ML20024E903

Statement of Matl Facts as to Which There Is No Genuine Issue Re Eddleman Contention 64(f) on Spent Fuel Shipping Cask Pressure Relief Valve

ML20024E903
Person / Time
Site:	Harris
Issue date:	09/01/1983
From:	Oneill J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20024E900	List: ML20024E899 ML20024E903 ML20024E906 ML20024E910 ML20024E915 ML20024E916 ML20024E917 ML20024E919
References
ISSUANCES-OL, NUDOCS 8309070187
Download: ML20024E903 (4)

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' September'1, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMI'LC SAFETY AND LICENSING BOARD In the Matter of )

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CAROLINA POWER.& LIGHT COMPANY )- Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN )' 50-401 OL MUNICIPAL POWER AGENCY )

V m -(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON INTERVENOR WELLS EDDLEMAN'S CONTENTION 64(f) (SPENT FUEL SHIPPING CASK PRESSURE RELIEF VALVE)

Pursuant to 10 C.F.R. 5 2.749(a), Applicants state, in support of their Motion for Summary Disposition of Eddleman-Contention 64(f) in this. proceeding, that there is no genuine issue to be heard with respect to the following material facts:

1. The issue raised by Mr. Eddleman in sponsoring Contention 64(f) is that a " pressure valve on the casks used for spent fuel transport are likely to unseat" or "the plastic

! components of such valves could and would melt in a fire" re-sulting in a release of the " coolant" and " radioactive contami;'

nation" followed by " fuel overheating & melting."

2. Carolina Power & Light Company ("CP&L") owns a i model IF-3OO stainless steel encased, depleted uranium shielded

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8309070187 830901 PDR ADOCK 05000400 0 PDR 2

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rail shipping cask ("IF-300 cask") manufactured by General Electric Company. The IF-300 cask is~ licensed by the Nuclear Regulatory Commission for the shipment of spent nuclear. fuel by Certificate of Compliance No. 9001. Affidavit of Louis H.

Martin in Support of Summary Disposition of Intervenor Wells Eddleman's Contention 64(f) (" Martin Affidavit"), T 2.

3. The IF-300 cask is the cask used thus far by CP&L to ship spent fuel from its Robinson Plant to its' Brunswick Plant. Martin Affidavit at 13. In the event Applicants are authorized to store spent fuel from CP&L's Robinson and Brunswick Plants at the Harris Plant, .such shipments to the Harris Plant in the foreseeable future are likely to be made in the IF-300 cask. Martin Affidavit at V 4.

4. The IF-300 cask is equipped with one pressure re-lief valve connected to the cask cavity. The purpose of the pressure relief valve is to provide controlled venting under design basis accident conditions for wet shipments and to be leak tight at all other times. Martin Affidavit at 1 5.

5. On June 24, 1981, CP&L withdrew its cask from wet shipment service because of potential problems with the pres-sure relief valve used on all IF-300 series casks. Certificate of Compliance No. 9001 was amended to permit only dry shipments-with the IF-3OO casks. Martin Affidavit at 1 6, 7.

6. CP&L intends to remove the pressure relief valve from its IF-300 cask and replace it with a " rupture disk" prior to any future spent fuel shipments. Martin Affidavit at V 8.

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7. Neither the rupture-disk nor any other component on the IF-300 cask, which is used as an-integral-barrier to the cask cavity, utilizes any " plastic component." Martin Affida-vit at 1 10.

8. In the event CP&L' elects to ship spent fuel from

.its Robinson and/or Brunswick Plants.to the Harris Plant, any such shipments in_the foreseeable future would be dry. Martin Affidavit at 1 11.

9. Pursuant to the Nuclear Waste Policy Act of 1982 and 10 C.F.R. Part 961, Applicants have entered into an agree-ment with the U.S. Department of Energy'(" DOE") for disposal of spent nuclear fuel and high-level radioactive waste produced at the Harris Plant. DOE is responsible for shipments of spent fuel from the Harris Plant to s nuclear waste repository, in 2

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accordance'with the terms and conditions of the DOE disposal contract. Martin Affidavit at 1 12.

Respectfully submitted,

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DJ Ib-mas A. Baxter, P.'C.

Jo n H. O'Neill, Jr.

Sh w, Pittman, Potts & Trowbridge O M Street, N.W.

Washington, D.C. 20036 (202) 822-1090 and Richard E. Jones Samantha F. Flynn Carolina Power & Light Company P. O. Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated: September 1, 1983 l

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