ML20215K031

New England Coalition on Nuclear Pollution First Set of Interrogatories & Document Request to NRC Staff.* Certificate of Svc Encl.Related Correspondence

ML20215K031
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/16/1987
From:	Weiss E HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#278-3825 OLA, NUDOCS 8706250194
Download: ML20215K031 (15)

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• i ret.ATED CORgESPONDENGl i

00CKETED June 16,19gyNRC

' UNITED STATES.0F AMERICA-

. NUCLEAR' REGULATORY COMMISSION 07 yg gg g) ;27 Be fore the. Atomic Sa fety ' and Licensing Boardt - ':

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In the' Ma tter of . .).

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Vermont Yankee Nuclear ~ ) ..

Power: Corporation ) Docket No.7 5 0-271-OLA

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'(Vermont' Yankee Nuclear- )

Power Station) )

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NECNP' S FIRST SET OF- INTERROGATORIES / AND:

," DOCUMENT REQUEST TO NRC STAFF INSTRUCTIONS FOR USE The following- interrogatories are to be: answered in writing and under oath by an~ employee,-representative or agent of the p

Applicant with 'ersonal knowledge of the. facts or information i

requested in each interrogatory.

For each question, please identify by 'ncme, job title and address each person who prepared or assisted in preparation of the reeponse.

The following definitions shall apply to these inter-rogatories and document requests:

1) " Document" shall mean any written or graphic matter of coramu nica tion, however produced or reproduced, and is intended to beicomprehensive-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 8706250194 370616 PDR ADOCK 05000271 m a o PDR So J

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communications, notebooks, diaries, sketches, diagrams ,1 forms ,

manuals, brochures, lists, publications, draf ts, telephone minutes, minutes of meetings, statements, calendars, j ournals, orders, confirmations and all other written or graphic materials of any natore' whatsoever.

'2) " Identify d with respect to any document shall mean to :

state the following: the documerit's title, its date, t'he' author of the document,L 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) " Identify"'with respect to any action Ot conduct shall' I mean state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date i such action was proposed and/or taken; all persons with knowledge or'information about such action; the-purpose or proposed effect

.of such action; and any document recording or documentir.g such action.

4) " Identify" with respecc to an individual shall mean state the individual's name, address, employer, occupation, and title.

5) " Describe" with respect to any action or matter shall mean state the following regarding such action or matters 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 persons; i.

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k, j i and the existence and location of any and all ' documents relating to'such action or matter.

6) "VY" or " Applicant" shall refer to the Vermont Yankee Nuclear Power Corporation.

7) " Staff" 'shall refer to all persons employed by the NRC at' headquarters or regional of fices, including contractors hired i

by NRC.- N INTERROGATORIES AND DOCUMENT' REQUESTS

1) VY lists five (5) methods for increasing on-site storage on page three of its " Proposed Technical Specification Change for Spent and New Fuel Storage," April' 25,1986 (FVY 86-34) and states that all were " considered" by VY. 'Ihe following questions relate thereto:

a. Has NRC or its contractor (s) performed any review to date of the consideration of alternatives presented by VY in FVY 86-34? If so, describe the substance of that review.

b. If so, please provide sl1 documents used in or generated duting that review. Identify by name, j ob title and address all persons who participated in that review and describe the.ir roles and tasks during the review.

c. Describe the process by which this review took place and the time period involved: e.g., was a committee estabe Aished; were contractors hired; were meetings and delibera-tions conducted?

d. If no review has yet taken place or is incomplete describe the manner in which NRC intends to review the cen-s

sideration of alternatives presented by VY, including but not limited to a description of the tasks to be performed and identification of the person (s) (including contractors) who wil1 perform them and re-schedule for their completion.

2) Has NRC performed or is it in the process of performing any independent evaluation (s) of the alternatives to the pending proposal by VY? If so, describe the substance thereof.

3) Provide all documents used in or generated during that evaluation. Identify by name, job title and address all persons (including contractors) who participated in or will participate in any such independent evaluation and describe theit roles and

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tasks during that evaluation. '

4) Describe the process by which any such independent i

evaluation has been or is being undertaken and the time period involved: e.g., has a cor.mittee been establiched, were contrac-tors hired; were meeting or deliberations held? i i

5) Identify all rules, criteria and/or guidance, whether or not formally proculgated, which the staff considets to apply to i I

the considerction of alternatives to this proposal pursuant to /

l the National Environmental :licy Act ("NEPA")- l l

6) Provide all communications (including but not limited to j i

c correspondence, memos, telephone logs, meeting minutes) among VY

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(and contractor s), NRC Region 1 personnel and NRC Headquerters personnel related to expansion of spent-fuel storage capacity at VY dating f rom January,1985 and forwardt (You need not provide  !

Material which has already been sent to the parties in this dase).

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7) Describe by date, substance of discussidn and participants all meetings held between and among VY ( a.nd contrac-tors), NRC Region 1 personnel and NRC Headquartere personnel ,

related to expansion of spent fuel storage capacity at VY, dating f rom January,1985 c.nd forward. Provide all documents relating to or used in these meetings or exchanged among participants thereto. (Refer to definition of " documents") .

8) Is it the staff's position that dry cask sr.orage is not a technically feasible method for spent fuel storage at -he VY j eite? Provide the reasons for your answer and any documents or ,

facts in support thereof.

9) Is it the staff's position that dry cask storage is too costly a method for spent fuel storage at the VY siSe? Provide the reasons for your answer and any documents or fact in support thereof, including but not limited to your estimate of the cost.

10) Is it the staff's position that dry cask storage poses safety risks greater than those associated with VY's proposed j J

action? Describe these risks in detail and provide any support-ing documentation.

11) Provide all documents in the staf f's possession which compare the cost, technical feasibility and/or risks of VY's pro- ,

I posed action to the cost, technical feasibility and/or risks of dry cask storage. l

12) Is it the staf f's position that an independent wet storage pool is not a technically feasibla method for spent fuel 1

storage at the VY site? Provide the ieasons for your answer and  !

l any d0cuments and f acts in support thereof. j I

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.13 ) Is it the.Otaff's position that an in' dependent wet storage pool is too costly..a. method for spent fuel storage at the

g. VY s i te7 ' Provids .'the ' reasons .for your answer' and . any documents and1 facts in supportethereof, innluding but not lim'ited to your estimate of ' the ' cost. -

14) Is ~ it' the 'staf f's position that an independent. wet storage pool poses risks greater than those associated with VY's i i

proposed action? .If so, describe these.riske in' detail and: pro- j

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t vide. any suppor ting documenta tion. '

15) Provide . all documents' in th'e staf f's possession ' which i

compcre the- cost, technical feasibility and/or. risks of'an inde- 1 pendent wet. storage" pool to the cent, technical feasibility and/or- risk of VY'nf proposed action.

16) 'Is .it the staff's position thet independent air-cooled' f

va41t storage is not a tc.chnica3.ly feasible method'for spent fuel itorage at the VY cite?

r Provide the-reasons for:your answer and.

any facts and documents in support thereof.

17) Is it the. staff's position that independent air-cooled vault storage is toc costly a method for spent fuel storage at

$he VY site? Provide the reasons for your-answer and any facts  !

and documents in support thereof, including but not limited to.

your estimate of the cost.

18) Is'it the staff'~s position that. independent air-cooled storage poses risks greater than those associated with VY's pro-poaed action?' hoscribe those risks in detail and provide any sepporting documentation.

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,y- 'l 19)' Provide all documents in the possession of the staf f.

which' compare the cost, technical feacibility Gnd/or-ris'ks-of.an' l independent air-cooled storage vault.

20) Identify all applications for dry. cask storage received by .the NRC to date and describe the st,atus of each (e.g. status

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of-sta'fi review, J icensing documents prepared, ' approved, in place, etc.).

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21)~ Answer the same question as Ho. 20, above but with. 1 respect to a) 1.ndependent wet pool storage and b) independent dry-cooled vault storage.

22) identify all cases where racks of the came design as those proposed' by- VY have been I? censed for other boiling water.

reactors.

23) For each boillrig water reactor where approval has been granted to install racks of the same design as those proposed by VY, state: )

a). the total number of _ cur.ies in the fuel stored in the p

' ool currently, b) the total number of curies that will be in' the fuel stored in'the pool at the time when the racks are full, c) the percentage of the total curie content currently attributable to cesium, strontium and plutonium,.

d) the percentage of the total curie content that will be attributable to cesium, strontium and plutonium at the time when the racks are full.

24) Provide' any internal agency guidance used by the staff in its review of spent fuel storage reracking requests in general end/or the VY proposal in particular.

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25) Identify all rules, criteria and gu<tdance,'whether or l net formally promulghted, which the staf f will apply to its

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review of:the safety issues involsed in the instant application.

26) Does the single f ailure criterion' apply to ' the VY spent i

' fuel pool cooling systems? Provide the reasons for your answer and any documents in support.thereof.

'27) Is it the statf's position that VY must demonstrate that j L the spent fuel pooliwater will be maintained at all' times.at' 1

140*FJor below? 150'F or below? EFplain the EP3 sons for your answer and identity and provide the rule criteria and/or guid-ance, shether or not formalAy promulgated, which support your response. ,

28) On Athe assumption of an 18-month refueling schecule. and -

& Call core discharge, for what period of time will the RHR sys- i tem by required to keep the pool water below 140'F? Provide all l

documents which support your answer.

29) On the assumption of an 18-month refueling senedule and  !

l a discharge of 136 assemblies, for what period of tine will the '

RHR system be required to ke6p the pool water below 140*F?

30) Provide all documents, enclyses, and/or evaluations in l

the staff's possession which evaluate the probability and/or con- j 1

sequences of'failurec in the RHR cystem'during the period of time I

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that the system is required to augment the cooling of the spent  !

i fuel pool. i

31) Provide all documents analyses and/or evaluations in the staf f's possession- which evaluate the probability and/or conse-i i

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~ f quences of accidents at VY in particular and boiling water reac-T ' tors'in general when the plant is not operating.

32) IsLit the staff's position that the spent fuel pool J cooling system at VY meets' the single failure criterion with the .j

'l spent fuel storage facility filled with normal refueling and j i

maintaining'tne pool water temperature nt less than 140'F? (See l Question 17 and response thereto, VY " Response to Request for Additional Information - Proposed Change No.133, Spent Fuel Pool  ;

Expansion."- Enc. 1, Nov. 24, 1986, PVY 86-107). Explain your answer and provide any documents in support thereof.

33) Is it the staff's position that the spent fuel pool cooling system at VY is recuired -to meet the single failure criterion with the spent fuel storage facility filled with notaal refueling and maintaining the pool water temperatur6 at less than 140*F?

34)- Answer the questions posed in No. 3 2 and 3 3 above, but on the assumption of a full core discharge.

35).Has the staff approved other applications for reracking where it is necessary to use the RHR system to maintain the pool cooling water temperature below 140'F7 If so, identify all such cases.

36) VY s tates in response to staf f question 17 (FVY 86-107, Nov. 2 4, 19 86, cited supra): " . . .VY does not consider the fuel pool cooling system to be single active failure proof (depending on RBCCW temp) until af! er approximately 42 days decay of a normel spent fuel discharge." Does the staff consider the system

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single act.ive f ailure proof? Explain your reasons and provide any documents in support thereof.

37) Has the staff previously approved reracking applications where the resultant pool. cooling system'was not single active failure proof? If so, identify all such cases.

38) During the period of time when the RHR system is required to cool the spent fuel pool to below 140*F, are the reactor cooling aystems, including but not limited to decay heat removal systems single f ailure proof? Explain the reasons for your answer and provide any documents in support thereof.

39) Assume that VY is shutdown for - refueling, the spent fuel has been dischargea and it is within the period of time that one train of the RHR system is required to augment opent fuel pool cooling:

a. How will VY assure adequate cooling of both the ccre and the spent fuel pool in the event of fallpre of one R."R train?

b. Provide all evaluations, analyses or other documents related to the above question. ]

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c. Has the staf f (or contractors) reviewed the VY operating I or emergency procedures which apply to this situation? If I so, provide the procedures and/or any documents reflecting i the staf f's (or contractors' ) evaluation or analyses.

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d. What is the probability of failure of one RHR train?

Explala your answer and provide all documents in support -

thereoE.

40) Does the staff disagree with any of the calculations l

presented by Brookhaven National Laboratories in section 20F the draft report "Beyond Design-Casis Accidents in Spent Fuel Pools,"

January,1987 (hereinaf ter "BNL Report") regarding the likelihood

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of the. initiating events for spent fuel pool accidents? If so, provide the ctaff's reasons in detail, and the staff's estimates

.for the likelihood-of these initiators. Provide any documents which support your response. )

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41) Describe in detail the process by which the 'staf f par- .!

l i ticipated in ' th'e preparation of the BNL Report, including but not l

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! ilmited to'a description of the tasks perfortced by Mr. E, Throm and Dr.- M. Imhl, who are credited by BNL with providing "consid-erable J.nput and technical direction." l

42) Identify Mr. E. Th r oin and Dr. M. Wohl by job title and

. address and provide. their resumes, vitae or other detailed des-L cription of their training, backg round and expertise.

43) Describ'e in detail the process by which the BNL Report has been or is being technically reviewed by the staff, including but not limited to identification of all individuals involved by name, job title and address and a description of their tasks.

44) Provide all 4ccuments reflecting communications between -

BNL End the NRC regarding the subject matter of the BNL Report.

l 45) Provide all. documents in the staff's possession which l

contain or reflect technical evaluation of the BNL Report or the codes or assumptions used therein. ,

46) What is the staff'e estimats.of the probability of loss of pool cooling water at VY in particular and/or other plants in general? Provide your reasons and supporting documents.

47) Does the Gtaff agree that the code developed at Sandia National Laboratories by Benjamin, et. al. (NUREG/CR. 0 649, SAND

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1371)' gives a. reasonable estimate of the potential for

/ propagation of a cladding fire.from high power to low. power spent fuel? (See BNL Report, p. S-4). If not, explain your answer and provide any supporting documents.

48) Does the staff have a computer code which it believes gives a more accurate estimate than does Sandia's, supra, for propagation of a cladding fire from high to low power spent fuel? 4 If'so, identify it explain the differences and give the reasons

-(including cocmnentation) why you believe it gives more accurate results.

49) Does the staff agree that the Sandia code provides a valuable tool for assessing the likelihood of a catastrophic fire for a variety of spent fuel configurations in the event that the pool is drained? (See BNL Report, p. S-4). If not, explain your answer and provide any supporting documents.

50) Does the staff have a cede which it believes provides a more accurate assessment than does Sandia's of the likelihood of a catastrophic fire in the event that the pool is drained? If I s o, . identify it, explain the differences and give the reasons why you believe it gives a more accurate assessment.

51) Assuming that VY's proposed amendment is granted, what would the off-site radiological consequences be of an accident i

involving a self-sustaining fire in the spent fuel cladding?

Answer t.he question for each refueling up to 2000 assemblies.

52) Assuming that VY's proposed amendment is granted, what is the probability of a self-sustaining fire in the cladding?

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Does this probability change depending on the amount of fuel stored? Explain your answers and provide any supporting docu-mentation. )

53) Does- the staf f agree with BNL's conclusion that the overall risk of beyond design basis accidents in spent fuel pools "are comparab2e to present estimates for dominant core melt acci-cents..." (BNL Repor t, p. S-5). Ptovide the reasons for your answer and any supporting documentation.

54) Provide a copy of D.D. Or vis et. a l. , " Re v i ew o f P r o-posed Dry Storage Concepts Using Probabilistic R{ sk Assessment,"

Re f. I to BNL Repor t, Section 6 (p. 6- 3) .

55) Does the staff agree with the following statement at page 3-8 of the BNL Report:

Since high density fuel storage racks are predicted to cause self-sustaining oxidation even after storage for one or more years it seems clear.that it would be undesirable to store

' spent fuel in high density storage racks if it has been dis-charged within the last two years.

56) If the staff disagrees with the above quoted statement, specify the areas of disagreement (e.g. , the factual predicate or the conclusion) and describe the staff's position in detail.

Provide all documents which support the etaff's position and all communications between the Staff and BNL relevant to this ques-l tion.

57) Provide all documents on which you rely or intend to rely during this proceeding which support the staff's position on l

each of the admitted contentions. This includes but is not

{ limited to all documents relating to answers to interrogatories and preparation of written presentations.

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58) Identify by name, job title and address all persons on whose f actual knowledge, opinions f or expertise you rely or intend to r'ely for the staff's position on each admitted contention.

59) Identify'by name, job title and address all persons who will. prepare or' assist in the preparation of the.L staf f'c. written presentation and oral argument under 10 CFR' S 2.1113. Describe the subject' matter of their participation and its substance and provide the documents'or. portions thereof upon which they'will rely. for f actual matter or opinions in support :of the staf f's positions.

l Respectfully submitted, ty s. ,

Ellyn R. Keiss h/kf(fz HARNON & WEISS 2001 "S" St reet, N.W.

Suite 430 Washington, D.C. 20009 (202) 328-3500 Counsel for NECNP 1.

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RELATED CORRESPONDENCE UNITED STATES'OF AMERICA NUCLEAR REGULATORY COMMISSION

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In the Matter of )

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Vermont Yankee Nuclear )

Power Corporation ) Docket No. 5 0-271-OLA >

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(Vermont Yankee Nuclear )

Power Station) )

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CERTIFICATE OF SERVICE The undersigned certifies that on June 16, 1987, " NECNP' S First Set of Interrogatories and Document Requests to NRC Staff" were served by hand to the NRC Staf f, and by U.S. mail, first class to the other parties listed below. i Charles Bechhoefer, Ch airman George Dean, Es q .

Atomic Safety and Licensing As sistant At torney General Board Panel U.S. Nu clear Commonwealth of Massachusetts Regulatory Commission Department of the Attorney General Washington, D. C . 20555 One Ashburton Place Boston, MA 02108 Glenn O. Br ight Daniel J. Mullett, Es q .

Atomic Safety and Licensing Vermont Department of Public Board Panel U.S. Nu clear Service 120 State Street Regulatory Commission Montpelier, VT 05602 Washington, D.C. 2 0555 Dr. James H. Ca rpenter Ann Hodgdon, Es q .

Atomic Safety and Licensing Of fice of the General Counsel Board Panel U.S. Nu clea r Be thesda U.S. Nuclear Regulatory Regulatory Commission Commission Washington, D. C. 2 0555 Washington, D. C. 2 0555 e Secretary of the Commission Diana Sidebotnam Attn: Docketing and Service R.F.D. #2 Section U.S. Nu clear Putney, Vermont 05346 Regulatory Commissio3 Washington, D.C. 2 0555 Atomic Eafety and Licensing Appeal Board Panel U.S. Nu clear Thomas G. Dignan, Es q . Regu3 atory Commission Kathryn A. Se lleck , Es q . Washington, D. C. 2 0555 2 Fran Street 1/s .

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Boston, MA 02110 Ellyn R. heiss / ]

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