EA's assassment of public radiation exposure (EA, pages 8-9), based on the Licsnsee's dose goal for the proposed action, including the installation of the enhanced spent fuel pool cooling system, will result'in a radiaticn dose goal of 33
-i person-rem.
The following questions relate thereto a.
Please state the total number of persons who will i
be exposed as a result of the proposed action taken into l
consideration in projecting a radiation dose goal of 33 person-rem from the proposed action, b.
State the surface dose from the water, in mil-lirems per hour, that each worker will be exposed to as a j
result of the proposed action.
7)
The EA (page 8) states that "The 33-person rem dose goal includes all activites (sic) necessary for the raracking l
operation including vacuum cleaning of SFP walls and floor; shuf-fling fuel, installation of the new racks; removal of the old e
racks; cleaning decontamination, and any necessary cutting of old racks; and disposal of waste resulting from the rereacking (sic) operation, incluling the old racks.
The following questions relate thereto:
i Provide a break-down of the projected radiation a.
dose goals attributable to each of the above-described
}
I activities.
b.
State how many persons will be required or used to i
perform each of the above-described activities.
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. c.
Describe the length of time (in hours) each such person identified in response to Interrogatory No. 7(b) will r
be exposed and what the millirem dose per hour will be to perform each of the above-described activities.
s d.
Aro there any other activities that may be per-formed during the raracking operation other than those 4
identified above?
If yes, please identify each such activity, provide the projected radiation dose resulting from each such activity, the number of persons who will be used or required to perform uach such activity, the length of time each such person will be exposed, and the millirem dose per hour to perform each such activity.
Identify and produce copies of all relevant documents.
- 8).
If the number of persons identified in response to II:' orrogatory No. 6(a) and Interrogatory No. 7(b) are different, explain the reasons for this difference.
9). In estimating that the proposed action, including the installation of the enhanced spent fuel pool cooling system, will result in a radiation dose goal of 33 parson-rem, please state whether VY considered any of the following occurrences:
The possible radiation dose exposure which might a.
result if a worker breaches.is or her protective garments during the installation of new racks.
b.
The possible radiation dose exposure which might result if a worker breaches his or her protective clothing during the installation of the enhanced spent fuel pool cooling system.
1 c.
The possible radiation dose exposure which might result if a worker drops a rack during the installation of the new racks.
d.
The possible radiation dose exposure which might I
result if a worker drops a spent fuel assembly during the installation of the new racks.
The possible worker exposure to radioactive gamma a.
rays released to the spent fuel pool if the purification filter does not work.
f.
The possible worker exposure to cesium or iodine resulting from.eaking spent fuel rods.
10)
If your answer is yes to any of the occurrences described in Interrogatory 9(a) through (f), state the projected radiation dose attributable to each such occurrence, the number of persons who will be exposed to such radiation, and the length of exposure, in millirems per hour, attributable to each such occurrence.
Provide copies of all relevant documents.,
11)
The EA (page 8) states that "hhe' dose for installation of the enhanced spent fuel pool cooling system has been estimated s
very conservatively to add less than 10 person-rem to the original dose goal."
The following questions relate thereto:
a.
Describe in detail what activities necessary or l
incident to the installation of the enhanced spent fuel pool 1i, cooling system contributed to this 10 person-rem addition to l
l the dose goal.
b.
Identify and provide copies of all documents used or generated by the NRC or its contractors, including L
. environmental reports and other information provided by Ver-mont Yankee, to assecs, evaluate, or review the radiological impact attributable to installation of the enhanced spent fuel pool cooling system.
12)
The EA (page S) states that the Licensee's projected dose goal for the proposed spent fuel. pool modification project before committing to add an enhanced fuel pool cooling system "is based on information gained by reviews of the experience gained with similar projects at other plants'."
The following questions relate thereto:
Identify each of these plants and the applicable a.
4 proceeding or context in which such reviews occurred (i.e.
4 license amendment, review under 10 C.F.R. 5 50.59), and pre-cise nature of the project.
Identj'y and produce copies of 4
1 any documents containing such evaluation or analysis.
b.
For each plant, state whether VY has performed, or otherwise acquired, an analysis, evaluation, review, or measurement of actual occupational dose exposure resulting from replacement of original fuel racks and the installation of new fuel racks in the spent fuel pool, and made a com-parison between actual dose exposure and projected dose exposure.
If yes, for each plant, describe the results of such comparisons, and provide copies of any documents con-taining such comparisons.
In any of these similar projects wr.s the c.
anticipated, estimated, or projected radiation dose exposure different from the actual dose exposure?
If yes, identify
. the plants, and explain why the projccted dose exposure was inaccurate.
13)
The EA (page 9) states one potential source of radia-tion to workers during the rerack operation is crud released to l
the pool water because of fuel movement during the proposed spent l
fuel pool modification.
The following questions relate thereto a.
Did VY consider the possibility that crud would be released from the old racks as a result of the movement or i
shuffling of the racks during the raracking operation?
If yes, state how much of the 33-rem dose goal is attributable
)
to the release of crud from the old racks.
If no, explain why you did not consider this possibility.
b.
Did VY consider the possibility that crud would be i
i released from tha spent fuel assemblies stored in the old racks as a result of the shuffling of fuel during the reracking operation?
If yes, stete how much of the 33-rem dose goal is attributable to the release of crud from spent j
fuel assemblies.
If no, explain why you did not consider f
this possibility.
r c.
How much crud will be released from the old racks f
as a result of the movement or shuffling of the racks during
[
the reracking operation?
Describe your method for making or j
estimating this amount, and identify and provide copies of
}
all documents generated or relied on by VY in estimating f
f i
this amount.
d.
How much crud will be released from the spent fuel assemblies stored in the old racko as a result of the shuf-l i
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i
_______ _ _ _ fling of fuel during the raracking operation?
Describe your method for making or estimating this amount,.and pro-vide copies of all documents generated or relied on by VY in estimating this arount.
a.
What is the delay time (in minutes, hours, or days) for the purification system to completely filter out crud from the spent fuel pool after the crud is disturbed and released into the spent fuel pool coolant.
14)
Has VY ever stored /or placed irradiated.nonfuel reactor components in the spent fuel pool?
If the answer is yes, please respond to the following questions:
2 a.
Did-you consider the possibility of worker exposure to radiation from these components in the event of a leak in thq spent fuel pool which exposes these components?
If yes, state how much of the 33-rem dose goal is attributable to such exposures.
If no, explain why you did not consider l
this possibility.
- 15) Please identify all persons on whose factual knowledge, i
opiriions, or technical expertise you rely or intend to rely for your position on NECNP's environmental contentions.
)
- 16) Please identify all persons you may call as witnesses on NBCNP's environmental contentions.
Please describe the substance of their testimony; and identify and describe any documents and i
I i
i l
i m
. the portions thereof that they may rely on for their testimony.
Respectfully submitted JW Andrea Forster HARMON, CURRAN & TOUSLEY 2001 "S" Street N.W.
Suite 430 Washington, D.C.
20009 (202) 328-3500 CERTIFICATE OF SERVICE I certify that on Noverber 10, 1988, copies of the forego-ing pleading were served by first-class mail, or as otherwise indicated, on all parties listed below.
Charles Bechhoefer, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Glenn O.
Eright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commiss'on Washington, D.C.
20555 Dr. James H. Carpenter Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Secretar** of the Commission Attn:
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Christine N.
Kohl, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 George Dean, Esq.
Assistant Attorney General Commonwealth of Massachusetts Department of the Attorney General One Ashburton Place Boston, MA 02108 Samuel Press, Esq.
Vermont Department of Public Service 120 State Street i
(;
o f.
.s.
- 14'-
Montpelier, VT 05602 Ann Hodgdon, Esq.
office of the General Counsel Bethesda U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Diana Sidebotham R.F.D.
- 2 Putney, Vermont 05346 R.K. Gad III **
Ropes & Gray 225 Franklin Street Boston, MA 02110 Gary J. Edles Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
t Howard A. Wilber Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission c
Washington, D.C.
20555 Geoffrey M. Huntington, Esq.
Office of the Attorney General Environmental Protection Agency State House Annex 25 Capitol Street Concord, ITH 03301-6397 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 t
N,.
__ m_.
i Andrea Ferster
- By overnight mail 1
4