ML20206C493
| ML20206C493 | |
| 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: | NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#488-7494 OLA, TAC-65253, NUDOCS 8811160303 | |
| Download: ML20206C493 (15) | |
Text
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RELATED CORRESPONogNcg of November g g 88 s
USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'E8 NW 14 P4 :12 Before the Atomic Safety and Licensing Board-
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(
In the Matter of
)
)
Vermont Yankee Nuclear
)
Power Corporation
)
Docket-No. 50-271-OLA
)
(Vermont Yankee Nuclear
)
Power Station)
)
)
NECNP'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF.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 oath by an employee, representative or agent of the NRC with peysonal knowledge of the facts or information requested in each interrogatory.
For each question, plea e 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 comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, microfiche, charts, analyses, intra-corporate or intra-office 3
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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.
3 2)
"Identify" 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 received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.
3)
"Identlig" with respect to any action or conduct shall mean state the following regarding any such action or conducc:
the pers.on or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect 1
of such action; and any document recording or documenting such action.
4)
"Identifv" with respect to an individual shall mean state the individual's name, address, employer, occupation, and title.
5)
"Describe" with respect to any acolon or matter shall mean state the following regarding such action or matter:
the substance or nature of such action or matter; the persons partic-I ipating in or having knowledge of such action or matter; the cur-rent and past business positions and addresses of such persons; 1
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and the existence and location of anysand all documents relating to such action or matter.
J 6)
"VY" or "Acolicant" 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 13f No Significant Impact -
Spent Fuel Pool Expansion, Vermont Yankee Nuclear Power Staticn (TAC No. 65253), _ issued by the NRC Office of Nuclear Reactor Regulation on July 25, 1988.
9)
"Procosed Action" shall refer to Vermont Yankee's request,for an amendment to the Vermont Yankee Facility Operating License DPR-28 to allow the expansion of the increased storage caphcity of spent fuel in the spent fuel pool to 2870 fuel assem-blies, as described in Section 1.1 of the Environmental Assess-ment.
INTERROGATORIES AND DOCUMENT REOUESTS 1.
Please identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each person contributed.
2)
The following questions the Environmental Assesonent's radiological impact assessment for the proposed action (Section 3):
Identify and provide copies of all documents used in or a.
generated during your analysis, or evaluation of che
i
-4 radiological impacts of the proposed action, including but not limited to environmental reports or information fur-a nished by Vermont Yankee.
Identify by name, job. title and address all persons (including contractors) who participated i
in or will participate in any such evaluation and describe their roles and tasks during that evaluation.
b.
Describe the process by which your evaluation of radiological impacts of the proposed action was undertaken and the time period involved; describe committees estab-lished, contractors hired, meetings or deliberations held.
c.
Identify all rules, criteria, standards or guidance, whether or not formally promulgated, which the staff used or applied in analyzing or evaluating the anticipated rad,1clogical impacts of the proposed action.
3)
The EA's assessment of public radiation exposure (EA, pages 8-9) concluded that the proposed action, including the installation of the enhanced spent fuel pool cooling system, will result in a radiation dose goal of 33 person-rem.
The following questions relate thoroto:
a.
Please state the total number of persons who will i
be exposed as a result of the proposed action taken into consideration in projecting a radiation dose goal of 33 l
u person-rom from the proposed action.
b.
State the surface dose from the water, in mil-lirems por hour, that each vorker will be exposed to as a result of the proposed action.
t
e 1 4)
The EA (page 8) states that "The 33-person rem dose goal includes all activites (sic).necessary_for the reracking f
operation including ' scuum cleaning of SFP walls and floor; shuf-fling fuel, installativt of the new racks; removal of the old racks; cleaning decontami'ation,-and any necessary cutting of old racks; and disposal of waste resulting from the rereacking (sic) operation, including the old racks.
The following questions relate thereto:
a.
Provide a break-down of the projected radiation dose goals attributable to each of the above-described activities.
b.
State how many persons will be required or used to perform each of the above-described activities.
c.
Describe the length of time (in hours) each such person identified in response to Interrogatory No. 4(b) will f
be exposed and what the millirem dose per hour will be to perform each of the above-described activities.
I d.
Are there any other activities that may be per-l formed during the raracking operation other than'those l
identified above?
If yes, please identify each such j
activity, provide the projected radiation dose resulting from each such activity, the number of persons who will be used or required to perform each such activity, the length i
i of time each such person will be exposed, and the millirem f
dose per hour to perform each such activity.
Identify and produce copies of all relevant documents.
L
. 5)
If the number of persons identified in response to Interrogatory No. 3(a) and Interrogatory No. 4(b) are different, explain the reasons for this difference.
6)
In concluding that the proposed action, including the installation of the enhanced spent fuel pool cooling system, will result in a radiation dose goal of 33 person-rem, please state whether the NRC considered any of the following occurrences:
a.
The possible radiation dose exposure which might result if a worker breaches his 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.
The possible radiation dose exposure which might c.
result if a worker drops a rack during the installation of the now racks.
d.
The possible radiation dose exposure which might result if a worker drops a spent fuel assembly during the installation of :he now racks.
' he possible worker exposure to radioactive gamma o.
rays coloased to the spent fuel pool if the purification filter does not work.
f.
The possible worker exposure to cosium or iodino resulting from leaking spent fuol rods.
7)
If your answer is yes to any of the occurrences described in Interrogatory 6(a) through (f), stato the projected radiation doso attributable to each such occdrrence, the number t
i
. of persons who will be exposed to such radiation, and the length of exposure, in mi?.lirems per hour, attributable to each such occurrence.
Provide copies of all relevant documents.
8)
Are you aware of any instances at any other nuclear power plant where worker protective garments have been breached or torn during the process of installing new racks in a spent fuel pool?
If yes, identify each incident, and state whether and how much additional radiation' exposure occurred as a result.
9)
Are you aware of any instances at any other nuclear power plant where a worker dropped a rack during the process of installing new racks in a spent fuel pool?
If yes, identify each incia2nt, and state whether and how much additional radiation exposure occurred as a result.
10),
Are you aware of any instances at any other nuclear power plant where a worker dropped a spent fuel assembly during the process of installing now racks in a spent fuel pool?
If yes, identify each incident, and state whether and how much addi-tional radiation exposure occurred as a result, 11)
Are you aware of any instances at any other nuclear power plant whero worker (s) were exposed to radioactive gamma rays released to the spent fuel pool during the process of installing now racks in a spent fuel pool because the spent fuel pool purification filter did not work?
If yes, identify each incident, and state whether and how much additional radiation exposure occurred as a result.
12)
Are you aware of any instances in any other nuclear power plant where worker (s) woro exposed to isotopos other than e
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8-Krypton-85, such as cesium or iodine, during the process of installing new racks in a spent fuel pool, as a result of leaking or damaged spent fuel rods.
If yan, identify each incident, and state whether and how much additional radiation exposura occurred i
as a result.
13)
Are you aware of any occurrences at other nuclear power plants that resulted in increased public radiation exposure dur-ing the process of installing new racks in a spent fuel pool.
If l
yes, identify the plant (s), describe each occurrence, and state J
whether and how much additional radiation exposure (in millirems per hour per person) occurred as a result, and the number of per-j sons who were exposed.
14)
The EA (page 8) states that "the dose for installation 4
of the e,nhanced spent fuel pool cooling system has been estimated i
very conservatively to add less than 10 person-rem to the i
original dose goal."
The following questions relate thereto:
i a.
Describe in detail what activities necessary or l
l incident to the installation of the enhanced spent fuel pool cooling system contributed to this 10 person-rem addition to 1
L the doso goal.
j b.
Identify and provide copios of all documents used
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r or generated by thu NRC or its contractors, including
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i environmental reports and other information provided by Ver-mont Yankee, to assess, evaluato, or review the radiological impact attributable to installation of the enhanced spent l
fuel pool cooling system.
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. 15)
The EA (page 8) states that the projected dose goal for the the proposed spent fuel pool modification project before com-mitting 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.
proceeding or context in which such reviews occurred (i.e.
license amendment, review under 10 C.F.R. 5 50.59), and pre-cise nature of the project, b.
For each plant, state whether the NRC.has per-formed, or otherwise acquired, an analysis, evaluation, review, or measurement of actual occupational dose exposure l
resulting from replacement of original fuel racks and the f
installation of now fuel racks in the spent fuel pool, and mado a comparison betwoon actual dose exposure and projected dose exposure.
If yes, for each plant, describe the results of such comparisons, and' identify and provide copies of any documents containing such comparisons.
16)
Are you aware of any instances with respect to other nuclear power plants where the anticipated, estimated, or projected radiation dose exposure, in person-roms, resulting from replacement of original fuel racks and the installation of now fuel racks in a spent fuel pool was different from the actual doso exposure?
If you, identify the plants, and explain why the projected dose exposure was inaccurate.
L
17)
The EA (page 9) states one potential source of radia-e tion to workers during the rerack operation is crud released to the pool water because of fuel movamant during the proposed spent fuel pool modification.
The following questions relate thereto:
Did you consider the possibility that crud would a.
be released from the old racks as a result of the movement or shuffling.of the racks during the reracking 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 you consider the possibility that crud would be released from the spent fuel assemblies stored in the old racks as a result of the shuffling of fuel during th'e reracking operation?
If yes, state how much of the 33-rem dose goal is attributable to the release of crud from spent fuel assemblies.
If no, explain why you did not consider this possibility.
4 How much crud will be released from the old racks c.
as a result of the movement or shuffling of the racks during the roracking operation?
Describe your method for making or estimating this amount, and identify and provido copios of all documents generated or relied on by the NRC or its con-4 tractors in estimating this amount.
i d.
How much crud will be released from the spent fuel assemblies stored in the old racks as a result of the shuf-fling of fuel during the re acking operation?
Describo i
your method for making or estimating this amount, and pre-l 4
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vide copies of all documents generated or relied on by the NRC or its contractors in estimating this amount.
e.
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.
- 18) ' In preparing the EA, did the NRC assess the radiologi-3 cal impacts of the proposed action over the life of the pisnt?
other than those involving the actual reracking operation, such as worker exposure resulting maintenance activities, and placing new spent fuel assemblies in the rack after subsequent refuel-ings?
If the answer is no, explain why these impacts were not assessed.
If yes, describe the activities assessed, and the exposures, in person-rems, attributable to each such activity.
19)
In its evaluation of alternative five (5) to the pro-posed action, construction of a new independent spent fuel storage installation (ISFSI), identifying dry cask storage
'nstallation, the Environmental Assessment concluded that dry cask sto::ago installation is not feasible as an alternative to l
the proposed license amendment because, inter alia, "the expan-sion of the existing pool is a resource that should be used".
The following questions relate thereto:
Identify and describe the "expansion" capacity of the a.
existing pool, and state whether this expansion capacity assumes the use of high density racks, the installation of f
additional racks of the existing design, and/or the storage l
of an increased number of spent fuel rod assemblics beyond l
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- that authorized under Vermont Yankee's current technical specifications.
b.
Describe 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.
a c.
Is this statement based on an assessment of the eco-t nomic costs of implementing the dry cask storage alterna-tive, as compared to the costs of using"the "resource" of l
the existing pool?
If yes, Please explain.
20)
Has the NRC or its contractors reviewed or analyzed the radiological impact on the public of designing and installing the dry cask storage alternative described'in the EA (p. 4).
If y'es, describe.the results of such a review or analysis, including the l
projected dose goal resulting from that alternative, and provide q
copies of all documents related thereto.
21)
Has the NRC or its contractors reviewed or analyzed the
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economic costs (projected) to Vermont Yankee of designing and installing the dry cask storage alternative described in the EA (p. 4).
If yes, provide a breakdown of these costs, and provide all documents related thereto.
[
L 22)
The IIA (page 4) states that "assessments for the dry cask ISFSI at the surry Power Station and the dry modular con-crete ISFSI at the H.B. Robinson Steam Electric Plant Unit 2 resulted in a Finding of No Significant Impact".
The following i
questions relate thereto:
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- 13 a.
State how much time (days, months and years) it took the NRC or its contractors to. review these applications in order to make this findings.
b.
State how much time (days, months and years) it took to decign and install the Robinson and Surry Independent Spent Fuel Storage Installations.
c.
Identify any other nuclear plower plants where a dry cask Independent Spent Fuel Storage Installation was reviewed by the NRC, and state how much time (days, months and years) it has taken the NRC or its contractors to review these applications.
- 23) Please ider*.ify all persons on whose factual knowledge, opinions, or technical expertise you rely or intend to rely for you[ position on NECNP's environmental contentions.
- 24) Please identify all persons you may call as witnessos on NECNP's environmental contentions.
Please describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.
Respectfully submitted,f
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i Andrea Forster HARMON, CURRAN & TOUSLEY 2001 "S" Street N.W. Suite 430 Washington, D.C.
20009 (202) 328-3500 1
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UNC GEBTIFICATE OF SERVICE I certify that on Novem'ser 10, 1988, copie@f@$4 f t PI2592-ing pleading were served by 2irst-class mail, or as otherw:.se indicated, on all parties '.isted below.
OFFIC J
.. i,, o Charles Bechhoefer, Chairman
[}dN ' #'
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Glenn O.
Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 t
Dr. James H. Carpenter Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Secretary of the Commission Attn:
Docketing and Service Section U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Christino 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 conoral one Ashburton Placo Boston, MA 02108 Samuel Press, Esq.
Vermont Dopartment of Public Service 120 Stato Stroot Montpelier, VT 05602 i
Ann Hodgdon, Esq.*
i' offico of the General Counsel Bothesda U.S.
Nuclear Regulatory Commission
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Washington, D.C.
20555 Diana Sidebotham R.F.D.
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Putnoy, Vermont 05346 R.K. Gad III **
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Ropes &' Gray p
g-225 Franklin Street Boston, MA 02110 Gary J.
Edles Atomic Safety and Licensing Appeal Board
'J, S. Nuclear Regulatory Commission Washington, D.C.
20555 Howard~A..Wilber Atomic Safety and Licensing Appeal Board U.S.' Nuclear Regulatory Commission Washington, D.C.
20555 Geoffrey M. Huntington, Esq.
Office of the Attorney General Environmental Protection Agency State House Annex 25 Capitol Street Concord, NH 03301-6397 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 WWF---
Andrea Ferster By FAX
- By overnight mail e