ML20247A859
| ML20247A859 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/16/1989 |
| From: | Patricia Jehle NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| Shared Package | |
| ML20247A865 | List: |
| References | |
| CON-#189-8349 OLA, NUDOCS 8903290213 | |
| Download: ML20247A859 (25) | |
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LUNITED 5TATES OF AMERICA W* :
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' NUCLEAR REGULATORY COMMISSION 1
BEFORE'THE ATOMIC SAFETY-AND LICENSING BOARD -
'89 NAE 27 ' A 9 i48 :
j In the Matter of
'yg VERMONT YANKEE NUCLEAR Docket No. 50-271-OLA POWER CORPORATION
'(SpentFuelPoolAmendment)-
(VermontYankeeNuclearPower Station)
NRC STAFF RESPONSE TO NECNP'S
.SECOND SET OF INTERROGATORIES'AND REQUEST FOR PRODUCTION OF DOCUMENTS a
TO THE NRC STAFF ON THE NRC ENVIRONMENTAL IMPACT-SPENT-FUEL POOL EXPANSION M n November 10, 1988, the New England Coalition on' Nuclear Pollution N-(NECNP) filed its Second Set of Interrogatories and Request for Production of Documents to the NRC Staff on' the Environmental Assessment and Finding-ofNoSignificant. Impact-SpentFuelPoolExpansion-(TAC.No.65253)
(occupational' dose). The Staff notes that interrogatories to parties other than the Staff are governed by 10 C.F.R. I 2.740b.
However, under 10C.F.R.I2.720(h)(2)(ii),answerstointerrogatoriesdirectedtothe Staff are required only on a finding by the presiding officer:
- 1) that answers to the interrogatories are necessary to a proper decision in the proceeding,-and 2) that answers to the interrogatories are not reasonably obtainable from any other source.
The Connission's regulation concerning production of NRC records and documents,10 C.F.R. I 2.744, requires that a request to the Executive Director of Operations for the production of an NRC record.or document not available pursuant to i 2.790 by a party to an L
initial licensing proceeding state, among other things, why the requested I
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. record.or document is relevant to' the proceeding.
Notwithstanding'the regulations in 10 C.F.R. il 2.744 and 2.720(h)(2)(ii), the' Staff is volunterfly providing responses to NECNP's interrogatories.
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l INTERROGATORY 1-i Please identify all persons who participated in the preparation of l
answers to these -interrogatories, and identify the portions of your response to'which each person contributed.
RESPONSE ~
Michael A. Lamastra, of the Medical, Academic and Commercial Use Safety Branch of the Office of Nuclear Material Safety _ and Safeguards provided the responses to Interrogatories 1, 2,.3, 4, 5, 64, 6b, 6c, 6d, 6e, 7a-e, 8, 9, 10, 11,_12, 13, 14, 16, 17c, 17d, 17e and 18.
John L. Minns I
of the Radiation Protection Branch of the Office of Nuclear Reactor Regulation.provided responses to Interrogatories 6f, 7f, 9, 10, 11, 12, 13, 14, 15, 16, 17a, 17b, 17c, 17d, 17e and 18. Morton B. Fairtile, Operating Reactor Project Manager in the Project Directorate I-3, who is Acting Project Manager for Vermont Yankee, prepared the response to Interrogatory 16.
Patricia Jehle provided responses to Interrogatories 19, 20, 21, 22, 23 and 24.
l INTERROGATORY 2 The following questions the Environmental Assessment's radiological impactassessmentfortheproposedaction(Section3):
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3-INTERROGATORY 2a Identify and provide copies of all documents used in or generated during your analysis, or evaluation of the radiological impacts of the-proposed action, including but not limited to environmental reports or
-information furnished by Vermont Yankee.
Identify by name, job title and addressallpersons(includingcontractors)whoparticipatedinorwill participate in any such evaluation and describe their roles and tasks during that evaluation.
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RESPONSE
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Those documents used in the analysis are listed in the " Environmental Assessment and Finding No Signficant Impact," References, Section 8.0
.(EA). Mr. Michael A. Lamastra, of the Medical Academic-and Commercial Use Safety Branch at the NRC, was the principal participant in the
' radiological evaluation.
He was assisted by the NRC staff members listed in the EA.
EA at 13. The EA is available for public review in the Public l
l Document Room.
I INTERROGATORY 2b Describe the process by which your evaluation of radiological impacts of the proposed action was undertaken and the time describe committees established, contractors hired, period involved, 3
meetings or
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deliberations held.
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RESPONSE
To the extent that committees were established, contractors were hired, and meetings or deliberations were held, these are listed in the Environmental Assessment.
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INTERROGATORY 2c j
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-Identify all rules, criteria, standards or guidance, whether or not formally promulgated,~which the staff used or applied in analyzing or evaluating the anticipated radiological impacts of the proposed action, c
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RESPONSE-The Staff used 10_C.F.R. Parts 19, 20, 30, 50 and 51 Regulatory Guide 8.8 and 8.10, and all of the Standard Review' Plan, NUREG-0800, especially Sections 11,12 and 13 in its analysis.
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J INTERROGATORY'3 TheEA'sassessment'ofpublicradiationexposure(EA,pages8-9) concluded that the proposed action, including the installation of the j
enhanced spent fuel pool cooling system, will result in a radiation dose-j 5
goal of 33 person-rem.
The.following quesi:1ons relate therete:
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_I_ INTERROGATORY 3a 1
Please state the total number of persons who will l,e exposed as a result of the proposed action taken into consideration in projecting a -
radiation dose goal of 33 person-rem from the proposed action.
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RESPONSE
1 In preparation of the Environmental Assessment the total dose to workers.was analyzed in order to estimate the environmental impact on i
workers. The' Staff did not break down the total projected dose of 33
person-rem into individual doses for specific workers.
This level of exposure was found to have no significant environmental impact on workers.
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Therefore, the individual worker doses, which are required to be below those values listed in 10 C.F.R. Part 20, would not be significant either.
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INTERROGATORY 3b-
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State the surface dose from the water, in millirems per hour, that each worker will be exposed to as a result of the proposed action.
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RESPONSE
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i In the general area of the spent fuel pool the dose is approximately.-
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2 mrem per hour. The specific dose received by an individual worker, j
q yhich would be very small, was not calculated. The Licensee, to coply j
with-10 C.F.R. Part 20, is required to keep individual worker exposure as low as reasonably achievable (ALARA).
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1 INTERROGATORY 4 i
activites (sic!ge 8) states that "The 33-person rem dose goal includes all TheEA-(pa necessary for the reracking operation including vacuum 1
. cleaning of SFF walls and floor [s]; shuffling fuel, installation of the new racks; removal of the old racks; cleaning decontamination, and any necessary cutting of old racks; and disposal of waste resulting from the rereacking (sic) cperation, including the old racks.
The following
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questions relate thereto '
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INTERROGATORY:4a l
1 Provide a break-down of the projected radiation ocse goals
. attributable to (ach of the above-described activities.-
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RESPONSE
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The Staff did rot evaluate individual doses for each task in preparing,the Environmental Assessment and the Licensee was not required q
to provide.these breakdtwr.s by task.
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'INTERR0GATORY 4b State how many persons will be required or used to perform each of.
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RESPONSE-i Same as responses to Interrogatories 3a and 4a.
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INTERROGATORY 4c I
Describethelengthoftime(inhours)eachsuchpersonidentifiedin response to Interrogatory No. 4(b) will be exposed and what the millrem dose per hour will be to perform e.ach of the above-described activities.
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RESPONSE
Same as responses to Interrogatories 3a and-4a.
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.,d Are there any other activities ~that may be performed during the' -
reracking operation other than those identified above? If yes, please identify each such activity, provide the projected radiation dose resulting from ech such activity, the number'of persor.s who will be used or required to perform each such activity, ttie ' 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 documelits.
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(;ESPONSE No, no other activities that would change the ' environmental a
assessment of the total dose are anticipated.
It is assumed in any incintenance activity that unforeseen maintenance duties may be required to-complete tne task. The estimated total dose of 33 person-rem includes these additional, but minor, exposures tnat may occur'during the-maintenance activity.
l INTERROGATORY 5 If the number of persons identified in response to Interrogat6cy No.
3(a) and Interrogatory No. 4(b) ara' differ 6nt, explain the reasons for
,this difference..
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.There is no difference..The Staff was,not required to provide'a i
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INTERROGATORY 6
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Intconcluding 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:
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lJ INT.ERROGATORY 6a n
?The.possible radiation radiation dose exposure,which might result if L..
'a worker breaches his or-her protective garments during the installation
.of new racks.
f RESPONSE-Technical Specifications 6.58 "P ant Operating Procedures" requires in part that health physics procedures be prepared, approved and made L
available to all station personnel.. The procedures must be consistent t
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.with the requirements of 10 C.F.R. Part 20. One of the procedures addresses actions taken when a worker's skin is contaminated.
Use of the proce'dures would ensure that the dose is well below the Part 20 requirement and that it is ALARA.
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.The possible~ radiation dose exposure which might result if a worker- '
breaches his or her. protective. clothing during'the installation of the.
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c41 enhanced sperit fuel pool cooling system.
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RESPONSE
- See response to Interrogatory 6a.
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f INTERROGATORY 6c The possible radiation dose exposure which might result if a worker i-drops a rack during the installation of the new racks.
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RESPONSE
No. As part of the original review, Section 14, 6.4 Refueling i
Accident of FSAR, a bounding fueling rod accident is evaluated..
Modification.of the spent fuel pool does not change the evaluation.
' l INTERROGATORY 6d The possible radiation dose exposure which might result if a worker drops a spent fuel assembly during the installation of the new racks.
f RESPONSE-jiee, responce to Interrogatory 6c.
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1 INTERROGATORY 6e The possible worker exposure to radioactive gamma rays released t h spent fuel pool if the purification filter does not work.
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RESPONSE
The purpose of the purification filter is to miniinize worker dose in the pool-area in accordance with the ALARA concept. The failure of.
the filter to function is an event that could oc:ur during rack replacement.
The spent fuel pool has an Area Radiatfon Monitor (ARM) which will set off an alarm if the filter fails to work and the dose level in the spent fuel pool area increases to above the pre-set level.
INTERROGATORY 6f
'The possible worker exposure to cesium or iodine resulting from leaking spent fuel rods.
RESPONSE
Yes.
The spent fuel pool water normally contains trace amounts of cesium and iodine.
For normal operations, exposure to cesium or iodine is of little significance.
See Section 2.1 " Radioactive Material Released to the Atmosphere," " Environmental Assessment and Finding of No Significant Impact - 3 pent Fuel Pool Expansion, Vermont Yankee Nuclear Power Station,"
July 26, 1986.
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4 INTERR0GATORY 7 If your answer is yes to any of the occurrences described in Question
~6(a)through(f),statetheprojectedradiationdoseattributabletoeach 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.
RESPONS_E a-e.
Mormally, the rcdiation dose in the crea is approximately 2 mrem per hour and this direct radiation exposure constitutes part of the estimated 33 rem occupational dose.
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See responses to Interrogatories 7a-e and 6f above.
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INTERROGATORY 8 l
Are you aware of any instances at any other nuclear power plant where l
worker protective garments have been breached or torn during the process i
of installing new racks in a spent fuel pool?
If yes, identify each j
incident, and state whether and how much additiongl radiation exposure i
occurred as a result.
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RESPONSE
i NRC regulations do not require the reporting of such incidents.
i However, I am aware that workers performing routine maintenance occasionally do breach their garments.
That is why NRC Standard technical specifications require procedures for decontaminating workers who receive contamination.
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. INTERROGATORY 9 1
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 i
spent fuel pool?' If yes, identify each incident, and state whether and how much additional radiation exposure occurred as a result.
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RESPONSE
The Staff is not aware of such an incident.
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'l INTERROGATORY 10 Are you aware of any instances at any other nuclear power plant where
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a worker drcpped a ' spent fuel assembly during the process.of installing l
new racks in a: spent fuel pool?
If yes,. ide' ntify each incident, and state i
-whether and how much additional radiation exposure occurred as a result.
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RESPONSE
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l No, I am not awara of such instances at any nuclear power plant, including Vermont Yankee.
However, on November 10, 1988, a fuel bundle was dropped while being transferred.into a basin storage basket in the underwater storage facility at the General Electric Plant (Radioactive i
Waste Site) -in Morris, Illinois (Docket No. 70-200001).
The transfer was nearly complete when the grappling device disengaged and the bundle was released prematurely and fell 18 inches to the bottom of the basket. An I
investigation indicated a weakened tension spring had caused the grapple i
to disengage. There was no indication of a release of radioactivity.
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Water chemistry and basin exposure levels conformed to normal operating = >
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parameters.- The NRC-staff and the Lice'nsee have reviewed the maintana'ce n
testing phocedures to prevent reoccurrence.
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INTERROGATORY 11'
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worker (s)you aware of any instances lat any other nuclear power plant where
, ere exposed to radioactive ganna rays released to the spent j
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w fuel' pool during the process of installing new racks in a spent fuel pool 1
because the spent fuel poul purification filtcr did not work? If yes,.
d identify each incident, and state whether and how much additional-l stadiation1 exposure occurred as a result.
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RESPONSE
i No., See gencrally response to Interrogatory 6e above.
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l INTERROGATORY 12
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Are you aware of any instances in any other nuclear power plant' where worker (s) were exposed to isotopes other than Krypton-85, such as cestem or %Aine,.during the procGs of installing new rocks in a spent fuel j
pool, as a result of leaking or damaged spent fuel rods.
If yes,. identify each incident, and state whether and how inuch additional radiation exposure occurred as a result.
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spent fuel pool water, the potential for worker exposure exists wherever i
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work is undertaken in a spent fuel pool.
The 33 person-rem occupational.
' dose: pool includes that exposure.
See generally response to
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i Are'you aware of any occurrences'at-other nuclear power plants that l
resulted in. increased public radiation exposure during the process 'of
.i installing new racks in a spent fuel pool.
If~ yes, identify the plant (s),
1 described each occurrence, and state whether'and how much additional I
radiation exposure (in millirems per. hour per person) occurred as a
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result, and the number of persons who were exposed..
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, RESPONSE No,.the Staff is not aware of such occurrences at any plant includ(ng n
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' INTERROGATORY 14 1
1 The EA (page B) statcs that "the dose for installation of the enhanced. spent fuel pool cooling system has been estimated very l
conservatively to add less than 10 person-rem to the original dose goal."
.I The following questions relate thereto:
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1 INTERROGATORY 14a j
Describe in detail what activities necessary or incident to the installation of the enhanced spent fuel pool cooling system contributed to this 10 person-rem addition to the dose goal.
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INTERROGATORY 14b Identify and provide copies of all documents used or generated by the hRC or its contractors, including environmental reports and other information provided by Vermont Yankee, to assess, evaluate, or review the radiological impact attributable to installation of the enhanced spent fuel pool cooling system.
RESPONSE
a-b.
This work is not different from maintenance procedures that are conducted on a regular basis. The Staff relied on the reasonable and conservative estimate provided by the Licensee and did not perform an independent, detailed analysis.
The planned operations are usually corducted in low radiation areas.
INTERR0GATORY 15 The EA (page 8) state that the 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:
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l Identify'each of these plants and the applicable proceeding or context in which such reviews occurred (i.e., license' amendment, review
'under 10 CFR f 50.59), and precise nature of the. project.
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INTERROGATORY 15b For each pla'nt, state'whether the NRC performed, or othenvise 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 madeLa comparison between actual. dose ~ exposure and projected dose exposure..If yes, for each plant, describe the results of such
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- comparisons, and identify and provide c6 pies 'of any documents containing i
.such comparisons.
RESPONSE-i a-b. Every Environmental Assessment prepared for an application to
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expand spent fuel pool capacity through reracking includes this
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information.- Over 100 such rerackings have been carried out to 'date;. the'
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information requested is available for review in the Public Document' Room j
1 docketed by individual facility proceeding. The dose exposure j
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l the projected as opposed to actual dose incurred are not available.
I Generally the projected dose e.xceeds the actual dose.
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INTERROGATORY 16, i
Are you aware of any instances with respect to other nuclear power plants where the anticipated estimated, or projected radiation dose 1
exposure, in' person-rems, res,ulting from replacement of original fuel racks and the installation of new fuel racks in a. spent' fuel pool was
'different from the actual' dose exposure?. If yes, identify the plants, and explain why the projected dose exposure was inaccurate.
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_ RESPONSE
.Yes.' It is not contemplated that in every instance the estimated doses and actual dose will be the same. An actual dose is generally less
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than an expected dose.
Licensees are not required to report actual H
person-rem exposure'by specific task, unless specifically requested by the Staff to do so.
The requested comparison is not readily available.
, However, the Licensee in its response to NECNP Interrogatories, dated December 1, 1988, states that when the spent fuel pool modification was about 65% completed, the actual dose incurred was 10.1 person-rem.
Based on a linear projection of estimated dose vs. percentage completion, the Staff estimates that the actual person-rem total dose when all the old racks i
are replaced, will be 15.54 person-rem vs. the Licensee's predicted dose of 23.0 person-rem.
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INTERROGATORY 17 I
The EA (page 9) states one potential source of radiation to workers during, the rerack operation is crud released to the pool water because of
. fuel movement during the proposed spent fuel pool modification.
The following questions relate thereto.
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INTERROGATORY 17a Did'you consider the possibility that: crud would be releaseo from the'
.old racks ss a result of the movement or shuffling of the racks during the reracking operation? If yes, state how much of the.33-person-rem dose -
goal is attributableito the release of crud from the old racks.
If no, explain why you did not consider this possibility.
INTERROGATORY 17b
'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 the reracking operatiorci. If yes, state how -nech of the 33.
person-rem dose goal is attributable to the release of crut from spent fuel assemblies.
If no, explain why you did not consider this possibility, m
INTERROGATORY 17c How much crud will be nieased from the old racks as a result of the moyement or shuffling.of the racks during the reracking operation?
Describe your method for making or estimating this amount, and identify f
and provide copies of all documents ganerated or relied on by the NRC or a
its contractors in estimating this amount.
INTERROGATORY 17d h
How much crud will'be released from the spent fuel assemblies stored in old racks as a result of the shuffling of fuel during the reracking operation? Describe your method for making or estimating this amount, and provide copies of all documents generated or relied on by the NRC or its contractors ie estimating this amount.
' RESPONSE a-d. Yes. g Section 3.4 " Spent Fuel Pool Expansion Safety Evaluation," October 14, 1988.
The Staff did not break down the estimated-j dose in the detail requested here.
We accepted the radiological l-protection program proposed by the Licensee. The Staff does not require l
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reporting of the amount of crud in the spent fuel pool, the racks, or the p
assemblies.
However, Technical Specification 6.50 requires haelth physics procedures to be prepared, approved, maintained and made available to all station personnel to ensure worker protection.
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i INTERROGATORY 17e 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 distributed and released into the spent fuel pool coolant.
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RESPONSE
l The Staff does not require reporting of the amount of crud in the i
spent fuel pool, the racks, or the fuel assemblies, nor does the Staff require complete filtering of crud to zero level.
Rather the NRC requires the filtering system to be operated to reduce radiation levels to meet the requirements of 10 C.f.R. Part 20 and the ALARA goals. Therefore, the time required for the purification system to completely filter out crud from the spent fuel pool cannot be readily calculated. However, significant releases of crud into the pool water during the rerack operation are not expected, since the new racks are clean prior to installation.
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.e INTERROGATORY 18 In preparing the EA, did the NRC assess the radiological' impacts of the proposed action over the life of the plant? Other,than those involving the actual reracking operation, such.as worker exposure resulting from maintenance activities, and placing new spent fuel assemblies in the rack after subsequent refuelings?
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.
RESPONSE
i Yes. The NRC assessed the radiological impact of the additional 870 assemblies which will be placed in the spent fuel pool during the life of the plant. The additional dose to workers from and in the pool will'not change significantly, because the addition of crud is greater during refuelings.when crud is first brought into the pool with the assemblies and primary coolant. The additional dose generated by the refuelings was estimated and is included in the total estimated doses for the proposed-action. The direct dose attributable to the additional assemblies will not j
increase.the dose to the spent > fuel pool area or to workers, due to the depth of the water which shields the assemblies.
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INTERROGATORY 19 Initsevaluationofalternativefive(5)totheproposedaction, construction.of a new independent spent fuel storage installation (ISFSI),
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-i identifying dry cask storage installation, the Environmental Assessment concluded.that dry cask storage installation is not feasible as an.
alternative to the. proposed license amendment because, inter alia the expansion of the existing pool is a resource that thould be usi P, "The
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following questicas relate thereto:
4 INTERROGATORY-19a Identify and describe the " expansion" capacity of the existing pool,,
and state whether.this expansion capacity assumes the use of high density-
. racks,.the installation of. additional racks of the existing design, and/or the storage of an increased number of spent fuel rod assemblies beyond--
j that authorized under Vermont Yankee's current technical specifications.
INTERROGATORY 19b i
' Describe what the " expansion" capacity of the existing pool would'be-if no chari9s are made to the number of spent fuel.. rod assemblies authorized under Vermont Yankee's current technical specifications. -
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Is.this statement based on an assessment of the economic costs of
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implementing the dry cask storage alternative, as compared to the costs of.
using the " resource" of the existing pool? If yes, Please explain.
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RESPONSE
a-c. See response to Interrogatories 3a-e in the "NRC Staff Response to NECNP,'s First Set of Interrogatories and Request for Production of
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Documents to the NRC' Staff on the Staff's Environment 1' Assessment," dated 1
December 8, 1988.
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Has the NRC or.its contractors reviewed or analyzed the radiological imoact on the public of designing and installing the dry cask storage i
alternative described in the EA (p.4).
If yes, describe the results of such a review or analysis, including the projected dose goal resulting l
from that. alternative, and provide copies of all documents related j!
thereto.
RESPONSE
.See responses / o Interrogatories 2a-g and 13 in the "NRC Staff j
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- Response to NECNP's First Set of Interrogatories and Request for I
i Production of Documents to the NRC Staff on the Staff's Environmental Assessment," dated December 8, 1988.
i INTERROGATORY 21 Has the NRC of its contractors reviewed or analyzed the economic costs (projected) to Vermont Yankee of designing and installing the dry caskstoragealternativedescribedintheEA(p.4).
If yes, provide a breakdown of these costs,.and provide all documents related thereto.
Y
RESPONSE
Same as response to Interrogatory 19 above.
INTERROGATORY 22 i
The EA (page 4) states that " assessments for the dry cask ISFSI at the Surry Power Station and the dry modular concrete ISFSI at the H.B.
Robinson Steam Electric Plant Unit 2 resulted in a Finding of No Significant Impact". The following' questions relate thereto:
INTERROGATORY 22a
' State how much time (days, months, and years) it took-the NRC or its contractors to review these a, applications in order to make this findings.
INTERROGATORY 22b State how much time (days, months,.and years) it took to design and install' the Robinson and Surry Independent Spent Fuel Storage Installations.
INTERROGATORY 22c Identify any other nuclear power plants where a dry cask Independent Spent Fuel Storage Installation was reviewed by the NRC, and state how j
much time (days, months, and years) it has taken the NRC or its j
contractors to review these applications.
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RESPONSE
a-c. Same as response to Interrogatory 19.
INTERROGATORY 23 Please identify all persons on whose factual. knowledge, opinions, or technical expertise you rely.or intend to rely for your position on NECNP's environmental contentions.
RESPONSE
The NRC relies on the factual knowledge, opinions, and technical i
expertise'of Michael A. Lamastra and John L. Minns, who prepared the l
answers to these Interrogatories, and of the Staff members who participated in the preparation of the EA, listed at page 13.
t INTERROGATORY 24 Please identify all persons you may call as witnesses 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.
RESPONSE
The NRC Staff does not intend to call witnesses to testify on NECNP's environmental contention. Subpart K - Hybrid Hearing Procedures for i
l Expansion of Spent Nuclear Fuel Stor3ce r,$oacf'y rt Civilian Nuclear Power l
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Reactors ldoes~not provide for callingLwitnesses.
10.C.F.R. Il 2.1113 and
,2.1115. The: Staff has not determined who will prepare sworn written testimony or sworn written submissions.
Respectfully submitted, AuJ.J&
' Patricia ~A. Jehle.
Counsel for NRC Staff'
. Dated at Rockville, Maryland this 16th day of March,--1988.
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