ML20236D346
| ML20236D346 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/14/1989 |
| From: | Patricia Jehle NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| Shared Package | |
| ML20236D349 | List: |
| References | |
| CON-#189-8311 OLA, TAC-65253, NUDOCS 8903230061 | |
| Download: ML20236D346 (28) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - __
- $$1 r
pTED CO'Mes March 14, 1989 p,
Nac UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '89 IM 20 P3 :56 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,:r : . 3 Occni - ,
's In the Matter of VERMONT YANKEE NUCLEAR ) Docket No. 50-271-0LA POWER CORPORATION (Spent Fuel Pool Amendment)
(Vermont Yankee Nuclear Power )
Station)
NRC STAFF RESPONSE TO NECNP'S THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON THE STAFF'S ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT - SPENT FUEL EXPANSION (TAC NO. 65253)
On December 20, 1988, New England Coalition on Nuclear Pollution (NECNP) filed its " Third Set of Interrogatories and Request for Production of Documents to the NRC Staff on the NRC Environmental Assessment and Finding of No Significant Impact-Spent Fuel Expansion" (TAC. No. 65253)
(dry cask). The Staff notes that while interrogatories to parties other than the Staff are governed by 10 C.F.R. 9 2.740b, answers to interroga-tories to the Staff, pursuant to 10 C.F.R. 9 2.720(h)(2)(ii), are required only on a finding by the presiding officer that answers to the interroga-tories are necessary to a proper decision in the proceeding and that answers to the interrogatories are not reasonably obtainable from any other source. The Commission's regulation concerning production of NRC records and documents, 10 C.F.R. 5 2.744, requires that a request to the Executive Director of Operations for the production of an NRC record or doct... lent not available pursuant to 6 2.790 by a party tc an initial licensing proceeding state, among other things, why the requested record h
g
[ $DO O PDR 71 p 30
2-s or document is relevant to the proceeding. Notwithstanding the regula- ;
tions in 10 C.F.R. 9% 2.744 and 2.720(h)(2)(ii), .the Staff is voluntarily providing responses to NECNP's interrogatories.
INTERROGATORY 1 1
Please identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each person contributed.
RESPONSE
Frederick C. Sturz, a Senior Project Manager in the Division of Industrial Medical and Nuclear Safety / Fuel Cycle Safety Branch, prepared the responses to all the Interrogatories, except Interrogatories 2a-j, 5, and 15. 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 5. Patricia Jehle prepared the responses to Interrogatories Ca-j and 15.
INTERROGATORY 2 In its evaluation of alternative five (5) to the proposed action, construction of a new independent spent fuel storage installation (ISFSI),
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 "this alternative could not be irrplemented in time to meet the need for additional capacity
1
RESPONSE
The NRC staff objects to the interrogatory as the premise underlying it is newly stated and is beyond the scope of the original Interrogatory 2 as set forth in "NECNP's First Set of Interrogatories and Request for
l-1 's I
l l l* i l Production of Documents to St'aff's Environmental Assessment and Finding of !
1 L No Significant Impact-Spent Fuel Pool Expansion, TAC No. 65253." I 1'
-INTERROGATORY 2a Did the EA's determination that "this alternative could not be implemented in time to meet the need for additional capacity for the Vermont Yankee Plant" rely on any documents, generic or otherwise? If yes, identify and produce all such documents and sections thereof.
' RESPONSE The answer to this Interrogatory was provided in Response to Interrogatory 2a, "NRC Staff Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the Staff's Environmental Assessment," dated December 8,1988, at pages 2-3.
INTERR0GATORY 2b State or provide an estimated date (year and month) by when VY will run out of storage capacity assuming no increase in the number of assemblies for which storage is presently authorized by VY's technical specifications (i.e. 2,000), without full core off-load capacity.
RESPONSE
The Staff objects to Interrogatory 2b as it is a new question not flowing from the Staff's responses to Interrogatories 2a-b provided in "NRC Staff Response to NECNP's First Set of Interrogatories and Request
for Production of Documents to'the NRC Staff on the Staff's Environmental Assessment,"-dated December 8, 1988.
i l
1 INTERROGATORY 2c State or provide an estimated date (year and month) by when VY will run out of storage capacity assuming no' increase in the number of assemblies for which storag, is presently authorized by VY's technical specifications (i.e. 2,000), with full core off-load capacity.
l
RESPONSE
Same as response to Interrogatory 2b above.
1 INTERROGATORY 2d When the EA's determination that alternative five (5) "could not be implemented in time to meet the need for additional capacity for the Vermont Yankee Plant," what did you assume or estimate was the time or i
date by which VY would need this additional capacity?
l
RESPONSE
Same as response to Interrogatory 2b.
l l
1 1 INTERROGATORY 2e l
l Please explain whether " additional capacity," refers to storage of spent fuel assemblies beyond the number of assemblies presently authorized by VY's technical specifications (i.e. any need to store more than 2,000 assemblies), whether this refers to the capacity of the VY spent fuel pool if the proposed action is authorized (i.e. storage of 2,870), or whether it refers to some other expansion capacity of the VY pool. If more than !
one expansion capacity scenario was considered in making the determination 1 that alternative five (5) "could not be implemented in time to meet the !
need for additional capacity for the Vermont Yankee Plant," please I
i l
l 1
1 l
identify the time'or date by which you assumed or estimated that VY would need additional capacity for each such expansion capacity scenario. )
RESPONSE !
Same as response to Interrogatory 2b.
INTERROGATORY 2f When the EA's determination that alternative five (5) "could not be !
' implemented in time to meet the need for additional capacity for the Vermont Yankee Plant," was made, what did you assume or estimate (months and years) was the time needed for implementation of alternative five (5)
(construction of a dry cask ISFSI)?
i
RESPONSE
Same as response to Interrogatory 2b.
INTERROGATORY 2g Was the EA's determination that alternative five (5) is infeasible based at all on assessment of the economic costs of implementing the dry cask storage alternative, as compared to the costs of using the " resource" of the existing pool? If yes, please state what those comparative costs i were assumed to be, and provide all documentation of the costs upon which l the Staff relied in making this determination, including all estimates l which break those costs down into their component parts. l i
RESPONSE
Same as response to Interrogatory 2b.
INTERROGATORY 2h Was the EA's determination that alternative five (5) is infeasible based at all on an assumption that construction of a new independent spent 1
\ ..
fuel storage installation (ISFSI) would require the acquisition of additional land area? If yes, identify and provide all documents, studies, evaluations, or analyses, upon which the Staff relied in making this assumption, generic.or otherwise.
1
RESPONSE
l Same as response to Interrogatory 2b.
i INTERROGATORY 21 Identify and list all factors that the Staff believes would impede or delay implementation of alternative five (5). For each factor, explain the basis for your belief that it would delay implementation, including specific instances in other licensing experiences, and state how much time each factor would be expected to contribute to the delay. j
RESPONSE
Same as response to Interrogatory 2b. l
)
INTERROGATORY 2j Was the EA's determination that alternative five (5) "could not be implemented in time to meet the need for additional capacity for the Vermont Yankee Plant" based on the assumption that VY will not utilire an ISFSI technology previously reviewed and approved by the NRC staff in a topical safety analysis report (TSAR)? If yes, explain why it is not possible for VY to utilize such a previously reviewed and approved TSAR.
RESPONSE
Same as response to Interrogatory 2b.
l l
i
_ _ _ _ _ _ _ _ - . -- _ . . - - - _ _ . _ - - - l
INTERROGATORY 2k Please identify the person or persons who drafted the section of the EAevaluatingalternativefive(5),constructionofanISFSI,andprovide a statement of qualifications for such person or persons.
RESPONSE
Mr. Frederick C. Sturz draf ted the section of the Environmental Assessment which provided the generic assessment of this alternative
'and his statement of professional qualifications is attached. The specific conclusions in the Environmental Assessment were prepared by Dr. Vernon L. Rooney and his statement of professional qualifications is attached.
INTERROGATORY 3 In the ".'iRC Staff Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the NRC Environmental Assessment and Finding of No Significant Impact - Spent Fuel Pool Expansion," dated December 8, 1988, at page 5, in responding to NECNP l I
Interrogatory 3b, the Staff stated the " Design and construction tine for a dry cask independent spent fuel storage installation (ISFSI) is necessarily design and site dependent and may vary according to cask vendors and applicants." Please identify and explain what design end !
site-specific characteristics affect the time required to design and/or i construct a dry cask ISFSI?
RESPONSE
Siting Evaluation Factors and General Design Criteria for ISFSI licensing are contained in Subparts E and F of 10 C.F.R'. Part 72. Site I characteristics, such as natural phenomena, external man-induced events, site boundary, nearby populations, terrain, geology, seismology, climate and meteorology may directly affect the safety or the environmental impact of the ISFSI and they must be investigated and assessed. The ISFSI and any associated structures, systems and components which are important to
[
safety, must be designed to be compatible with and to accommodate the effects of, and site characteristics and environmental conditions. And ,
1 they must be able to withstand postulated accidents. In general, storage casks, modules or facilities are designed to accommodate the effects of natural phenomena, such as earthquakes, tornadoes, lightning, hurricanes, floods, tsunami, and seiches, and to be compatible with a wide range of environmental conditions that may be expected in this country. However, not all design parameters may be the same among different storage system designs. Therefore, potential users must evaluate specific site I characteristics against the system design parameters to determine suitability. If design parameters do not accommodate certain site characteristics or environmental conditions, the potential user must I design additional measures so the specific storage system design is made compatible with the site. Extreme site characteristics, environmental conditions, or natural phenomena generally require a more complicated i
design to accommodate the effects. Thus, a longer time period may be <
required to design and construct the ISFSI. For casks, users must review site-specific factors against cask design parameters, and design the ISFSI l accordingly, to assure cask compatibility with the site.
INTERROGATORY 4 Please provide your best estimate of the range of the time it would take to design and construct a dry cask ISFSI for a BWR? For a PWR?
RESPONSE
Based on ISFSI licensing experience to date the NRC staff's best estimate for the range of the time necessary to plan, design, license,
construct and initially load an ISFSI is from three to six years. See "NRC Staff Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the Staff's Environmental Assessment," dated December 8, 1988, responses to Interrogatories 3d and'
- 6. This estimate includes a one year period from the initial pre-license l application discussions until the submittal of the license application, but does not include time spent by the applicant on planning studies conducted before the initial discussions were held. This estimate is valid for an ISFSI for both BWR and PWR fuels. Because of the Staff's ISFSI licensing and Topical Safety Analysis Report (TR) review experience with PWR fuel, the time required to desigt, and construct an on-site dry cask ISFSI for PWRs is expected to be in the shorter time range. However, l because no storage casks for BWR fuel currently have active NRC approval, the time required to design and construct an on-site dry cask ISFSI for !
i BWRs is estimated to be closer.to six years.
1 INTERROGATORY 5 Was the information provided in the "NRC Staff Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the' NRC Staff on the NRC Environmental Assessment and Finding of No i Significant Impact - Spent Fuel Pool Expansion," dated December 8,1988, in response to NECNP Interrogatory 3d, the sole basis for the EA's conclusion (EA, page 5) that "[t]here is little likelihood that this effort could be completed in time to meet the need for additional capacity..."? If not, please idertify and provide all documents and all other information relied on in reaching this conclusion.
RESPONSE l No. The conclusion was also based on 5 8.0, References, of the EA.
See generally, response to Interrogatory 6, "NRC Staff Response to NECNP's
d ;
j First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the NRC Environmental Assessment and Finding of No Significant Impact - Spent Fuel Pool Expansion," dated December 8, 1988. l l
INTERROGATORY 6 ;
i Please provide your best estimate of the range of the time it would take for the NRC to license a dry cask ISFSI for a BWR, if such an application were submitted on January 1,1989? For a PWR?
RESP 0NtF The Staff's best estimate of the time necessary to license 6 dry cask ISFSI for either BWR or PWR fuel on a reactor site (assuming no interven-tion) is 12 to 18 months. Because of the Staff's experience in ISFS1 licensing and TR reviews for PWR fuel, the time required to license an on-site dry' cask ISFSI, which references a previously reviewed and approved cask design for PWR fuel, is expected to tend towards the lower end of the time range. Because no storage casks for BWR fuel currently have active NRC approval, the time required to license an on-site dry cask l ISFSI and concurrently review a cask TR for SWR fuel is expected to tend towards the upper end of the time range.
INTERROGATORY 7 Provide an estimate of the length of time licensing of a dry cask i ISFSI at VY would take (months and years), based on the following ;
assumptions: that such a license application under 10 C.F.R. [P) art 72 is ;
submitted by VY on January 1,1989, and that the license amendment is not '
l contested.
I
RESPONSE
See response to Interrogatory 6.
INTERROGATORY 8 Provide your best estimate of the length of time licensing of a dry cask ISFSI at VY would take (months and years), based on the following assumptions: that such a license application under 10 C.F.R. [P] art 72 is submitted by VY on January 1, 1989, and that VY.will utilize an ISFSI technology previously reviewed and approved by the NRC staff in a topical
< safety analysis report, and that the license amendment is not contested.
RESPONSE
See response to Interrogatory 6.
INTERROGATORY 9 In .the "NRC Staff Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the NRC Environmental Assessment and Finding of No Significant Impact - Spent Fuel Pool Expansion," dated December 8,1988, at page 6, the Staff noted that information regarding the design and construction time for a new independent spent fuel storage installation (ISFSI) varies according to cask vendors and~ applicants. The following questions relate thereto:
INTERROGATORY 9a Please identify all such cask vendors known by the NRC and identify the type of ISFSI manufactured by each.
RESPONSE
The following is the current list of the NRC staff's dry spent fuel storage TP projects. The list provides vendor name, design type, model
' name, the capacity of each unit, and the status of NRC staff review or approvtl. Please note that not all the projects are casks.
l l
. )
l;4 l
/s DRY SPEllT FUEL STORAGE TOPICAL. REPORT PROJECTS-Status or.
Project Application Approval ;
Vendor /Model/ Type Number' Date Date- Capacity [
l Mitsubishi International Corp. M-33 05/83 withdrawn 52 BWR.
MSF-IV Topical Report 05/87 (Formerly REA-2023)-
l Metel Cask i
Mitsubishi International Corp. M-36 05/83 withdrawn 24 PWR MSF-IV Topical Report 05/87 (Formerly REA-2023)'
Metal Cask General Nuclea'r Systems, Inc. M-34 04/82 review .
16 BWR !
CASTOR Ic Topical Report completed l Metal Cask 05/14/85 approval held in abeyance f General Nuclear Systems, Inc. M-37 12/83 09/30/85 21 PWR Castor V/21 Topical Report 02/86 04/30/86 l Metal Cask' 04/03/87-01/87 NUTECH,.Inc. M-39 12/84 03/28/86 7 PWR NUHOMS-7 Topical Report Concrete Podule !
Nuclear Assurance Corp. M-40 12/84 3/29/88 26 PWR l NAC S/T Cask Topical Report i Metal Cask ~
Westinghouse Electric Corp. M-41 01/85 09/30/87 24.PWR HC-10 Topical Report Metal Cask j Transnuclear, Inc. M-42 09/85 ongoing 24 PWR TN-24 Topical Report review Metal Cask 4 ;
Combustion Engineering M-43 12/85 ongoing 24 PWR I Dry Cap Cask Topical Report review 60 BWR Petal Cask I
I
---__----__.-_w_---- - - - - - - _ . - - _ - - _ - - . - - _
- ,13 -
~ DRY SPENT FUEL STORAGE TOPICAL REPORT PROJECTS Status or Project Application Approval Vendor /Model/ Type Number Date Date Capacity' Nuclear Packaging, Inc. M-44 11/87 QA 3/9/88 9 PWR NuPac CP-9 Topical Report ongoing 1 Concrete Cask review !
FWEnergy Applications, Inc. M-46 10/86 03/22/88 83 PWR Modular Vault Dry Storage 150 BWR Topical Report
. Concrete Vault HUTECH, Inc. M-49 03/88 ongoing 24 PWR NUHOMS-24P Topical Report review Concrete Module General Nuclear Systems, Inc. M-50 07/88 ongoing 28-33 PWR CASTOR X/28-33 Topical Report review Metal Cask Nuclear Assurance Corp. P-51 02/88 09/30/88 56 PWR NAC-C28 S/T Topical Report lietal Cask fluclear Assu'rance Corp. M-52 08/88 ongoing 31 PWR NAC-31 S/T Topical Report review lietal Cask Pacific Sierra Nuclear Assoc. M-53 letter of intent ,
Ventilated Storage Cask System to submit TR in Topical Report Feb 89 Concrete Cask Nuclear Assurance Corp. M-54 12/88 ongoing 28 PWR j NAC-128 S/T Topical Pcport review Metal Cask
I
- la -
INTERROGATORY 9b J Please identify the ISFSI.or cask vendors who supplied or will supply an ISFSI to the Surry plant, the H.B. Robinson plant, and the Oconee Plant.
RESPONSE
The Surry ISFSI uses the General Nuclear Systems, Inc., CASTOR V/21 storage cask. Virginia Electric and Power Company (VEPCO). contracted with Bechtel for the engineering design of the Surry ISFSI and for the preparation of the. license application. The site preparation and construction'was performed by VEPCO's construction department, using.
specialty subcontractors as required. VEPC0 submitted a license I 1
amendment, dated January 13, 1989, for the use of the Westinghouse MC-10 spert fue. :torage cask. VEPC0 also indicated to the NRC staff that it would eventually like to use the Nuclear Assurance Corporation's FAC-128 l
S/T cask end the General Nuclear Systems, Inc. Castor X cask at the Surry ISFSI.
Nutech Engineers, Inc., was the prime contractor for the design and analysis of the H. B. Robinson ISFSI. Carolina Power & Light Company (CP&L) was responsible for onsite construction, material procurement and l
contract administration. The NRC staff is unaware of any CP&L intentions ,
to use designs other than the NUHOMS designs at the H. B. Robinson Steam Electric Plant site. See also, "NRC Staff Response to NECNP's First Set
- of Interrogatories and Request for Production of Documents to.the NRC Staff on the Staff's Environmental Assessment," dated December 8, 1989, response to Interrogatory 6, at page 10. i Nutech Engineers, Inc., is the prime contractor for the design and l
analysis of the Oconee ISFSI. It is also responsible for the fabrication l
of the transfer equipment and the canisters. The Duke Power Company (Duke)' onsite construction organization is responsible for the concrete module construction. The NRC staff is unaware of any Duke intentions to i use designs other than the NUH0MS-24P design at the Oconee ISFSI.
See also, "NRC Staff Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the Staff's Environmental Assessment," dated December 8, 1989, response to Interrogatory 6, at pages 10-11.
INTERR0GATORY 9c Does the Staff know what price is currently being ouoted for the for each purchse cask vehdor of casks, identified and in forresponse the construction of a dry[9)(a) to interrogatory cask and ISFSI(b), above.
If yes, identify this information, and provide all documents in the Staff's possession containing this information.
RESPONSE
No. The Staff does not know what price is currently beirg quoted for the purchase of casks, or for the design, analysis, and construction of a ;
dry cask ISFSI, for each cask vendor identified in response to Interrogatory 9(a) and (b), above.
The DOE in its " Initial Version Dry Cask Storage Study," DOE /RW-0196, August 1988, provides cost estimates of storage for several dry storage concepts.
IllTERROGATORY 9d Does the Staff I,new what time is estimated by each cask vendor identified in response to interrogatory 9 (a) and (b), above, to complete the design and construction of a dry cask ISFSI for a BWR? For a PWR? If I yes, identify this information, and provide all documents in the Staff's possession containing this information.
RESPONSE
No. The Staff does not know what time is estimated by each cask vendor identified in responscs to Interrogatories 9(a) and (b), above, to j couplete the design and construction of a dry cask ISFSI for a BWR or PWR.
IllTERR0GATORY 10 In the "NRC Staff Response to ilECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the NRC Environmental Assessment and Finding of No Significant Impact - Spent Fuel Pool Expansion," dated December 8, 1988, at pa that the EA's evaluation of alternative five (ges5) 6-7, to thethe Staff responded proposed action, construction of a new independent spent fuel storage installation (ISFSI),
was based on past licensing experience," identifying the Surry and ll.B.
Robinson plants, for which license applications were submitted in 1982 and 1985, respectively. The following questions relate thereto:
INTERROGATORY 10a Your response indicates that the Surry ISFSI was licensed in approximately three years and nine months from the date of the utility's l license application submittal, and the H.B. Robinson ISFSI was licensed approximately one year ard six months from the date of the utility's I license application submittal. Identify and explain what factors, including but not liriited to improvements in the ISFSI technology, increased fiRC and industry experience and familiarity with the ISFSI technology, and utilization of an ISFSI technology previously reviewed and approved by the NRC staff in a topical safety analysis report, contributed !
to the shorter amount of licensing time for the H.B. Robinsen plant.
I RESF0 HSE 1 See "l1RC Staff Response to NECNP's First Set of Interrogatories and Rectest for Production of Documents to the hRC Staff on the Staff's
i Environmental Assessment," dated December 8, 1988, response to Interroga-tory 6, at pages 9-12 and the NRC staff's response to Interrogatory 9(a) above, for information about dates of receipt for TRs and license applications. j At the time VEPC0's license application for dry spent fuel storage at its Surry Power Station was submitted, no TRs had been reviewed by the NRC; in fact, TR reviews were just beginning. At that time, VEPC0 had not chosen a cask design to be employed for storage. Instead, VEPCO indicated to NRC staff thet it would await completion of the NRC safety review of and approval of cask design TRs before selecting a cask or casks. Neither VEPC0 nor the NRC anticipated the delays that were encountered in the submittals of cask design information in the form of TRs by potential vendors. VEPCO could only go so far in responding to the Staff's questions without the selection of a cask design. In March 1984, VEPC0 notified the NRC staff that it had selected the CASTOR V/21 dry storage cask. The TR for this cask was received by the NRC in late January 1984.
The NRC staff review of the cask TR paralleled the review of the Safety Analysis Report subnitted with VEFC0's application. Because VEPC0 l submitted the first application for dry spent fuel storage and the CASTOR l casks were among the first casks reviewed by the NRC staff, additional
- tirre was needed to complete the dry spent fuel storage licensing process.
I Additionul time was required to develop acceptable review procedures, to properly document the design analyses, to identify technical issues and to provide the necessary bases for them. Because the CASTOR V/21 cask is designed and fabricated in k'est Germany, the materials used in the fabrication of components important te stfety were referenced to Deutsch l
I
- - - - - - - - - - - . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ .. J
Industrie Normen (DIN), quality standards. . For this reason additional time was required to reconcile DIN standards with appropriate American Society ofHechanicalEngineers(ASME)Codestandsrds. Another factor in the length of review time for the Surry application was that the CASTOR V/21 cask uses some materials not covered by any authoritative standard or specification. Considerable time and effort was spent establishing material properties or specifications and the quality assurances and controls necessary to evaluate whether the material met all the safety.
criteria of 10 C.F.R. Part.72. Lastly, additional analyses, redesigning, and more evaluations were necessary as a result of tests performed on a l CASTOR V/21 cask, by the Department of Energy (DOE) at its Idaho National Engineering Laboratory (INEL), in a cooperative derronstration program with VEPCO.
When Carolina Pcwer & Light Company's (CP&L) license application for an ISFSI at its H. B. Robinson Steam Electric Plant was received by the NRC, the VEPC0 application and CASTOR V/21 cask TR reviews were well l underway. Acceptable review procedures, the nieans to document design l
L analysts, and the technical issues and their bases had been established in the Surry ISFSI licensing review. The CP&L application and the NUHOMS TR reviews also proceeded in' parallel; hcwever, the NUHOMS design uses
. relatively standard construction naterials and that allowed for much more l
straightforward analyses.
1 l
l INTERR0GATORY 10b 15 it pcssible or likely that the length of time it take[s] to license an ISFSI et VY, f rom the submittal of a license application to l
i
i fuel loading, would be shorter than H.B. Robinson if such an application were submitted on or after January 1,1989, as a result of VY's utiliza-tion of an ISFS! technclogy previously reviewed and approved by the NRC staff in a topical safety analysis report?
RESPONSE
Yes, depending on the timing of the application. The NRC staff expects as many as five new ISFSI license applications in 1989. This' number of new applications in this time period could press NRC staff l resources. Past NRC staff practice in the review of TRs has been to ;
review them in the order in which they are received. However, TRs :
associated with a license application have been given preference. License i applications are reviewed in the order in which they are received. .
l l
INTERR0GATORY 10c Please identify the actual costs for the design and construction of '
the ISFSI at the H.P. Robinson plant.
RESPONSE
The NRC staff has no information en the actual costs for the design and construction of the ISFSI at the H. B. Robinson Steam Electric Plant.
Any data concerning the cost for the design and construction of this ISFSI i
would not be representative of a full size ISFSI because it was designed '
for a limited amount of fuel and was built as a demonstration facility in cooperation with DOE. ,
l
g, INTERROGATORY 10d Please identify the actual costs for the design and construction of the ISFSI at the Surry plant.
RESPONSE
The NRC staff has no information en the actual costs for the design and construction of the Surry ISFSI. However, VEPCO, in its Surry ISFSI License Application, Section 1.4, did provide an. estimate of the project costs:
The total cost of building and operating the Surry ISFS1 over the lifetime of the project in 1982 base dollars would be a low for capital expenditures of $57.8 million and a.high of $90.6 million with an operation and maintenance cost of $1.9'million.
The DOE in its " Initial Version Dry Cask Storage Study," 005./RW-0196, August 1988,,at page 33, provides factors for estimating the unit-cost range for storing intact spent. fuel in metal storage casks. Using the DOE factors, the estimated' cost range for the Surry ISFSI would be between $45 million end $79 million.
l INTERROGATORY 11 In the "NRC Staff Response to NECNP's First Set of Interrogatories I and Request for Proc'uction of Documents to the NRC Staff on the NRC Environmental Assessment and Finding of No Significant Impact - Spent Fuel Pool Expansion," dated December 8,1988, at pages 10-11, in response to NECNP Interrogatory 6, the Staff stated that an ISFSI application was currently pending from Duke Power Company "for use of NUH0MS-24P design at its Ocenee Nuclear Station." The following questions relate thereto:
INTEisROGATORY lla Fitase identify and provide an estimate of the costs for the design !
and construction of the ISFSI at the Ocorec plant.
\
RESPONSE
Duke provided an estimate of the project costs in its Oconee Nuclear Station ISFSI License Application, Chapter 1: " Duke estimates that the .
l total cost of the proposed Oconee Nuclear Station ISFSI will be approximately $20 million.'
In the ' Initial Version Dry Cask Storage Study," 00E/RW-0196, August 1988, Section 4.1.4.4, at page 42, the DOE states: "The total-system cost for the NUHOMS systen to be constructed at Duke Power's Oconee site is estimated at $40 million for a capacity of almost 1000 hTHM."
INTERROGATORY lib Please provide an estimated date by which the Staff review of the Topical Safety Analysis Report for the Oconee ISFSI application will be completed.
RESPONSE
Duke's projected spent fuel storage requirements necessitate operating the Oconee fiuclear Station ISFSI by January 1990. Duke requested that the NPC review anc approve the ISFSI Safety Analysis Report (SAR) by March 31, 1989. The NRC staff plans to complete the ISFSI SAR review by that datc. The review schedule for the NUti0t:S-24P TR is paralleling the review of the Oconee Nucleer Station ISFSI SAR review.
This schedule allows tirac for the Commission to review Duke's application and to authorize the issuance of a license by spring or early summer of 1989.
INTERR0GATORY 11c l
' State whether or not this licensing application is being contested.
RESPONSE' The-Oconee Nuclear Station ISFSI license application is not being contested. !
i l
INTERR0GATORY 11d ,
l Please identify any further significant licensing actions connected j
with this application that have occurred since the date the "NRC Staff '
Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the NRC Environmental Assessment and Finding of No Significant Impact - Spent Fuel Pool l Expansion,* dated December 8, 1988, response to NECNP Interrogatory 6, I was prepared, j i
RESPONSE
Ho further significant licensing actions connected with the Oconee I huclear Station License Application have occurred. Duke Power Compary and Nutech Engineers, Inc., have provided responses to NRC staff questions, and the NRC staff is continuing its safety reviews. l i
l INTERR0GATORY 12 i
In VY's letter to the NRC dated flarch 2, 1988 (FVY 88-17), VY !
estimated that its enhanced spent fuel pool cooling system "will be operational no later than the end of Cycle 16 (Projected 1993)." If a !
license application for an ISFSI were subraitted by VY on January 1,1989, es e substitute for the proposed action, assuming that such a license j application was uncontested, is it possible that the ISFSI could be licensed prior to October, 19937 If not explain what factors would prolong the time to license such an ISFSI.
RESPONSE
See responses to Interrogatories 6, 7 and 8.
INTERROGATORY 13 In its evaluation of alternative five (5) to the proposed action, constructionofanewindependentspentfuelstorageinstallation(ISFSI),
' identifying dry cask storage installation, the Environmental. Assessment concluded that dry cask storage installation "is environmentally acceptable." (EA, page 4). Identify the specifica1' environmental factors that support this statement, including, but not limited to analyses'of occupational radiation exposures, assessment of risks of severe accidents, etc, associated with construction of an ISFSI, and identify all documents, studies, reports, analyses or past licensing experience relied on or supporting this statement.
RESPONSE
As previously stated in the "NRC Staff Response to NECNP's First Set of Interrogatories and Request for Production of Documents to the NRC Staff on the Staff's Environmental Assessment," dated December 8, 1988,.in response to interrogatory Pa, "the evaluation of alternative five, ... was a generic evaluation of environmental impacts, which relied on tiering on a previous environmental impact statement, NUREG-0575 (EA Ref. No. 2), and was based on previous licensing experience (EA Ref. Nos. 20 and 21)."
Also, the NRC has issued an Environmental Assessment and Finding of No Significant Impact in connection with the Oconee Nuclear Station ISFSI license application, which provides additional support fbr the conclusion that dry storage is environmentally acceptable. The three EAs address site-specific construction and operational impacts in connection with land and water resources, sccioeconomics, climatology, noise, end air quality, and the projected radiological doses to the workers and the public are 1
also associated with site-specific factors; however, the estimates for the three sites can be used to draw general conclusions about potential !
radiologicci and environmental effects of dry storage. Additionally, the Cortraission, in its " Waste Confidence Decision," Federal Register, Vol. 49, No.-171, August 31, 1984, stated that it " finds reasonable assurance that, if necessary, spent fuel...can be stored safely and without significant l environmental impacts" in reactor storage pools or in " independent spent-fuel storage installations." Moreover, the " Environmental Assess- ,
ment for 10 C.F.R. Part 72 ' Licensing Requirements for the Independent j i
Storage of Spent Fuel and High-Level Radioactive Waste,'" NUREG-1092, and the Supplementary Information for the proposed rule published in the i Federal Register (51 Fed. Reg. 19106) on May 27, 1987, contain specific analyses which show the potential environmental impacts of dry storage of spent fuel in casks are staa11.
The NRC staff has assessed the public health consequences of dry storage cask accidents and acts of radiologic sabotage. In connection i i
with separate, ongoing rulemakings related to licensing requirements for stcrage of high-level radioactive wastes and emergency preparedness, the i NRC staff reevaluated consequences of potential accidents involving spent fuel storage in dry casks. See 51 Fed. Rg.19106 and "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensces," NUREG-1140. The reevaluation revealed no reason to increase the estimated doses set forth in NUREG-0575 and NUREG-0709,
" Safety Evaluation Report Related to the Renewal of Material License SNk-1265 for the Receipt, Storage, and Transfer of Spent Fuel Pursuant to 10 C.F.R. Part 72 - Morris Operation - General Electric Company," Docket l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ . _ . ________.____________J
l l
Nos. 70-1308 and 72-1. The NRC staff also determined that the releases from dry cask storage are of a magnitudo comparable to that for wet storaga. Because of the physical characteristics of the storage casks, the conditions of storage, and specific security provisions, the NRC staff concl'udes the'potentihl risk to the public health and safety due to I accidents or sabotage is extremely small.
Il4 TERR 0GATORY 14 The " Initial Version Dry Cask Storage Study," issued for comment in -
August, 1988 by the 11.5. Department of Energy, Office of Civilian Radioactive Waste Management (DOE /RW-0196), at page 13, stated that "the NRC plans to issue in 1988 a proposed rule to amend 10 CFR Part 72 by providing a process for the issuance of generic certificates of compliance '
for dry-storage casks." The following questions relate thereto:
IliTERR0GATORY 14c -
If such a process were approved, would it shorten the length of time it would take to design and construct an ISFSI? If yes, by how much time (months and years)?
RESPONSE t We have insufficter,t information to provide an answer to this t question.
I j IllTERROGATORY 14b
( If such a process were approved, woulo it shorten the length of tine it would teke the f4RC to license an ISFSI, and, if yes, by how much time (months and years)?
l w__-_____-___-___
RESPONSE
If such a process were approved and the NRC were to licerse an ISFSI, the amount of time for NRC to conduct its licensing review would not change. However, under such a process, the NRC would conduct its safety reviews of dry spent fuel storage casks and issue a Certificate of Compliance for each type or model of cask approved. These Certificates of Compliance would set forth the conditions of each cask's use. A general license would be issued to holders of power reactor licenses for the storage of spent fuel in dry casks approved by the NRC. The reactor licensee would have to show that there are no changes required in the facility technical specifications or unreviewed safety questions rtlated to activities involving storage of spent fuel under the general license.
The licensee would also have to show ecnformance with conditions of.the Certificate of Compliance issued for the cask by the NRC. The licensee vould have to establish and maintain records showing compliance. And the records would have to be made availeble for inspection by the Commission.
Ur& r this process, power reactor licensees would be allowed to store spent fuel at the reactor site without additional NRC site-specific reviews (that is, no NRC site-specific licensing of an ISFSI). For j storage designs not compatible with such a process, NRC licensing under 10 C.F.R. Part 72 vet,16 continue essenticily unchanged.
l l- l INTERROGATORY lac Please ider tify and provi& all documents, analyses, studies or reports or segrrents thereof prepared by, or in the possession of the NRC or its contractors, or prepared by the U.S. Departnent of Energy or its contractors, which evaluate dry cask storage in connection with the i
Staff's possible issuance of generic certificated of cen;pliance for dry cask storage. Please note that we are requesting factual analyses not subject to claim or privilege.
RESPONSE
The NRC staff is not aware of any documents, analyses, studies or reports or segments thereof prepared by, or in the possession of NRC
]
contractors, or prepared by the DOE or its contractors which specifically evaluate dry cask storage in connection with the NRC staff's possible issuance cf generic. Certificates of Compliance for dry cask storage. The DOE document " Initial Version Dry Cask Storage Study," August 1988, DOE /RW-0196, is indirectly related. The study was prepared pursuant to Section 5064 of the Nucleer Waste Policy Amendments Act of 1987 and the Nuclear Waste Policy Act of 1982. The NRC staff is preparing the appropriate analyses and documentation necessary for a Proposed Rule to amend its regulations in 10 C.F.R. Part 72. The information is considered pre-decisional and cannot be provided at this time. However, upon Commission approval the Proposed Rule will be published for comment and the informatico will be publicly available in the NRC Public Document I'
Room.
INTERR0GATORY 15 Does the Staff intend to introduce any documents other than the EA in any hearing or summary disposition proceedings that may be conducted with
{ respect to MECNP's Environniental contentions? If yes, please identify and l
produce those documents.
1
RESPONSE
No. The Staff does not intend to introduce documents into this proceeding, other than the Environtrental Assessment and those referred to in the Environmental Assessment. To the extent appropriate, the Staff might j rely on its Interrogatory responses. The Staff will advise NECNP if their intentions change.
Respectfully submitted, A sh% G
,1 Patricia Jehle Counsel for flRC Staff Dated at Rockville, flaryland this 14th day of March , 1989 l
I i
- - _ _ - _ - _ _ _ _ _ _ _ .