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Category:INTERVENTION PETITIONS
MONTHYEARML20095L2141984-08-27027 August 1984 Response to Concerned Citizens of Louisa County,Va (Cclc) Revised Contention 4 Re Physical Protection Sys for Spent Fuel Shipments.Protective Order Necessary for Cclc Access. Certificate of Svc Encl ML20094L7861984-08-14014 August 1984 Response to 840730 Third Draft of Contentions of Concerned Citizens of Louisa County.All But Contention 4 Should Be Denied.Certificate of Svc Encl ML20064N8311983-02-0909 February 1983 Reply to Util & NRC Responses to Louisa County,Va Contentions.Arguments That Consequences of Spent Fuel Transportation from Surry to North Anna Beyond Scope of Hearing Exalt Form Over Substance.Certificate of Svc Encl ML20028G2181983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa,Va Contentions.Contentions Untimely & No Good Cause Shown. Contentions 1 & 4 Should Be Deferred & Contentions 2,3 & 5 Denied.Certificate of Svc Encl ML20028G2041983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa County,Va Contentions.Contentions Untimely & No Good Cause Shown. Contention 1 Re NEPA Requirements & Contention 2 Re Dry Cask Alternative Should Be Deferred.Certificate of Svc Encl ML20028G2121983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I, IIIB2,VB,VD,VF,VG,VH(4),VI & VJ(3) Should Be Rejected & Contentions 2,IIIA,IIIB1,VA,VC,VE,VH(1 - 3) & VJ(1,2 & 4) Should Be Deferred.Certificate of Svc Encl ML20028G2291983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I,Iiic, IVB,IVD,IVF,IVG,IVI(4),IVJ,IVK(3),VA,VC & VI Should Be Denied & Contentions 2,IIIA,IIIB,IIID1,IIIE,IVA,IVC,IVE,IVH, IVI(1 - 3),IVK(1,2 & 4) & VB Deferred.W/Certificate of Svc ML20028E1411983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1321983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1601983-01-17017 January 1983 Contentions Re Proposed License Amend to Expand Spent Fuel Pool Capacity.Certificate of Svc Encl ML20028E1531983-01-17017 January 1983 Contentions Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry 1 & 2 in North Anna Spent Fuel Pool.Certificate of Svc Encl ML20027D3811982-11-0202 November 1982 Answer to Concerned Citizens of Louisa County 821022 Petition to Intervene.Adequate Interest Established. Applicants Will Respond to Contentions When Filed. Certificate of Svc Encl ML20027D3781982-11-0202 November 1982 Answer to Concerned Citizens of Louisa County 821022 Petition to Intervene.Adequate Interest Established. Applicants Will Respond to Contentions When Filed. Certificate of Svc Encl ML20027D3771982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20027D3751982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20065P8851982-10-22022 October 1982 Petition to Intervene of County of Louisa,Va & Board of Supervisors of County of Louisa,Va Re Proposed License Amend to Expand Fuel Storage Capacity.Certificate of Svc Encl ML20065P8621982-10-22022 October 1982 Petition of County of Louisa,Va & Board of Supervisors of County of Louisa,Va to Intervene Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Certificate of Svc Encl ML20065P8411982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend Authorizing Increase in Capacity of Spent Fuel Pool.Notice of Appearance & Certificate of Svc Encl ML20065P8131982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend to Authorize Receipt & Storage of Surry Spent Reactor Fuel at North Anna.Certificate of Svc Encl 1984-08-27
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20095L2141984-08-27027 August 1984 Response to Concerned Citizens of Louisa County,Va (Cclc) Revised Contention 4 Re Physical Protection Sys for Spent Fuel Shipments.Protective Order Necessary for Cclc Access. Certificate of Svc Encl ML20094L7861984-08-14014 August 1984 Response to 840730 Third Draft of Contentions of Concerned Citizens of Louisa County.All But Contention 4 Should Be Denied.Certificate of Svc Encl ML20064N8311983-02-0909 February 1983 Reply to Util & NRC Responses to Louisa County,Va Contentions.Arguments That Consequences of Spent Fuel Transportation from Surry to North Anna Beyond Scope of Hearing Exalt Form Over Substance.Certificate of Svc Encl ML20028G2181983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa,Va Contentions.Contentions Untimely & No Good Cause Shown. Contentions 1 & 4 Should Be Deferred & Contentions 2,3 & 5 Denied.Certificate of Svc Encl ML20028G2041983-02-0101 February 1983 Response Opposing Concerned Citizens of Louisa County,Va Contentions.Contentions Untimely & No Good Cause Shown. Contention 1 Re NEPA Requirements & Contention 2 Re Dry Cask Alternative Should Be Deferred.Certificate of Svc Encl ML20028G2121983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I, IIIB2,VB,VD,VF,VG,VH(4),VI & VJ(3) Should Be Rejected & Contentions 2,IIIA,IIIB1,VA,VC,VE,VH(1 - 3) & VJ(1,2 & 4) Should Be Deferred.Certificate of Svc Encl ML20028G2291983-02-0101 February 1983 Response to Louisa County,Va Contentions.Contentions I,Iiic, IVB,IVD,IVF,IVG,IVI(4),IVJ,IVK(3),VA,VC & VI Should Be Denied & Contentions 2,IIIA,IIIB,IIID1,IIIE,IVA,IVC,IVE,IVH, IVI(1 - 3),IVK(1,2 & 4) & VB Deferred.W/Certificate of Svc ML20028E1411983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1321983-01-19019 January 1983 Revised Contentions,Superseding Contentions in 821022 Petition to Intervene.Certificate of Svc Encl ML20028E1601983-01-17017 January 1983 Contentions Re Proposed License Amend to Expand Spent Fuel Pool Capacity.Certificate of Svc Encl ML20028E1531983-01-17017 January 1983 Contentions Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry 1 & 2 in North Anna Spent Fuel Pool.Certificate of Svc Encl ML20027D3811982-11-0202 November 1982 Answer to Concerned Citizens of Louisa County 821022 Petition to Intervene.Adequate Interest Established. Applicants Will Respond to Contentions When Filed. Certificate of Svc Encl ML20027D3781982-11-0202 November 1982 Answer to Concerned Citizens of Louisa County 821022 Petition to Intervene.Adequate Interest Established. Applicants Will Respond to Contentions When Filed. Certificate of Svc Encl ML20027D3771982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20027D3751982-11-0202 November 1982 Answer to Louisa County,Va & Board of Supervisors of Louisa County 821022 Petition to Intervene.Adequate Interest Established.Applicants Will Respond to Contentions When Filed & Do Not Object to Consolidation.W/Certificate of Svc ML20065P8851982-10-22022 October 1982 Petition to Intervene of County of Louisa,Va & Board of Supervisors of County of Louisa,Va Re Proposed License Amend to Expand Fuel Storage Capacity.Certificate of Svc Encl ML20065P8621982-10-22022 October 1982 Petition of County of Louisa,Va & Board of Supervisors of County of Louisa,Va to Intervene Re Proposed License Amend to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Certificate of Svc Encl ML20065P8411982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend Authorizing Increase in Capacity of Spent Fuel Pool.Notice of Appearance & Certificate of Svc Encl ML20065P8131982-10-22022 October 1982 Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend to Authorize Receipt & Storage of Surry Spent Reactor Fuel at North Anna.Certificate of Svc Encl 1984-08-27
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20148M6511997-06-18018 June 1997 Comment Opposing Proposed Suppl to Bulletin 96-001 That Would Request Licensees to Take Action to Ensure Continued Operability of Control Rods L-95-045, Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors1995-10-19019 October 1995 Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors ML20080M1121995-02-27027 February 1995 Comment Re Proposed Suppl 5 to GL 88-20 IPEEE for Severe Accident Vulnerabilities. Proposed GL Suppl Should Indicate That Licensees Can Use Llnl Hazard Results of NUREG-1488 Re Revised Hazard Estimates Instead of NUREG/CR-5250 ML20073M0751994-09-23023 September 1994 Comment on Proposed Rules 10CFR30,40,70 & 72 Re Clarification of Decommissioning Funding Requirements. Permitting Access to Funds Only on Semiannual Basis Seems Unnecessarily Restrictive ML20069L5291994-06-13013 June 1994 Comment Supporting Proposed Rulemaking 50-60 Re Petition for Rulemaking & Changes to 10CFR50.54 ML20029D8251994-04-29029 April 1994 Comment Supporting Elimination of Proposed 5-yr Implementation Schedule & Believes That Current Programs Adequate to Maintain Containment Integrity ML20044G1971993-05-24024 May 1993 Comment Supporting Draft Insp Procedure Re Commercial Grade Procurement & Dedication ML20044E5721993-05-19019 May 1993 Comment Supporting Proposed Generic Ltr for Relocation of TS Tables on Instrument Response Time Limits ML20044D3271993-05-0707 May 1993 Comment Opposing Proposed GL Availability & Adequacy of Design Bases Info ML20125B6141992-12-0303 December 1992 Exemption from Requirements of 10CFR50,app a Re GDC-2 & 10CFR50.49 Re Environ Qualification of Electric Equipment Important to Safety for Nuclear Power Plants ML20095J6881992-04-23023 April 1992 Comment Opposing Draft Reg Guide DG-1022, Emergency Planning & Preparedness for Nuclear Power Plants ML20077R5161991-08-14014 August 1991 Comment Supporting Petition for Rulemaking PRM-20-20 Re Reduced Total Effective Dose Equivalent to Individual Members of Public from 0.5 Rem (5 Msv) to 0.1 Rem (1 Msv) ML20235N8531989-02-14014 February 1989 Comment Supporting Chapter 1 Re Policy Statement on Exemptions Below Regulatory Concern.Policy Development for Criteria for Release of Radioactive Matl Needed for Development of Consistent Waste Mgt Practices ML20235P3311989-02-0808 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20236P5851987-11-0909 November 1987 Transcript of 871109 Briefing in Washington,Dc Re Facility Steam Generator Tube Rupture Event.Pp 1-56.Supporting Documentation Encl ML20138N5311985-11-0101 November 1985 Memorandum & Order Affirming ASLB 850903 Initial Decision Authorizing Director of NRR to Issue License Amend for North Anna to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry Power Station.Served on 851101 ML20133K7171985-10-18018 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133K6801985-10-18018 October 1985 Forwards Notice of Withdrawal of Appearance in Proceeding. Requests Svc List Be Revised to Include Client Under Listed Address.W/O Encl ML20133F4241985-10-0909 October 1985 Order Stating That ASLB 850903 Initial Decision Authorizing NRR to Amend OL to Permit Receipt & Storage of Spent Fuel Should Not Be Deemed Final,Pending Further Order. Served on 851009 ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N6981985-09-0303 September 1985 Initial Decision LBP-85-34 Authorizing NRR to Issue Amends to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Initial Decision Effective Immediately.Served on 850904 ML20134N4381985-09-0303 September 1985 Order Granting Licensee 850621 Request to Correct Transcript.Proposed Transcript Corrections & Certificate of Svc Encl.Served on 850904 ML20129K1251985-07-18018 July 1985 Brief in Support of NRC 850718 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing Issuance of Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129K1281985-07-18018 July 1985 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing NRR to Issue Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129F8231985-07-12012 July 1985 Reply Opposing Concerned Citizens of Louisa County post- Hearing Brief.Licensee Proposed Findings of Sabotage & Human Error Not Addressed.Challenge of NRC EIS Conclusion Unnecessary.Certificate of Svc Encl ML20209F0021985-07-0808 July 1985 Post-hearing Brief Re Issues Raised at ASLB 850521 & 22 Evidentiary Hearings.Nrc Required by NEPA to Evaluate Alternative of Constructing & Operating Dry Cask Storage Facility,But Failed to Perform Even Cursory Review ML20209F2041985-07-0808 July 1985 Proposed Findings of Fact & Conclusions of Law Re Application for Amend to Ol,Authorizing Licensee to Ship 500 Spent Nuclear Fuel Assemblies from Surry Power Station to North Anna Station.Certificate of Svc Encl ML20128H0791985-07-0808 July 1985 Order Granting Concerned Citizens of Louisa County 850627 Motion for 7-day Extension Until 850708 to File Proposed Findings of Fact & Conclusions of Law.Served on 850708 ML20128G9471985-06-27027 June 1985 Motion for Extension of 850701 Deadline to File Proposed Findings of Fact & Conclusions of Law.Addl Wk Required Due to Addl Legal Duties.Certificate of Svc Encl ML20127F0511985-06-21021 June 1985 Proposed Findings of Fact & Conclusions of Law Re Util 820713 Application to Amend Ol,Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.Unsigned,Undated Order & Certificate of Svc Encl ML20127F0451985-06-21021 June 1985 Post-hearing Brief Requesting Board Find in Util Favor Re Proposed OL Amend Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.No Basis from Sabotage or Human Error Considerations for Denying Proposed Amend ML20128A7731985-05-22022 May 1985 Transcript of 850522 Hearing in Charlottesville,Va.Pp 313-364.Supporting Documentation Encl ML20125C4081985-05-21021 May 1985 Applicant Exhibit A-H-11,consisting of Undated,Untitled Photograph H ML20125C3601985-05-21021 May 1985 Applicant Exhibit A-B-5,consisting of Undated,Untitled Photograph B ML20125C4221985-05-21021 May 1985 Applicant Exhibit A-J-13,consisting of Undated,Untitled Photograph J ML20125C3471985-05-21021 May 1985 Applicant Exhibit A-3,consisting of SAND82-2365, Assessment of Safety of Spent Fuel Transportation in Urban Environs, Dtd June 1983 ML20125C4301985-05-21021 May 1985 Applicant Exhibit A-K-14,consisting of Undated,Untitled Photograph K ML20125C3941985-05-21021 May 1985 Applicant Exhibit A-F-9,consisting of Undated,Untitled Photograph F ML20125C4361985-05-21021 May 1985 Applicant Exhibit A-L-15,consisting of Undated,Untitled Photograph L ML20125C3101985-05-21021 May 1985 Staff Exhibit S-1,consisting of Undated Environ Assessment & Finding of Proposed No Significant Impact Re 820713 & 0820 Applications for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,allowing Receipt & Increased Storage of Spent Fuel ML20125C3411985-05-21021 May 1985 Applicant Exhibit A-2,consisting of 830915 Procedure 1-OP-4.19, Receipt & Storage of Spent Fuel TN-8L Shipping Cask Unloading & Handling Procedures ML20125C3291985-05-21021 May 1985 Staff Exhibit S-3,consisting of Forwarding NMSS Apr 1985 Environ Assessment Re 821008 Application for Authority to Construct & Operate Dry Cask ISFSI at Surry Power Station ML20125C4001985-05-21021 May 1985 Applicant Exhibit A-G-10,consisting of Undated,Untitled Photograph G ML20125C3381985-05-21021 May 1985 Applicant Exhibit A-1,consisting of 831104 Procedure OP-4.3, Shipping of Spent Fuel TN-8L Shipping Cask Loading & Handling Procedures, for Surry Power Station ML20125C3711985-05-21021 May 1985 Applicant Exhibit A-C-6,consisting of Undated,Untitled Photograph C ML20125C3791985-05-21021 May 1985 Applicant Exhibit A-D-7,consisting of Undated,Untitled Photograph D ML20125C3821985-05-21021 May 1985 Applicant Exhibit A-E-8,consisting of Undated,Untitled Photograph E ML20125C3501985-05-21021 May 1985 Applicant Exhibit A-A-4,consisting of Undated,Untitled Photograph a ML20125C3191985-05-21021 May 1985 Staff Exhibit S-2,consisting of Undated Safety Evaluation Re Increasing Spent Fuel Storage Capacity.Proposed Mods to Spent Fuel Pool & Transshipment/Storage of Spent Fuel Acceptable ML20125C4131985-05-21021 May 1985 Applicant Exhibit A-I-12,consisting of Undated,Untitled Photograph I 1997-06-18
[Table view] |
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l UNITED STATES OF AMERICA y NUCLEAR REGULATORY COMMISSION U k' '
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13 Jg 19 P254 In the Matter of )
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VIRGINIA ELECTRIC AND POWER COMPANY ) '%
)
(North Anna Power Sta., Units 1 and 2) )
Docket Nos. 50-33 8 OLA-2
, ), 50-339 OLA-2 (Proposed Amendment to Operating License )
to Permit Increase in Spent Fuel Storage )
Capacity) )
)
CITIZENS' REVISED CONTENTIONS !
The following is a list of the contentions that Con-
~
cerned Citizens of Louisa County (" Citizens") intends to advance in the above-captioned proceeding. Each conten-tion is followed by a summary of the factual basis for it. Those contentions that were listed in Citizens' Pe-titios.n for Leave to Intervene, filed October, 22, 1982, should be disregarded henceforth, as they are superceded by those contentions listed herein.
Citizens has secured the assistance of two experts in the field of spent fuel transportation and storage:
Mr. Lindsay Audin of Ossining, NY, and Dr. Marvin Res-nikoff, of New York City. Both have written and spoken 8301210023 830119 PDR ADOCK 05000338 C PDR
-1 - - - , - -
hI
-2 '
. . _ Together they have prepared an in-depth study of the .
economic, safety, environmental, and other aspects of spent fuel transportation and storage. This study will be published in book form in March, 1983. They have assisted counsel in the preparation of contentions, and intend to present testimony in support thereof.
- 1. The proposed license amendment constitutes a major federal action significantly affecting the human environ-ment, and thus may not be granted prior to the prepara-tion of an environmental impact statement. .
Citizens contends that for purposes of the environ-mental review required under the National Environmental Policy Act, 42 U.S.C. 84321 et seq., the environmental im-pacts of the proposed license amendment cannot be evaluated apart from the environmental impacts of the Surry-to-North Anna spent fuel transshipment proposal which is being ad-dressed in the companion licensing proceeding. The modifica-tion of the North Anna spent fuel pool was proposed within weeks of the transshipment scheme and is obviously designed to accomodate the 500 fuel assemblies that VEPCO intends to remove from the Surry spent fuel pool. Actions that are related in this vt: cannot be " segmented" for purposes of NEPA review. See W. Rodgers, Environmental Law 97.9 at 789
}
f (1977). Therefore, the environmental effects of the spent
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fuel pool modification must be summed with the effects of -
the transshipment proposal. As discussed below, the effects of this proposal are themselves "significant."
The transportation of spent fuel by truck creates a risk of accidents caosing tremendous human health and environmental damage. Although the NRC has promulgated standards, 10 C.F.R. Pt. 71 App. B, governing spent fuel cask safety, these standards would not prevent serious consequenced in the event of an accident. Moreover, these standards are outdated and unreliable.
The 30-foot drop standard corresponds to the im-pact that would be sustained in a 30-m.p.h. collision.
Since, however, there is no reason to believe that VEPCO's spent fuel trucks will travel at less than 55-60 m.p.h., an accident exceeding NRC criteria is quite possible. Studies show that if a spent fuel cask were to strike a bridge abutment sideways at no more than 12.5 m.p.h., the cask cavity could be expected to rupture. Batelle Pacific Northwest Laboratory, ,,
An Assessment of the Risk of Transportina Spent Nuclear Fuel by Truck, PNL-2588 (Nov. 1978) at 6-4.
Further, NRC fire standards are inadequate. More than 1.5% of all highway accidents involve fires. PNL- l 2588, supra. Many commonly transported substances, e.g.,
diesel fuel, burn at a temperature higher that the NRC's Indeed, design basis fire temperature of 1,450 degrees.
l .
y many substances, e.g., propane, burn at 4000 degrees or higher. Moreover, highway fires in rural areas can be expected to burn for more than the NRC standard of 30 minutes. Many transportation-related fires burn for hours or days. An 1,850 degree-fire which burns for only 30 minutes can cause failure in valves essential to cask integrity.
A hypothetical accident scenario analyzed by our experts for other purposes involves a single truck cask which is involved in an accident in a rural area. They predict impacts including hundreds of cancer deaths per year for several years following the accident, and economic damage-ranging in the tens to hundreds of mil-lions of dollars. Whether impacts of this magnitude can be expected should one of VEPCO's shipments become in-volved in an accident has not yet been determined, but it is safe to say that roughly comparable results are probable.
Other environmental costs associated with the pro-posed license amendment include the risk of sabotage, the effects of which would be comp, arable to those of a serious traffic accident. In addition, the possibility of error by VEPCO employees when performing such tasks as sealing the shipping casks creates additional risks.
Because of all of these risks, the proposed license amendment involves sign'ificant environmental effects.
N ..
- 2. Neither Applicant nor NRC Staff has adequately con-sidered the alternative of constructing a dry cask storage facility at the Surry station.
The use of shippin.g-type casks for* indefinite storage of spent fuel has been shown to be feasible. In the opinion of Mr. Audin and Dr. Resnikoff, dry cask storage methods are among the cheapest and safest of all spent fuel storage i methods, including pool storage. Dry cask storage may well be safe and reliable for up to 50 years or more. In ad-dition to its economic and environmental advantages, dry cask storage provides a capability for on-site as well as off-site transportation of spent fuel. E.R.
Johnson Associates, Inc., A Preliminary Assessment of Alternative Methods for the Storage of Commercial Spent Nuclear Fuel, (Nov. 1981) at 4-1. And in this case the construction of the dry cask storage facility at the Surry station would eliminate the need to transport spent fuel off-site. .,
VEPCO has already applied to the NRC for authority to construct such a facility at Surry. It cannot be determined at this time how long the NRC review process will take. But even if.the facility cannot be completed for several years, the safe operation of VEPCO's reactors will not be threatened. VEPCO claims that it is threat-
/
l ened with the loss of full core discharge ( " FCD") capa-bility at the Surry spent fuel pool. in 1984, and with the shutdown of one of the Surry units in 1987. These dates can be deferred substantially .
First, VEPCO can install three spent fuel racks in the cask lay-down area in the Surry pool. In an internal VEPCO memorandum in Citizens' posse ssion, this alternative is held out as presenting no probl ems from a technical standpoint. It is said to defer the loss of FCD capability by "at least two years. " Another memo in Cit izens ' posses-sion suggests that FCD capability can be extended by at least a another year by repla cing the stainless steel ra &s now in the Surry pool with new, lighter ra cks equipped with i neutron-absorbing materials. And, if necessary, a limited number of spent fuel assemblies could be shipped from Surry to North Anna, so that the dry cask storage facility could be completed before a full transshipment program becomes necessary. Since FCD capability is not essential to safety, see Department of Energy, U.S. Spent Fuel Policy, Storage l
of U.S. Spent Power Reactor Fuel vol. 2 (May 1980) at 11-12, dry cask storage remains an attractive option even if it can't be implemented until roughly 1990.
Respectfully submitted, CMn h
&mes B. DobghertV Dated this 19th day of January, 1983 Counsel for Citizens 3045 Porter St., NW Washington, D.C. 20008 (202)362-7158
UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION ::t 1.EJET .
In the Matter of ) '83 JA" 19 P2 S
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VIRGINIA ELECTRIC AND POWER COMPANY ) htc.,- : ..:[!((Eh ICE
) U (North Anna Power Sta. , Units 1 and 2) )
Docket Nos.NCH50-338 OLA-2
). 50-339 OLA-2 (Proposed Amendment to Operating License )
to Permit Increase in Spent Fuel Storage )
Capacity) )
)
CERTIFICATE OF SERVICE I certify that copies of the foregoing CITIZENS' AMENDED CONTENTIONS were served this 19th day of January, 1983, by deposit in U.S. Mail, First Class, upon the fol-lowing:
Michael Maupin, Esq. Marshall Coleman, Esq.
Hunton & Williams Beveridge & Diamond Box 1535 1333 New Hampshire Ave., NW Richmond, VA 23212 Washington, D.C. 20036 Daniel T. Swanson, Esq. Sheldon J. Wolfe, Chairman U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board '*
Washington, D.C. 20555 U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Dr. Jerry Kline ~
Administrative Judge Dr. George A. Fergu. son U.S. Nuclear Regulatory Commission Administrative.'Jndge Washington, D.C. 20555 School of Engineering Howard University 2300 5th St., N.W.
Washington, D.C. 20059
- Ov.
M m 'e s B . Doughdrty
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