ML20236E650
| ML20236E650 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/21/1987 |
| From: | Weiss E HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20236E625 | List: |
| References | |
| OLA, NUDOCS 8708030037 | |
| Download: ML20236E650 (10) | |
Text
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l D 0. ',E i f f' y:
July 21,1987 UNITED STATES OF AMERICA 87 Ji 24 A8 :29 '
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
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In the hbtter of
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Vermont Yankee Nuclear
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Power Corporation
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Docket No. 50-271-OLA
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1 (Vermont Yankee Nuclear
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Power Station)
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NECNP'S THIRD SET OF INTERROGATORIES AND DOCUMENT REQUESTS TO NRC STAFF The instructions and definitions contained in N ECNP's Fi rst Set of Interrogatories and Document Requests are incorporated herein.
1.
On June 18, 1986, the Commission issued public notice of the pendency of the instant license amendment application and pro-posed to make the finding that the instant amendment involves no significant hazards considerations.
51 Fed. Reg. 22,226.
Was this finding proposed pursuant to a recommendation f rom the NRC staff?
If so, identify the NRC staf f member (s) who participated in the preparation of any such recommendation and describe the role of each.
2.
Provide all technical and/or factual analysis or other material presented to the Commission prior to the June 18, 1986, proposed finding of no significant hazards considerations.
3.
The staf f states in the NRC Staf f's Br ief in Opposition to the Brief of Applicant June 25, 1987 (hereinaf ter Staf f Brief) at page 5 that the current VY tech specs "do not ensure redundancy 8708030037 970721 PDR ADOCK 05000271 G
2-in the spent fuel pool cooling system."
Please explain what ele-ments of redundancy are missing from the current tech spec.
4.
The proposed new tech spec submitted by VY and attached as Appendix B to the Staff Brief, states as its objective:
"[t]o assure that adequate cooling is available for heat removal in the spent fuel pool."
Would compliance with the proposed tech spec ensure the appropriate redundancy for the core decay heat removal system?
Please explain your answer.
5.
Is it the staf f's view that compliance with the proposed new tech spec would ensure that the spent fuel pool cooling system meets the single failure criterion?
Please explain your answer.
6.
Is it the staf f's view that compliance with the proposed new tech spec onuld ensure that the core decay heat removal system meets the single failure criterion?
Please explain your answer.
7.
What requirements and/or criteria apply to the determination of whether sufficient " redundancy" exists in the spent fuel pool cooling system?
8.
In view of the fact that both the proposed new tech spec and the Af fidavit of John N.
Ridgely ( Appendices B and C to the Staff Brief) use 150'F as the applicable temperature limit, has the Staff made the judgment that 150'F is the appropriate limit.for purposes of this requested amendment?
If so, please explain why
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a limit other than that contained in the Standard Review Plan j
applies in this case.
9.
Has the staff applied the 140'F limit contained in the Stan-dard Review Plan to other reracking applications?
Please explain why or why not and identify other reracking amendments as to which a 140'F limit has been applied.
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l 1
i '
- 10. The staf f states at page 11 of the Staf f Brief:
"The [19 77] Staf f SER did not make clear that the licensee was permitted to use one train of RHR to provide supplemen-1 tal spent fuel pool cooling in cases of normal refueling (1/3 core offloads) if needed to maintain spent fuel pool temperature ' below IS0'F."
a.
Was the Staff aware prior to the Prehearing Conference of April 21, 1987, that VY is, under its current license, required to use one train of RHR to cool the spent. fuel pool in cases of normal refueling (1/3 core offload) in order to keep the pool temperature below 150*F?
b.
Did the Staff intend in the 1977 spent fuel pool amend-ment to permit VY to use one train of RHR to cool the spent fuel pool in cases of normal refueling?
11.
With reference to the proposed new tech spec (Staff Brief,-
Appendix B), please answer the following:
Should line 3 of Specification B of S 3.14 be corrected i
a.
to read "... incapable of maintai.ning...?"
b.
Does Specification C of S 3.14 require - the reactor to be l
shut down immediately whenever both fuel pool cooling subsystems i
are made or found inoperable?
Please explain.
c.
Does Specification C of S 3.14 require the reactor to be shut down immediately whenever the fuel pool temperature cannot i
be maintained below 150*F with use of the spent fuel pool cooling j
systems alone?
In the alternative, does this specification
'l permit the plant to operate if the pool temperature can be maintained below 150*F by using RHR?
4 d.
Does the reference to 200'F in specification C of S 3.14 mean that even if both fuel pool cooling subsystems are made or
4-found inoperable, plant operation can continue unless and until the fuel pool temperature exceeds 200*F?
If not, please explain tiie significance of 200 F in the context of the specification.
e.
Specification A.2.
of S 4.14 requires the monitoring of fuel pool temperature and level.
Please explain whether this proposed tech spec or any other current or proposed section of the VY license requires VY to take specific actions when specific 1
l pool temperature or level limi ts are exceeded.
If so, please j
l identify.
If not, please explain the purpose of the monitoring requirement.
12.
What effect does the change from an annual to an 18-month refueling cycle have on the combined heat load of the spent fuel pool and the core?
Please provide all analyses, calculations or
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other documents which support your response.
13.
The current fuel pool limit of 2000 assemblies is based on certain assumptions regarding the heat load which must be removed and the heat removal capabilities of the cooling system.
What effect does the change to an 18-month refueling cycle have on the heat load which must be removed from each assembly?
14.
In the letter of June 11, 1987, from Warren P.
Murphy, Vice President and Manager of Operations, VY, to V.L.
Rooney, NRC,
( FVY 87-65) Mr. Murphy refers in the first sentence to "recent discussions with NRC staff concerning certain issues associated with" this proposed amendment.
(This letter is cited at note 7 on page 5 of the Staf f Brief) Please describe the substance of these discussions with VY in which the issues covered in the June 11, 1987 letter were discussed.
r I I 15.
Identify all persons involved in the discussions referred to j
above.
l 16.
Who initiated these discussions and in what manner?
Did the i
staff send any questions to VY on these issues?
If so, provide them.
1 17.
Provide any documentation of these discussions, including but not limited to notes and/or minutes, l
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18.
VY refers at page 3 of Mr. Murphy's letter to an evaluation which concluded that each of the components of the spent fuel pool cooling subsystems are capable of operation at a fluid temperature of 200"F.
Has this evaluation or any other documen-tation related to this issue been given to the staff?
If so, j
please identify and provide.
l 19.
Is it the staf f's view that each of the components of the opent fuel pool cooling subsystems are qualified for operation at a fluid temperature of 200 F?
Provide all analyses, calcula-tions, evaluations or other documents which relate to the ability of these components to operate at a fluid temperature of 200*F.
20.
Does the staff agree that "there is no need to augment spent fuel pool cooling" with RHR7 (See Licensee's Responses to NECNP's First Se t of Interrogatories, July 1, 1987, Interrogatory No. 23, p. 2 0).
Please explain your answer and provide (or reference, if previously provided) the analyses, calculations or I
1 assessments which support your view.
21 The following questions relate to the memorandum of Thomas M. Novak to the NRC Commissioners, subject:
" Board Notification Regarding BNL Draf t Report on Spent Fuel Pool Accidents (BN 87
-m 05)," March 2 7, 1987, (hereinafter "Novak Memorandum") a ttached
~to the copy of the January,1987 draf t report entitled "Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82)"
i (hereinaf ter "BNL Report") sent to the parties to this case.
1 a.
The Board Notification states that "[t]he _draf t report has been distributed widely within the staff for a peer review."
Identify all persons to whom the report was so distributed, b.
Provide all documents which were prepared as part of the 4
process of the " peer review" referred to above.
c.
Has the staf f communicated with or received information from any persons outside the PRC staff in connection with or related to the review of the BNL Report?
If so, provide all doc-umentation of these communications and any.information received, including but not limited to minutes of meetings.
d.
Has BNL been requested or permitted to respond to criti-cisms of or questions about the draf t BNL Report?
So, provide all documents containing questions and/or criticisms to BNL and any BNL responses thereto.
Provide any communications between VY and NRC related to e.
a the draf t BNL Repor t.
f.
The Novak memorandum states:
" Preliminary Staff opinion is that substantial portions of the report'will need more criti-cal review because some assumptions appear to be oversimplified. "
Identify the specific staff member (s) upon whose opinions this Statement is based and provide all documents in which the identified persons express and support those' opinions.
I g.
W;ith regard to the statement quoted in question f6, above identify all " assumptions" which the s.taff believes to be
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s 7-oversimplified and explain why provide any documente. which sup-port your response.
h.
The Novak Memorandum states:
" Based on a brief review, the staff expects that the final results of the study is likely to provide a much lower estimate of risk."
Describe the nature of the "brief review" refeered to and identify all participants.
Provide any documents generated ' by or reflecting this "brief review."
1.
The Novak memorandum states that "other studies of the cesium retention in similar buildings and the large fraction of cesium retained at Chernobyl indicate that the report may underestimate retention by a factor of ten."
Provide all studies referred to by Mr. Novak and any analyses or other documentation
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related to Chernobyl which evaluates or estimates the amount of 1
cesium retained.
j.
Is it the staff's view that cesium or other radionuclides were released from the spent fuel pool at Chernoby1?
If so, describe the scenario or mechanism (s) leading to this release.
Provide all documents which evaluate or assess the possible involvement of the spent fuel pool in the Chernobyl accident and/or the release of cesium associated' with that acci-dent.
k.
The Novak memoranoum states that "the [BNL] r eport.is less an estimate of the risk than identification of the factors that'need further study in order to make a reasonably accurate estima te of risk."
Nhat is the staf f's estimate of. the numerical uncertainty associated with BNL's risk estimates?
Is this O
4 8-uncertainty significantly greater than the uncertainty associated 1
with the estimates of core melt risk generated by typical current probabilistic risk assessment (e.g. NUREG-ll50) ?
Please explain 1
your. answer.
22.
The BNL Report was accompanied by a cover letter, d a t ed Fe b-l a
ruary 5,1987, form K. R. Perkins, BNL, to Edward Throm, Division of Safety Review and Oversight, NRC.
The cover letter character-1 izes the enclosed BNL report as a " revised draft" and states:
"We have incorporated your comments on the rough draf t."
'Please provide the rough draf t and all NRC Comments on the rough draf t.
1 l
By O
4 Ellyn R. Meiss HARMON & WEISS 2001 "S" Street, N.W.
Suite 430 Washington, D. C. 20009 (202) 328-3500 Counsel for NECNP I
l
- l
t 3M KE U i
" or UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 J124 A8 :29 Before the Atomic Safety and Licensing Boardr; 00p;,v; 1
c:cr
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BPz;n -
In the Matter of
)
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3 Vermont Yankee Nuclear
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Power Corporation
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Docket No. 5 0-271-OLA
)
h (Vermont Yankee Nuclear
)
EI' Power Station)
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CERTIFICATE OF SERVICE The undersigned certifies that on, July 21,1987 "NECNP's Third Set of Interrogatories and Document Requests to Vermont Yankee Nuclear Power Corporation", a'nd "NECNP's Third Se t of Interrogatories and Document Requests to NRC Staff" were served r
on the following parties to this case by hand and/or overnight mail; as designated below:
Charles Bechhoefer, Ch airman Atomic Safety and Licencing 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 Dr. James H. Ca rpenter Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Secretary of the Commission Attn Locketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ch ristine N.
Kohl, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 2 0555
'~w George Dean, Es q.
Assistant Attorney General Commonwealth of Massachusetts Department of the Attorney General One Ashburton Place Boston, MA 02108 fi i'
Daniel.J. Mullett, Es q.
Vermont Department of Public Service 120 State Street Montpelier, VT 05602 Ann Hodgdon, Es q.
Office of the General Counsel Bethesda U.S. Nuclear Regulatory Commission i
Washington, D. C.
20555 Diana Sidebotham R.F.D.
- 2 Putney, Vermont 05346 Thomas G.
Dignan, Es q.
Ropes & Gray j
225 Franklin Street Boston, MA 02110 Gary J. Edles Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commicsion Kashington,-D.C. 20555
-Howard A. Wilber l
Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 l
Geoffrey M. Huntington, Es q.
Office of the Attorney General Environmental Protection Agency State House Annex 25 Capitol Street Concord, NH 03301-6397
!II i
l Ellyn R.8 Weiss x l