ML20112B130
| ML20112B130 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/12/1985 |
| From: | Jay Dougherty CONCERNED CITIZENS OF LOUISA COUNTY |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20112B132 | List: |
| References | |
| CON-#185-106 OLA-1, NUDOCS 8503190032 | |
| Download: ML20112B130 (8) | |
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IoO REEATED CORRESPONDENCE gC// /3 PC C9WITED y'eo5 USMC W W 18 21 :29 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0FFIC OF SECRETARY 00CiDING & SERvlCf.
BEFORE THE ATOMIC SAFETY AND LICENSING BOASRANCH e
e
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In the Matter of ) ,
) Docket Nos.
VIRGINIA ELECTRIC AND POWER CO. ) 50-338 OLA-1
) 50-339 OLA-1 (North Anna Power Station, )
Units 1 and 2) )
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CONCERNED CITIZENS OF LOUISA COUNTY RESPONSE TO NRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Question 1-1 a. Upon what person or persons do you rely to substantiate in whole or in part your position on Consolidation Contention I?
Answer: Dr. Marvin Resnikoff,
- b. Provide the addresses and educational and professional qualifications of any persons named in your response to a. above.
Answer See the attached resume of Dr. Resnikoff.
- c. Identify which of the above persons or any other person you may call as witnesses in this proceeding.
Answers Dr. Resnikoff.
Question 1-7 Provide summaries of the views, positions or proposed testimony on Consolidated Contention 1 of all persons named in response to Interrogatory 1-1, that you intend to present as witnesses during this proceeding.
Response: The transportation of spent fuel entails environmental risks, safety risks, and economic costs that are not even hinted at in the Environmental Impact Appraisal prepared by the NRC 8503190032 850312 PDR ADOCK 05000338 Q PDR 6]
Staff in connection with this proceeding. In particular, a d
surry-to-North Anna transshipment programs gives rise to a sig-nificant risk of incidents which would lead to substantial per-sonal injury and environmental harm. Among these incidents are sabotage or diversion of a spent fuel cask, and transportation accidents.
- VEPCO's and the NRC's apparent willingness to accept these radiological and environmental risks cannot be justified in light of the f act that it would be preferable, f rom every standpoint, including an economic one, to construct a dry cask storage facilitya at the Surry Station in lieu of shipping Surry spent fuel to North Anna. The use of dry storage casks at Surry would reduce the occupational radiation exposures from the fuel assemblies involved, and would similarly reduce the possibility of fuel handling, transportation, and other accidents. In addition, reliance on dry storage would produce a short-term economic saving-of up to $50 million, including transportation to, and final disposal at, a geologic repository.
Question 1-3 State the specific bases and references to any documents upon which the persons < named in response to Interrogatory No. 1-1 rely to substantiate their views regarding Consolidated Contention 1.
Answer See answer to Interrogatory 1-4.
O-Question 1-4 With regard to Consolidated Contention 1 identify all documentary or other material that you intend to use during this proceeding to support this contention and that you may offer as exhibits on this contention or refer to during your cross-examination of witnesses presented by the Applicant and/or the NRC staff.
Answer:
Resnikoff, M., The Next Nuclear Gamble, Transportation and Storage _o_f Nuclear Waste, Council on Economic Priorities, 1983.
f NRC, Final Environmental Statement on the Transport ,o f Radioactive Materials M Air and Other Means, 1977, (NUREG-0170)
Battelle Pacific Northwest Laboratories, O?portunities to Increase the Productivity of Spent Fuel Shipp:,nq Casks in tn United States, 1980 (PNL-3017)
NRC, Potential Crush Loading of Radioactive Material Packages in Highway, Rail, and Marine Accidents , 1980 t (NUREG/CR-lS88)
Oak Ridge National Laboratories, Cask Designers Guide, 1970 (ORNL-NSIC 68)
E.R. Johnson & Associates, A Preliminary Assessment of Alternative Dry Storage Methods for the~ Storage of Commerci T
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Spent Nuclear Fuel, 1981~(~ DOE /ET/47929-1)
R. E. Hoskins, Integrated Cask Storage Systems for Storago, Transportation, and Disposal of Spent Nuclear Fuel, 1984.
Westinghouse Electric Corp., Preliminary Cost Analysis of a Universal Package Concept in the Spent Fuel Management System,
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1984 (WTSD-TME-032)
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NRC, Transportation of Radionuclides in Urban Environs, 1980
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( NUREG-CR-0743 )
P. Eggers, Severe Rail and Truck Accidents: Toward a Definition o_f_ Bounding Environments for Transportation Packages, 1983 (NUREG/CR-3499)
NRC, Reactor Safety Study, 1975 (WASH-1400)
Question 1-5 specifically With regard to Consolidated Contention 1 identify the " accidents occurring during the transportation of spent f uel casks f rom Surry Station to North Anna" that you assert the Staff failed to evaluate in its Environmental Assessment. In your answer to this interrogatory provide for each " accident" any analysis, data, or basis concerning the probability or consequences of such " accident."
e f Answer Because accidents can be neither predicted nor described before they occur, this interrogatory cannot be answered precisely. It can be said, however, tnat among the general types of accidents (each of which would result in loss of cask integrity and possibly significant releases of radioactive materials) that are made possible by the proposed transshipment programs are:
accidents in which the cask being transported is struck by another object, such as another vehicle or a train; accidents in which the cask itself strikes another object, such as a bridge abutment or a road surface after a fall from a bridge; accidents involving high-temperature and extended duration fires; accidents involving sabotage, diversion, or attempted diversion; accidents involving human error;and combinations of the above.
The probabilities of these accidents is uncertain. To establish the probabilities of the first three categories listed above, CCLC will rely on data obtained from the Virginia Highway Department or the federal Bureau of Motor Carrier Safety. Proba-bilities associated with the other categories are discussed below in connection with Interrogatories 9 and 13.
Estimating the consequences of opent fuel transportation accidents involves a high degree of uncertainty due to the large number of variables that come into play, such as number of assem-blies involved, overall cladding integrity, longth of cooling time since removal from core, severity of cask and/or assembly damage, atmospheric conditions (particularly wind and precipita-tion), population density and environmental sensitivity of sur-roundings, and type of emergency response.
CCLC has yet to calculate the probable consequences asso-ciated with an accident involving one of VEPCO.'s proposed ship-ments. In the past, however, Dr. Resnikof f has estimated the probable consequences of a similar accident occurring in a rural area. See The Next Nuclear Gamble, cited in response to Inter-rogatory 5, at chapter VI, particularly pp. 268-278. As this analysis shows, exposed individuals would probably receive inhal-ation as well as ingestion doses many times the current stan-dards. In addition, farmland within a 1.4-square mile area would be severely contaminated, i
l Question 1-6 With regard to Consolidated Contention 1 specifically identify the " accidents" which you assert might be occasioned by acts of sabotage. In your answer to this interrogatory provide for each " accident" any analysis, data, or basis concerning the probability or consequences of such
" accident."
Answers CCLC has not calculated the probability of possible f orms of sabotage. In Dr. Resnikof f's view, however, commonly-available industrial explosives, such as those used for drilling aids and oceanographic cable cutters, would easily penetrate most transportation casks. Such explosive devices are conical-shaped, r weigh less than one kilogram, and can penetrate 355 mm of steel with a hole diameter of 45 mm.
Presumably, the consequences of such an incident would be comparable to other transportation accidents involving breach of cask containment.
See R.T. Barbour, Pyrotechnics h industry, 1981 (McGraw Hill), p. 47 (describing the usos and of fectiveness of l industrial oxplosives).
l
Question 1-7 With regard to Consolidated Contention i specifically identify the " accidents" which you assert might "be occasioned ... by error of Applicant's employees. in preparing the casks for chipment." In your answer to this interrogatory provide for each " accident" any analysis, data, or basis concerning the probability or consequences of such " accident."
Answer Accidents caused by human error can never be described or evaluated, with precision, before they happen. VEPCO's pro-posed transshipment programs creates a risk of the following kinds of accidents caused by human errors
- Failure to adequately inspect the shipping cask and/or trans-port vehicle. A similar failure led to the uncoupling of a truck cab and its trailor, on which was mounted a spent fuel cask, on the Indiana Turnpike in September of 1983.
- Failure to properly seal and prepare the cask af ter loading it with spent f uel.
A similar incident was reported to the t1RC by Duke Power Company on December 1, 1981.
- Transport vehicle / escort vehiclo driver negligence. Such nog-ligence led to an accident involving a shipmont of fuel to North Anna on June 20, 1984.
- Failure to properly secure the cask tie-downs, impact limiters, overpacks, or other shipping paraphernalia.
CCLC han, and will make available to the Staf f, copios of nown articles regarding the accidents identified above. Also available in a lottor f rom Wm. O. Parker, Jr., Duke Power Co, to John Davis, t1RC, concerning the improperly sealed cask described above.
Quoation 1-0 Provide the bacia for your assertiona in Conco11 dated Contention 1 that construction of a dry cank ntorage f acility at Surry Stations (a) in f oanible, (b) can be ef fected
i in a timely manner, and (c) is the least expensive and safest method for at least 50 years. In your answer to this inter-rogatory provido any data or analysis that support your asser-tions (a), (b), and (c) above.
Answers Dry cask storage at Surry is safer than transshipment to and pool storage at North Anna because there is virtually no accident that can bef all a dry storage cask that poses a signif-icant health or environmental risk. There is no' form of electri-cal failure, mechanical failure, or human error which could foraceably lead to of fsite radioactive releases.
Tranashipment to tiorth Anna, on the other hand, is attended by numerous riska, such as sabotage, human error, materials fail-uros, etc. Moreover, transferring the shipped fuoi to the North Anna pool (and eventually transferring it back out again) in-volvos a risk of fuel handling accidenta and will noconaarily ontail unneconaary occupational exposuroa. There is a largo number of foracoable incidents at North Anna or its opont fuci pool that would damage the Surry opent fuoi and cause offaito reloanos. Among those are pump failuto, chillor failuro, fuel or cack handling accidento, and LOCA.
The foanibility of dry cask storago is shown by the fact that there are neveral commercially-availabio caska that are adoquate for both chipping and storage of spent fuel. Whilo the t1RC Staf f has yet to cortify such canka, nuch cortification la aald to bo expected this year.
Many of the documenta referenced in rosponse to Quontion 1-4, e.g. , Ronnikoff, Johnson, ilonkina, and Wontinghouco, concludo that dry cask atorago la not only foanibio, but the most advan-u
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tageous form of spent fuel storage yet developed. This method i
had received substantial testing in West Germany and by the I j
Tennessee. Valley Authority. r The economic advantages of dry cask storage stem from the fact that once spent fuel is placed in a shippable storage cask, it need never be handled again by VEPCO. i There is no further i need to place it in a pool, comove it f rom a pool, or otherwise handle it until it is shipped of f site to a geologic or interim i repository. Thus, the transportation risks, occupational ex-posures, and economic costs of shipping and handling the fuel ,
(including monitoring, maintenance, and the like) can be avoided. .
Additionally, using dry cask storage at Surry preventa unneces- l sary filling of the North Anna apent fuel. If it placos 500 t
Surry annomblies in the North Anna pool VEPCO will soon be in need of more storage capacity at North Anna. I h
Moreover, so-called " universal casks" may be transferred i directly f rom the roactor site to a geologic repository. Accord- "
ing to the authorition cited in response to Question 1-4, see Westinghouse and lloskins, this feature makes dry cask storage !
probably the least expensive of the opent fuel storago options ;
available today. !
Ronpectfully submitted, l
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i Dated thin day of etnrtT, 1985
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Jamou u. Doughorty
- i. - l Counnot for Concernod
! Citizona of Loutua County' l t
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