Appendix — Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc.
Supreme Court brief1978
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APPENDIX
VOLUME Il - RODAR, JR, CLERK |
Paces 401 - 1396
In THE
Supreme Court of the Anited States
Octrosper Term, 1976
No. 76-419
VERMONT YANKEE NUCLEAR POWER
CORPORATION,
Petitioner
v.
NATURAL RESOURCES DEFENSE COUNCIL,
INC., ET AL.,
Respondents
No. 76-528
CONSUMERS POWER COMPANY,
Petitioner
v.
NELSON AESCHLIMAN, et Au.,
Respondents
ON WRITS OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT
PETITIONS FOR WRITS OF CERTIORARI FILED
SEPTEMBER 21 AND OCTOBER 14, 1976
CERTIORARI GRANTED FEBRUARY 22, 1977
401
[SUMMARY OF APPLICATION
VERMONT YANKEE NUCLEAR POWER STATION
Ex. 3, pp. 2-5, AEC Dkt. No. 50-271]
SITE AND ENVIRONS
The site for the Vermont Yankee Nuclear Power Station
is located in the town of Vernon, Vermont in Windham
County on the west shore of the Connecticut River upstream
of the Vernon Hydroelectric Station. The site consists of
about 125 acres owned by the Vermont Yankee Nuclear
Power Corporation and a narrow strip of land owned by
New England Power Company and located between the
Connecticut River and the boundary of the Vermont Yankee
property and in which Vermont Yankee has perpetual
rights and easements granted by the New England Power
Company with the approval of the Federal Power Commis-
sion. The City of Brattleboro, Vermont is about five miles
upstream of the site. There are no residences on the site,
and the minimum distance from the reactor building to the
boundary of the exclusion zone, as defined in 10 CFR 100, is
910 feet. The nearest town with a population of 25,000 or
greater is Northampton, Massachusetts, about 30 miles to
the south. Much of the land around the site is undeveloped.
Most of the developed land is used for agriculture and dairy-
ing, with houses scattered or grouped in small villages. Ap-
pendix B appended hereto is a map showing the location of
the site with respect to adjacent areas (FSAR 2.2).
In July 1969 Vermont Yankee initiated a comprehensive
environmental radiation surveillance program designed to
monitor the atmospheric, terrestrial and aquatic environ-
ments in the vicinity of the station. This program was de-
veloped in cooperation with the Vermont State Department
of Health and reviewed by the Vermont Water Resources
Board.
402
It is Vermont Yankee’s intent that the environmental sur-
veillance program will be closely coordinated with condi-
tions of station operation by systematically correlating in-
formation developed through continuous in-plant monitor-
ing, effluent release records and environmental sample col-
lection and analysis. The primary purpose of the surveil-
lance program is to make station management and the State
Health Department aware of any conditions of station op-
eration which may have a significant effect on the environ-
ment. The operational surveillance program will be a
graded program subject to periodic critical review (FSAR
2.6).
Plant Design Bases Dependent Upon Plant Site
and Environs Characteristics
Information relating to the site and environs for the
Vermont Yankee Nuclear Power Station is presented in
Section 2 of the FSAR. The design features which were
dependent or affected by the site characteristics are sum-
_ marized below.
Condenser Off-Gas System
The condenser off-gases will be discharged to the atmos-
phere through deeay piping and a stack 308 feet above
grade. The off-gas system is used during normal operation.
It is expected that the release of gaseous radioactivity will
be kept within small fractions of the limits specified in 10
CFR 20 based on the use of the off-gas system. However,
to further minimize the release of gaseous radioactive
wastes, Vermont Yankee will modify the off-gas system to
provide additional holdup and subsequent decay of air
ejector off-gases. The design of this advanced off-gas sys-
tem is currently underway and fabrication and installation
403
will be completed by the end of the first refueling outage
(FSAR 9.4 and Appendix I).
Liquid Waste Effluents
Liquid effluents will be released from the radwaste dilu-
tion system at a point downstream of the aeration blocks in
the station discharge structure. The liquid waste treatment
system has been designed so that those liquid effluents
which are released from the station are always well within
the limits specified in 10 CFR 20. This is a batech-type sys-
tem wherein the wastes are separately collected and pro-
cessed based upon the most efficient methods, Batches of
liquid radwaste are sampled and analyzed prior to dis-
charge. If suitable for discharge, radwaste effluents are
released at a rate such that the resultant concentration at
the point of release will never exceed 10 CFR 20 nor the
applicable state release limit. During each release, a con-
tinuous radiation monitoring device is set to alarm upon
excessive activity concentration in the radwaste discharge
line. Diseharge records are maintained for all station
liquid radwaste effluents.
Wind Loading Design
Plant structures are designed to withstand the effects of
80 mph winds with gusts to 110 mph. Although the prob-
ability of a tornado occurring at the Vermont Yankee site
is small, all structures and equipment necessary to initiate
and maintain a safe plant shutdown are designed to with-
stand a tornado wind loading of 300 mph (FSAR 2.3 and
12.2
IHlydrology
The site is at mile 138.3 above the mouth of the Connecti-
eut River on the west bank on the pond formed by the
404
Vernon Dam and Ilydroelectriec Station. The maximum
recorded water level at Vernon was 231.4 feet mean sea
level which oceurred during the flood of March 19, 1936.
The minimum elevation of access openings to buildings
housing important equipment is. 252.5 feet mean sea level,
more than 20 feet above the maximum observed water level.
An analysis of water levels resulting from the probable
maximum flood, a postulated occurrence which is more
severe than the most significant historical event, has been
performed and shows that the station is suitably protected
against the maximum probable flood (FSAR 2.4 and Ap-
pendix IL).
Geology
The site area is overlaid by glacial deposits, with an
average of 30 feet of glacial overburden above the local
bedrock. Major structures of the station, including the
reactor building and turbine building, are supported on
rock. Seismic velocity measurements at the site verified
the hard massive nature of the bedrock and there were no
indications of deeply weathered or faulted zones (FSAR
2.5).
Seismic Design
The maximum acceleration at the bedrock surface of the
plant site from an earthquake is expected to be from 0.03g
to 0.04g. Although this acceleration is considered to be con-
servative, the seismic design for structures and equipment
important to safety are based on dynamic analyses using
acceleration response spectrum curves together with a
ground motion of 0.07g. The station is also designed so that
the plant can be shutdown in a safe and orderly manner
even if the ground acceleration were 0.14g (FSAR 2.5 and
12.2).
405
SUMMARY DESCRIPTION OF THE FACILITY
3.1 Lwrropuction
The nuclear steam supply system of the Vermont Yankee
Nuclear Power Station utilizes a General Electric boiling
water reactor identical in most design features to Monti-
cello Unit No. 1, the operation of which was recently author-
ized by the Atomie Energy Commission, The design of the
features of the Vermont Yankee facility is based upon
power technology attained during the development, design,
construction and operation of boiling water reactors of
similar types, including the Monticello facility. These fea-
tures include the basic fuel design, Zircaloy fuel cladding,
hydraulically operated control rods, in-core neutron moni-
toring instrumentation, pressure suppression containment
and radioactive waste control.
The following discussion summarizes the principal de-
sign features of the Vermont Yankee facility which are sig-
nificant to safety considerations. The FSAR and subse-
quent amendments present an extensive technical deserip-
tion and evaluation of this facility and FSAR references
elaborating on the discussion below are given in each sum-
mary. Appendix C of this testimony gives a comparison of
the significant station design features of Vermont Yankee
to other boiling water power reactor stations. A drawing
of a reactor and containment typical of the Vermont Yankee
plant is shown in Appendix D.
3.2 Reactor Primary System
The reactor is a single eyele, forced circulation, boiling
water reactor producing steam for direct use in the steam
turbine.
The fuel for the reactor core consists of slightly enriched
uranium dioxide pellets contained in sealed Zircaloy-2
406
tubes. These fuel rods are assembled into individual fuel
assemblies of 49 fuel rods each, Each complete core load-
ing consists of 368 fuel assemblies (FSAR 3.2),
Control of the reactor is achieved by movable control
rods. Reactor power level control is augmented by con-
trolling the recirculation flow rate through the reactor core.
The core is designed so that the reactor can be shutdown
from any point in its operating cycle by control rods alone,
Stored energy will be available from reactor pressure and
gas-charged accumulators to insert all control rods simul-
taneously for rapid shutdown of the reactor (FSAR 3.4).
In addition, there is provided a standby liquid control
system containing a boron neutron-absorbing solution which
is capable of shutting down the reactor and maintaining it
in a shutdown condition. This system is an independent
system that would be used to shutdown the reactor in the
unlikely event that shutdown cannot be accomplished with
the control rod system alone (FSAR 3.8).
The reactor pressure vessel contains the reactor core and
supporting structure, the steam separators and dryers, the
jet pumps, the control rod guide tubes, the feedwater and
core spray spargers and other components. The main con-
nections to the reactor vessel include the steam lines, reactor
coolant recirculation lines, feedwater lines, control rod drive
housings and other connections fortore cooling. Appendix
I. is a cut-away view typical of the reactor vessel and core
arrangement (FSAR 3.3).
Reactor Coolant will enter the reactor near the bottom of
the core and flow upward through the fuel assemblies. The
heat from the nuclear reaction will produce a mixture of
steam and water. The steam will be separated from the
water by means of steam separators and dryers located in
the upper portion of the reactor vessel, and will then pass
407
through steam lines to the turbine. The separated water
will mix with the incoming feedwater within the reactor
vessel and the total flow will be returned to the core inlet
through jet pumps located in the vessel. The motive force
for the jet pumps will be supplied by the water discharged
from two reactor coolant recirculation pumps. Variable
frequeney motor-generator sets supply power to the recir-
culation pump motors.
The design, fabrication, erection, testing, and certifica-
tion of the reactor pressure vessel are discussed in detail
in Amendment No. 13 to the license application (applica-
tion dated December 2, 1966, Docket No, 50-271).
The plant has removable insulation in specified areas
which permit direct inservice inspection of the exterior of
the reactor vessel and other primary system components.
This permits inspection of selected nozzle-to-shell welds,
inspection of reactor vessel studs, nuts and bushings, se-
lected sampling of high eyelie stress vessel welds. and
selected sampling of coolant system piping, pumps, valve
supports, and hangers. Inspection of the interior of the re-
actor vessel can be accomplished under water using re-
motely operable lights and visual aids such as boresecopes
and underwater TV cameras. (FSAR 4.2.6, 4.3.6, 4.4.8,
and Section 4.6 of the Vermont Yankee Technical Speei-
fications. )
3.3 Plant Containment System
The primary containment system, consisting of a steel
light-bulb-shaped drywell, a steel doughnut-shaped pressure
suppression chamber, and interconnecting vent pipes, pro-
vides the first containment barrier surrounding the reactor
vessel and reactor primary system. Any leakage from the
primary containment system is to the secondary contain-
408
ment system which consists of the reactor building, the plant
standby gas treatment system, and the plant main stack.
The integrated plant containment system and its associated
engineered safeguards features is designed so that off-site
doses resulting from postulated design basis accidents are
well below the reference values stated in 10 CFR 100,
3.3.1 Primary Containment System
The primary containment is designed to accomodate the
pressures and temperatures which would result from, or
occur subsequent, to, a failure equivalent to a double-ended,
circunferential rupture of a reactor coolant recirculation
system line within the primary containment resulting in
the loss of reactor water at the maximum rate. The pres-
sure suppression chamber is a steel, torus-shaped pressure
vessel approximately half filled with water, and... .
[USAEC STAFF SAFETY EVALUATION,
VERMONT YANKEE NUCLEAR POWER STATION,
Ex. 9, p. 5, AEC Dkt. No. 50-271)
. connected by vent pipes to the doughnut-shaped
steel water-filled suppression chamber (torus). The reactor
vessel and the recirculation water piping, valves and pumps
are housed in the drywell. The reactor is a direct-cycle,
foreed circulation, boiling water system which produces
steam at 1000 psig. The reactor core uses slightly enriched
uranium dioxide fuel in the form of pellets contained in
Zirealoy tubes. Water, which serves as both the moderator
and coolant, is pumped upward through the core where it
boils due to the heat produced in the core. Two recircula-
tion loops, each with a pump, provide the driving flow. The
resulting steam is supplied to the turbine, which is directly
coupled to the generator. After passing through the tur-
bine, the steam is condensed, partially reheated and re-
turned to the reactor.
409
SITE AND ENVIRONMENT
Site Description
The plant is located near the village of Vernon, Vermont,
slightiy less than four miles north of the Massachusetts
state line. It is on the west bank of the Vernon Pond. The
pond is formed behind the Vernon Hydroelectric Station
dam one-half mile downstream on the Connecticut River.
The west bank of the river forms the boundary between the
states of Vermont and New Hampshire flows in a south-
easterly direction in a narrow, steep-sided valley through
the Pisgah Mountains. The terrain rises steeply from the
valley floor in the vicinity of the plant and reaches the
same elevation as the plant stack at a point 6300 feet from
the plant. The site is bounded on the west by the village
and on the....
410
UNITED STATES OF AMERICA
ATOMIC ENERGY COMMISSION
IN THE MATTER OF
VERMONT YANKEE NUCLEAR Docket
POWER CORPORATION No. 50-271
(VERMONT YANKEE NucLEAR Power STaATIon)
ORDER DETERMINING OBJECTIONS
TO INTERROGATORIES
On April 30, 1971, Intervenor Natural Resources De-
fense Council (NRDC) submitted various interrogatories
to Vermont Yankee Nuclear Power Corporation, the Ap-
plicant herein. Objections to these interrogatories were
filed by the Applicant which emphasized the difference
between interrogatories and motions for production of
documents, as defined in the Federal Rules of Civil Pro-
cedure and as adapted by the Atomic Energy Commission
to its Rules for proceedings. Applicant, after stating its
general objection based upon this difference, then waived a
portion of its objection by agreeing to make requested docu-
mentary material available for inspection and copying by
the Intervenors.
The Atomie Safety and Licensing Board adheres to its
ruling respecting the general objection made by Applicant
to interrogatories submitted by New England Coalition on
Nuclear Pollution in its Order dated May 11, 1971, and
reasons therefor will not be repeated but are incorporated
as fully as though set forth herein.
et
411
Applicant, in addition to a general objection which is
sustained tothe extent of the Order respecting New Eng-
land Coalition on Nuclear Pollution interrogatories, also
made specific objections to two main categories of inter-
rogatories by NRDC which, however, were limited to one
subject respecting the transportation and disposal of high
level nuclear waste materials which will oceur after leay-
ing the plant site. The objection was upon the ground that
off-site activities respecting such waste materials were not
within the issues prescribed by the Commission for this
proceeding.
Upon a consideration of the interrogatories and objec-
tions thereto,
IT IS ORDERED, in accordance with the Atomic Energy
Act, as amended, and the Rules of Practice of the Commis-
sion, that the specific objection made by the Applicant
respecting the transportation and disposal of high level
waste products is sustained upon the ground that such
considerations are not within the issues prescribed by the
Commission for this proceeding, but rather are the sub-
jects for other licensing activities.
ATOMIC SAFETY AND LICENSING BOARD
By Samuei W. Jenscu, Chairman
Issued :
May 11, 1971
Germantown, Maryland
AEC Docket No. 50-271
APPLICANT’s ANSWERS TO
INTERROGATORIES OF
NaTuRAL Resources Derense CouNciL
SERVED ON
Vermont YANKEE NuCLEAR Power CorPoRATION
413
UNITED STATES OF AMERICA
ATOMIC ENERGY COMMISSION
IN THE MATTER OF
VERMONT YANKEE NUCLEAR Docket
POWER CORPORATION No, 50-271
(VERMONT YANKEE NUCLEAR POWER STATION )
AFFIDAVIT OF DONALD E. VANDENBURGH
Now comes Donald E. Vandenburgh, and being on oath,
deposes and says as follows:
1.
That he is a Vice President of Vermont Yankee Nu-
clear Power Corporation.
That attached hereto, are the answers to the inter-
rogatories propounded in the above entitled matter
to Vermont Yankee Nuclear Power Corporation by
Natural Resources Defense Council; and that there
is also attached certain “Supplementary Information
—IV Transportation: High Level Wastes from the
Plant” which should be considered as supplementing
the answers given with respect to Interrogatories
Nos. [V.1-6, [V.(DIS).2, 46.
That in the preparation of these answers, he has con-
sulted with the following individuals with regard to
the questions set forth next to their names below:
Name Numbers
R. M. Grube 1.1-7, V.1-18
R. J. Merlino IT.1-3, TV.1-22
IV(DIS) 1-8
W. P. Johnson IIT.1-9
J. W. Stacey IV(DIS) 9 and 10
414
4. That the answers attached hereto, are true and cor-
rect to the best of his knowledge and belief.
5. That on the advice of council and in view of the rul-
ings of the Board with respect to certain objections
sustained to the interrogatories, no answers are in-
cluded for questions 1.7 and IV.(DIS) 8.
DonaLp E. VanpENBURGH
DonaLtp FE. VanpENBURGH
COMMONWEALTH OF MASSACHUSETTS
Worcester, §.S. June 1, 1971
Then appeared before me, the above subscribed Donald
Kk. Vandenburgh and made oath that he is a Vice President
of Vermont Yankee Nuclear Power Corporation; that he is
authorized to subscribe to the answers of that corporation
to the interrogatories of the Natural Resources Defense
Council; that he has read the foregoing affidavit; and that
the statements set forth therein are true to the best of his
knowledge and belief.
Before me,
ArManpd R. Soucy
Armand R. Soucy — Notary Public
My Commission Expires September 9, 1977.
415
I. BASIC INFORMATION
QUESTION 1.1
How long is it expected that the Vermont Yankee plant
will run before being shut down for fuel reloading and
removal of high level wastes from the reactor core?
ANSWER IL.1
The first evele of plant operation is expected to run for
about 18 months before shutdown for refueling. At the
first shut down, about 4% of the fuel assemblies will be
removed and stored for reinsertion in a later cycle. At the
end of the second cycle of about 12 months, about 409% of
the fuel assemblies will be removed for shipment and re-
processing.
QUESTION 1.2
How often is it expected that refueling and removal of
high level wastes will be necessary?
ANSWER 1.2
For cycles subsequent to the second cycle, it is expected
that shutdowns for refueling and removal of spent fuel
assemblies will occur about every 12 months when about
25-30% of the assemblies will be removed.
QUESTION 1.3
Where will the high level wastes removed from the
reactor core be stored prior to their removal from the plant
site?
y
ANSWER 1.3
After removal from the reactor core, irradiated fuel as-
semblies will be stored in the spent fuel storage pool under
23 feet of water shielding. Spent fuel storage is described
in Section 10.3 of the VY FSAR.
416
QUESTION L4
llow long will the wastes be stored at the site before
they are removed?
ANSWER L4
Spent fuel assemblies are normally stored for a minimum
of 3 to 4 months prior to shipment to a reprocessing plant.
It is not expected they would be stored longer than a year
prior to shipment.
QUESTION 1.5
By what means of transportation will the wastes be taken
away from the plant? Lf this is expected to change during
the lifetime of the plant, describe each means and the period
over which it is expected to be used.
ANSWERS 1.5
The means of spent fuel transportation has not been
selected. VY facilities can accommodate both truck and
rail transportation. Any means of transportation will be
in compliance with government regulations. During the
lifetime of the plant, more than one means of transporta-
tion could be used.
QUESTION 16
lf the wastes are to be reprocessed, at what plant or
plants will this be done? If this is to change over the life
of the plant, specify the periods during which each re-
processing plant or plants is/are to be used.
ANSWER 16
It is planned that all VY spent fuel will be reprocessed.
A plant for reprocessing VY’s spent fuel assemblies has
not been selected. The following reprocessing plants are
now in operation, under construction, or planned for the
417
time period when the first batch of VY spent fuel will need
to be reprocessed.
1. The Nuclear Fuel Services, Inc. plant in operation,
at West Valley, New York.
2. The General Electric Co. plant under construction, at
Morris, Illinois.
3. The Allied-Gulf Nuclear Services plant, under con-
struction, at Barnwell, S.C.
4. The NUMEC Atlantic-Richfield plant, planned to be
located at Leeds, S.C,
Over the life of the VY plant, several different reprocess-
ing plants could be used.
QUESTION 1.7
If the wastes are to be reprocessed at a reprocessing
plant :
a.) Deseribe where the resulting reprocessed waste ma-
terials will be taken from the reprocessing plant. [n-
elude deseription of where reprocessed materials to be
disposed of are to be taken, and where any other
materials are to be taken. If this is expeeted to
change during the life of the plant, give this deserip-
tion for each relevant period.
b.) By what means of transportation will each segment
of the reprocessing wastes be taken to each of these
destinations? If this is to change over the period of
the plant’s life, specify the means during each phase
of the plant’s life.
ce.) Where will the waste products which must be disposed
of be taken? If this is to change during the life of the
plant, describe where the wastes are to be taken dur-
ing each phase of the plant’s life.
418
ANSWER 1.7
We are advised by legal council that in view of the
Board’s findings, no answer is required.
QUESTION. I1.1
Describe in detail the procedures to be used to remove
the radioactive materials from the reactor in order to
allow for refueling, including, but not limited to:
a.) How is the reactor core vessel to be opened and
processed to assure that no radioactivity escapes
from the containment vessel during this process?
b.) What is the chemical and radiological composition of
the materials which will be removed from the core at
that time?
ce.) What toxie chemical compounds will be present in this
process, in what quantities and proportions?
d.) What radioisotopes will be present in the material
removed from the reactor core at this time? List them,
including the quantity expected of each, the propor-
tion of the isotope to the total radioactive isotopes
present, the total amount of radioactivity represented
by each type of isotope (expressed in appropriate
nits), and the half-lives of each isotope.
ANSWER IL1
a.) The reactor is first shut down and cooled down. The
top of the primary containment vessel is removed to
expose the top of the reactor vessel. The bolted head
of the reactor vessel is removed and the area flooded
with about thirty feet of water. All subsequent opera-
tions are carried out under water. Core internals are
removed and stored under water. The spent fuel is
then removed and placed in special underwater storage
racks within the reactor building. New fuel is then
419
installed into the core and the previous steps are re-
versed to place the reactor in operation again.
Under normal conditions and operations, no radio-
activity will escape. The entire refueling area is sur-
rounded by the reactor building which is automatically
isolated should an incident oceur which results in the
release of any radioactive material. Section 14.6.4 of
the FSAR, discusses the postulated radioactive re-
lease in the event of a refueling accident.
b.) Entire sealed fuel assemblies are removed during
refueling. The chemical composition of the fuel is
basically unchanged, that is an oxide, which now con-
tains fission products which are listed in d.) below.
ce.) No processing takes place at Vermont Yankee and no
toxie chemical compounds are present.
d.) Attached are two lists which present the significant
radioisotopes one day after shutdown, which is the
earliest that fuel can possibly be moved. One list is
of fission products and the second is an estimate of
other significant radio-nuclides present in a single
spent fuel assembly. The normal refueling procedure
removes only about 4% of a core during each shut-
down (about 92 assemblies).
aonourt Sie =
BR83
BR84
BR85
BR&7
1129
I31A
131B
1132
1133
1134
1135
1136
KR3M
KR5M
KR85
KR87
KR88
KR89
XEIM
XK3M
XE33
XE5M
XE35
XE37
X38
SES81
SKh3M
SES3
SES4
RBSs
RBs9
RB90
420
VERMONT YANKEE
FISSION PRODUCT INVENTORY
1 Spent Fuel Assembly
1 Day Decay
HALF-LIFE CURIES AFTER
(SEC.) 1 DAY DECAY
0,829K 04 0.158E 02
0.198E 04 0,.278E-08
0.180K 03 0.000E 00
0.563K 02 0,000K 00
0.505E 15 0.433E—02
0.695E 06 0.896E 05
0.695E 06 0.126 05
0.828E 04 0.1351 06
0.755E 05 O.115E 06
0.315E 04 0.895 E-02
0.241E 05 0.197 05
0.840E 02 0.000E 00
0.686 04 0.685E 02
0.158E 05 0.114KE 04
0.3346 09 0.167 04
0.468E 04 0.270E 00
0.100E 05 0.356K 03
0.192E 03 0.000E 00
0.108E 07 0.6441 03
0.198K 06 0.559K 04
0.459 06 0.244E 06
0.935E 03 O.59RE 04
0.326K 05 0.293KE 04
0,234E 03 0.000K 00
O.101K 04 0.689 E-20
O.108K 04 0,134E-19
0.6726 02 0.000E 00
O.150K 04 0.387 K-13
O.119K 038 0.000E 00
0.108E 04 0.401E 03
0.900E 03 0.290E-23
O.161E 03 0.000E 00
0.361 E-05
0.635B-15
0.000E 00
0.000E 00
0.990E-09
0.204E-01
0,290 K-02
0,309 K-01
0.264E-01
0.204K-08
0.451K-02
0.000E 00
0.156K-04
0.260E-03
0.383 E-03
0.617 E-07
0813-04
0,000 00
0147-03
0.127K-02
0.559K-01
0.136102
0.671 E-03
0,000E 00
0.157 6-26
0.307 E-26
0.000E 00
0.886 K-20
0,000E 00
0.916E-04
0.663 E-30
0.000E 00
51
53
NUMBER ISOTOPE
RB91
RB92
SR89
SR9IO
SR91
SR92
SRI
SR94
Y90
Y9IM
Yo
Y92
Y93
Y94
Y95
ZR95
ZR97
NBOM
NB95
NB7M
NB97
MO99
M001
MO02
M005
TCOM
TOOL
TC2A
TC2B
TCOS
RUO3
RUO5
RU06
RUOT
RHSM
RH5M
RHO5
RELO6
RIH07
0.840E
0.800 E
0.441E
0.8841
0,350K
0.972E
0.420K
O.119K
0,.230K
0.300
0.529K
0.129K
0.359E
0.990E
0.630K
0.563K
0.613K
0.3231
0.302K
0.597
0.44418
0.244
0.900K
0.6931
0.1191
0.215K
0.8578
0.498
0.2691
0.597K
0.3445
0.161K
0.315K
0.287
0.341E
0.450K
0.1268
0.300E
O.131E
CURIES AFTER
1 DAY DECAY
0.231 K-25
0.000K 00
OAT9K 06
O.145K 05
0.4056 05
0.430E 03
0.000K 00
0.000K 00
0.1458 05
0.2566 05
0.223K 06
0.743E 04
0.444E 05
0.125K-20
0.000K 00
0.2346 06
0.848E 05
O.457K 04
0.2441
0.8346
0,929K
0.184
ESSS
0.477 K-32
0.000K 00
O75 06
0.502 6-22
0.480K-32
0.781 K-32
0.000E 00
O112K 06
O.883K 03
0.128 05
0,000K 00
O112K 06
0.853E 03
0.227K 05
0.1296 05
O0.169B-15
0.528E-32
0.000E 00
0.409 E-01
0.332 B02
0.926602
0.982K-04
0,.000E 00
0,000 00
0.332 6-02
0.586 6-02
0.511B-01
0.16902
0.101E-01
0.28727
0,000K 00
0.5385K-01
0.193E-01
0.104602
0.558E-01
0.190KE-01
0,.212K-01
0.421K-01
0.558E-30
0.0001 00
0,000E 00
0.401K-01
0.114K-28
0,000E 00
0.178E-—38
0,000K 00
0.257K-01
0.201 K-08
0.292 E-02
0,000K 00
0.257E-01
0.194E-03
0.521 K-02
0,.295E-02
0,388 6-22
91
5)
7
"9
101
102
103
105
107
110
SN27
SN28
SN30
SB27
SB28
SB29
SB30
SB31
SB32
SB33
TE7M
TETA
TE7B
TE9M
TERIA
TE9B
TEIM
TEIA
TEIB
TH32
TE3M
TE33
TEH34
CS37
CS38
CS39
CS40
CS42
BATM
BA39
BA40
BA4I
BA42
LA40
LA41
LA42
LA43
CE41
CE43
422
HALF-LIFE
(SEC.)
O.741E 04
0.341 04
O.156E 03
O.319K 06
0.597TE 03
O.151E 05
0.597E 03
0.138E 04
0.126E 03
0.245E 03
0.907E 07
0.338E 05
O.341E 05
0.285F 07
O.372E 04
0.372E 04
0.103E 06
0.150E 04
0.150E 04
0.280E 06
0.378KE 04
0.120E 03
0.263E 04
0.946E 09
0.192E 04
0.568E 03
0.660E 02
0.597E 02
0.156E 03
0.509K 04
O.110K 07
O.107E 04
0.660E 03
0.144E 06
0.136E 05
0.509E 04
O.114E 04
0.276E 07
O.11SE 06
CURIES AFTER
1 DAY DECAY
0.130E 01
0.340E-03
0.000E 00
0.443E 04
0.111 B-04
0.729E 03
0.15602
0.164E-13
0,000E 00
0.000F 00
0.133E 04
0.380E 04
0.797E 03
0.131KF 05
0.532E 03
0.130E 05
0.954E 04
0.469E-11
0.217E 04
0.131E 06
0.254E-01
0.128E-01
0.359E-04
0.144E 05
0.118E-07
0.000E 00
0.000F 00
0.000F 00
0.135E 05
0.217E 01
0.227E 06
0.189E-18
0.000E 00
0.239E 06
0.316E 04
0.199E 01
0.352E-17
0.228E 06
O.137E 06
0.297 E-06
0.779 E-.0
0.000E 00
0.101 E-02
0.255E-11
0.166 E-03
0.357 E-09
0.376E-20
0.000E 00
0.000E 00
0.304 E-03
0.870 E-03
0.182E-03
0.300 E-02
0.121E-03
0.299E-02
0.218E-02
0.107E-17
0.496 E-03
0.300E-01
0.580E-08
0.293E-08
0.821E-11
0.331 E-02
0.270E-14
0.000E 00
0.000E 00
0.000E 00
0.309 E—02
0.498 E-06
0.520E-01
0.432E-25
0.000E 00
0.547E-01
0.722 E-03
0.456E-06
0.804E-24
0.523E-01
0.314E-01
111 CE44
112 CE45
113 CE46
114 PR43
115 PR44
116 PR45
117 PR46
118 ND47
119 ND49
120 ND51
121 PM47
122 PM49
123 PM51
124 SM51
125 SM53
ISOTOPE
U-235
U-238
Pu-239
Pu-240
Pu-241
423
HALF-LIFE
(SEC.)
0.246E 08
0.180E 0°
0.840E 03
0.120E 07
0.105E 04
0.215E 05
O.144E 04
0.100E 07
O.719E O04
0.900E 03
0.794E 08
0.194E 06
0.100E 06
0.230E 10
0.169E 06
1 DAY DECAY
0.187E 06
0.000E 00
0.121E-25
0.222E 06
0.187E 06
0.937E 04
0.241 E-12
O.787E 05
0.966E O01
0.205 E-24
0.342E 05
0.302E 05
0.913E 04
0.110E 02
0.423E 04
TOTAL = 0.4375E 07
VERMONT YANKEE
Other Significant Radionuclides In
1 Spent Fuel Assembly
HALF LIFE
(Yrs)
7.1 X 10°
4.51 X 10°
2.44 < 10°
6.60 < 10°
1.43 X 10°
RATIO TO
TOTAL
0.427E-01
0.000E 00
0.277 E-32
0.507E-01
0.428 E-01
0.214E-02
0.551 K-19
0.179E-01
0.220 E-05
0.469E-31
0.782 E-02
0.691 E-02
0.208 K-02
0.252 E-05
0.966 E-03
MASS
(Kg)
1.60
185.0
0.84
0.45
0.15
The total activity of these radionuclides is about 2 < 10*
curies.
424
QUESTION 11.2
What impact would the chemical compounds described
above, in the quantities which will be present at the time
of refueling, have on the environment, including human
beings, if they were to escape the containment vessel?
ANSWER II.2
As no chemical compounds are employed, no environ-
mental effects are involved.
QUESTION 11.3
What impact would the radioisotopes present in the
materials removed from the reactor*¢ore vessel have on
the environment, including human beings, if they were to
escape the containment vessel? a.) Include short and long
term effects, specifying the length of time each isotope
would be dangerous to life. b.) Describe how these materials
might be disseminated through the environment — for ex-
ample, could they be disseminated through underground
aquifers at the plant site, or by the Connecticut River, or
by other means?
ANSWER IL3
Any release of these radioisotopes is considered unlikely
since they are contained in sealed fuel tubes and no pro-
cessing of the fuel is to be performed at the site. The only
postulated incident involves the dropping of a fuel as-
sembly while it is being moved from the reactor vessel to
the storage pool. This operation is performed under water
and within the confines of the reactor building. In the event
the fuel assembly were dropped and significantly damaged,
some of the fission product gases contained in the gap
between the fuel pellets and the cladding might escape and
rise to the surface of the storage pool. The analysis of
this incident is presented in Section 14.6 of the FSAR.
425
QUESTION 11.4
What facilities have been built into the plant to prevent
an accident which would disseminate the chemical and/or
radiological materials into the environment.
ANSWER I1.4
As stated in the answer to question II.2, there are no
chemical compounds employed in the nuclear coolant sys-
tem, therefore, none can be released in the event of an
accident.
Section 4+ of the station Final Safety Analysis Report
(FSAR) describes the reactor coolant system in detail.
The reactor vessel and connecting piping systems which
makeup the reactor coolant system provide a_ barrier
against leakage of radiological materials into the primary
containment. The reactor vessel is designed, fabricated, in-
spected and tested in accordance with the ASME Boiler
and Pressure Vessel Code, Section III. Reactor coolant
piping is designed and constructed in accordance with the
USA Standard Code for Pressure Piping, Power Piping,
USAS B 31.1.0, 1967. These codes require large safety
margins between the design pressure for vessels and piping
and the actual pressure where the material would fail.
Other requirements providing assurance of the reactor
coolant system barrier integrity are the quality assurance
and quality control programs employed during construc-
tion. In addition, an inservice inspection program will
affirm continuing integrity of the coolant barrier throughout
the life of the plans.
Section 7.2 of the FSAR describes the reactor protection
system. This system is designed to provide protection
against the onset of conditions that threaten the integrities
of the fuel cladding and the reactor coolant system barrier.
426
The system continuously senses the pertinent reactor para-
meters and will automatically perform its safety function
independent of operator action.
Reactor safety is further assured by operators who are
skilled, highly trained men who must demonstrate their
proficiency to the AEC Division of Reactor Licensing to
qualify for their positions. The operator is trained to
recognize conditions that could conceivably lead to a situa-
tion which would require action by the reactor protection
system and to take action to safely shutdown the reactor.
In short, many considerations are taken into account in
the design, fabrication, construction, testing and operation
of a reactor plant to provide a high degree of certainty that
an accident will not occur.
QUESTION IL5
Assuming that the chemical and/or radiological ma-
terials, or some part thereof, did escape the containment
vessel, what plans exist for preventing further dissemina-
tion of them into the environment?
ANSWER IL5
This response is directed to the radiological aspects of
the question since no chemical compounds are present in
the reactor coolant system.
There are numerous station facilities built for the pur-
pose of preventing dissemination of radiological materials
into the environs in the event of an accident. Detailed de-
scriptions of these facilities and how they function during
accident conditions are a substantial part of the written
work presented in the four volumes of the plant FSAR.
Section 5 of the FSAR describes the primary and sec-
ondary containments and the functions of each to mitigate
427
the effects of an accident. Section 14.6 of the FSAR pre-
sents analyses of various design basis accidents including
responses of the primary and secondary containments to
the design basis accidents where applicable.
Section 6 of the FSAR describes the systems (core
standby cooling systems) which will automatically provide
sufficient cooling to the reactor core in the event of a loss of
coolant accident. Analyses for the various loss of coolant
accidents are also presented in Section 6.
Section 7 of the FSAR describes the instrumentation and
controls used for reactor protection circuitry, primary and
secondary containment isolation circuitry, reactor core iso-
lation cooling systems circuitry as well as other reactor
control systems.
QUESTION I1.6
Under what circumstances is it credible that the chemical
and/or radiological materials described in the above sched-
ule of questions, or any part thereof, could escape from the
containment vessel? Supply any relevant studies upon
which this judgment is based.
ANSWER I1.6
As mentioned previously in answers II.2, I1.4, and IT.5,
no chemical compounds are employed, therefore, the por-
tion of the question pertaining to chemicals is not applic-
able.
Section 14.6 of the FSAR presents detailed analyses of
the credible design basis accidents and the analytical re-
sults in terms of off site doses to the public. A credible
design basis accident is a hypothesized accident the char-
acteristics and consequences of which are utilized in the
design of those systems and components pertinent to the
preservation of radioactive material barriers and the re-
428
striction of radioactive material release from the barriers.
The hypothesized accident is a “worst case” situation
which, even though it is extremely unlikely ever to happen,
is assumed to occur coincident with other highly unlikely
events such as loss of off site electrical power and an earth-
quake. The doses are calculated based upon radiological
materials escaping into the environs. The quantity of
escaping radioactive materials are analytically determined
based on a series of very conservative assumptions (con-
servative in that actual dose rates would likely be much
less than those shown in the analysis).
Section 8 of the FSAR describes emergency electrical
power circuits, components and sources (AC and DC).
Ill. FUEL HANDLING
QUESTION IIl.1
Describe the procedures by which fuel materials received
at the plant gate will be processed and stored, specifying
the accounting and security procedures which will be used
to prevent accidental loss or theft of these materials during
receiving, storage prior to loading, or while the fuel is be-
ing loaded into the reactor.
ANSWER III.1
The following procedure provides the answer to this
question.
1.0 SCOPE
This procedure establishes requirements for the control
of special nuclear material in the facility of Vermont
Yankee Nuclear Power Corporation where such material is
used directly or indirectly in the production of electrical
energy. The materials involved in this facility are uran-
ium and plutonium of various isotopic content. The nuclear
429
material control system involves the establishing of re-
ceipts from the shipper, six internal material balance areas,
and records of shipments to a reprocessor or other licensed
receiver as the means of maintaining control and account-
ability of all leased, or owned special nuclear material, or
special nuclear material owned by others but residing in
the facility of Vermont Yankee.
2.0 DEFINITIONS
2.1 Special Nuclear Material (SNM)
A. 10CFR 70
Special Nuclear Material as defined by 10 CFR
70 is as follows: “(1) Plutonium, Uranium
-233, uranium enriched in the isotope 233, or
in the isotope 235, and any other material
which the Commission, pursuant to the pro-
visions of Section 51 of the act, determines to
be Special Nuclear Material, but does not in-
elude source material, or; (2) any material
artificially enriched by any of the foregoing
but does not include source material.”
B. Nuclear Material Control and Safeguards
System For the purposes of these proceedings
the following shall be considered to be units
of special nuclear material:
1. Fuel Assemblies or separate fuel pins
2. Source Range Monitors (SRM’s)
3. Intermediate Range Monitors (IRM’s)
4. Local Power Range Monitors (LPRM’s)
5. Traversing In-Core Probe Monitors
(TIP’s)
6. Subcritical Training Assembly
2.2
2.3
3.1
430
Material Balance Areas
For the purpose of maintaining control over the
special nuclear material at the reactor site, the
plant shall be divided into the following special
nuclear material balance areas:
A. New Fuel Storage Vault
B. Spent Fuel Storage Pool
C. Reactor
D. Reactor Operating Floor
KE. Warehouse
F. Training Laboratory
Authority and Responsibility
All special nuclear material on site shall be under
control of the Reactor Engineer by direction of
the Plant Superintendent. All reporting to the
Central Accountability Office shall be done through
the Reactor Engineer.
3.0 RECEIPT OF SPECIAL NUCLEAR MATERIAL
Kach receipt of special nuclear material shall be
accompanied by a bill of lading or packing list
which contains a listing of the shipping containers
involved in the shipment as well as a loading sched-
ule for each shipping container. The loading
schedule should show:
(a) The serial number of the shipping container
(b) The serial number of the individual units of
special nuclear material contained in the ship-
ping container.
(c) The type of special nuclear material.
431
3.2 A piece count of shipping containers shall be per-
3.3
formed upon receipt and the serial numbers of the
shipping containers received shall be compared
with those shown on the shipping documents.
Upon removal of the units of special nuclear ma-
terial from the shipping containers, the serial num-
bers of the individual units of special nuclear ma-
terial received shall be compared with those shown
in the shipping documents.
After the unloading of each shipment the Central
Accountability Office shall be notified of the date of
receipt of the special nuclear material and the
serial numbers of the units of special nuclear ma-
terial using a pre-printed form, VY0002.
40 STORAGE OF SPECIAL NUCLEAR MATERIAL
4.1
4.2
4.3
The storage of all receipts of special nuclear ma-
terial shall be in a Material Balance Area. Opera-
tions pertaining thereto shall be restricted to
selected employees named by the Reactor Engineer
and approved by the Plant Superintendent. There
is no personal access to the new fuel vault.
A record shall be maintained of the contents of all
storage locations showing the serial numbers of all
units of special nuclear material received or re-
moved, the dates of such receipts or removals, and
the location of each unit of special nuclear material
in the storage location.
Immediately upon removal of units of special nu-
clear material from their storage locations the
Central Accountability Office shall be notified of
the date of such removal, the serial numbers of the
units of special nuclear material removed, and the
disposition of the removed units,— using pre-
printed forms, VY0003, and VY0004, VY0005 or
V Y0006.
5.0 REACTOR OPERATION
5.1
5.2
5.3
5.4
A unit of special nuclear material is introduced in-
to or removed from the Reactor only during re-
fueling.
The Central Accountability Office shall be promptly
notified of the location of each unit of special nu-
clear material in the Reactor upon its introduction
thereto, using VY0003 and VY0007 or V Y0008 and
of any relocation of units of special nuclear mater-
ial during refueling operations using VY0007 or
VY0008.
A record shall be maintained in the Reactor Con-
trol Room showing the serial numbers of the units
of special nuciear material charged to or removed
from the Reactor, the dates of such charging or
removal, and the location of each unit of special
nuclear material in the Reactor. At the conclusion
of refueling the Central Accountability Office shall
be furnished with a copy of the Core Fuel As-
sembly lay-out plan, VY0007, and in-core instru-
mentation lay-out form VYOOO8.
Immediately upon removal of irradiated units of
special nuclear material from the Reactor, the
Central Accountability Office shall be notified of
the date of such removal, the serial numbers of the
units of special nuclear material removed, and the
disposition of the removed units using preprinted
forms V Y00038 and V Y0009.
433
5.5 A member of the Plant Reactor Engineers staff at
the Vermont Yankee site shall be responsible for
the calculation of Core depletion and plutonium
production. He shall also determine the place-
ment of assemblies in the reactor at the time of
refueling.
At the end of Core life the Central Accountability
Office shall be notified of the depletion of special
nuclear material by units in both total uranium
and Uranium 235, and the plutonium production
the Core has experienced during its residence in
the Reactor, identifying each unit by serial num-
ber. During Core life at the end of each reporting
period, using form AO-1, the Central Accounta-
bility Office shall be notified of the uranium deple-
tion and plutonium production experienced in the
Core during the period to be reported.
6.0 STORAGE OF IRRADIATED SPECIAL
NUCLEAR MATERIAL
6.1
6.2
6.3
The storage of all irradiated units of special nu-
clear material shall be effected in a Spent Fuel
Pool, which will be located in a controlled Access
Area. Access to the area shall be restricted to
selected employees.
The Central Accountability Office shall be notified
of the location of each irradiated unit of special
nuclear material in the Spent Fuel Pool upon its
receipt, and of any subsequent change in location
using forms V Y0003.
A record shall be maintained in the Spent Fuel
Pool area showing the serial numbers of the units
of special nuclear material received at and removed
from the area, the dates of receipt and removal
6.4
434
f rom the Spent Fuel Pool, and the location of each
unit of special nuclear material. The location of
the units of special nuclear material in the Spent
Fuel Pool shall be recorded on VY0009 and a copy
of this form shall be sent to the Ce
7k » Central A .
ability Office, ecount
Immediately upon removal of irradiated units of
special nuclear material from the Spent Fuel Pool
the Central Accountability Office shall be notified
of the date of such removal, the serial numbers ot
the units of special nuclear material removed, and
the disposition of the removed units i
| — using a pre-
printed form VY0010. tien
7.0 SHIPMENT OF SPECIAL NUCLEAR MATERIAL
7.1
7.2
Hach shipment of special nuclear material shall be
accompanied by a bill of lading or packing list
which shows the serial number of the shipping cask
involved and a loading schedule which shows the
serial numbers of the individual units of special
nuclear material contained in the eask.
After the loading of each shipment, the Central
Accountability Office shall be notified of the date of
shipment of special nuclear material, the serial
numbers of the units of special nuclear material
shipped, the serial number of the shipping cask
ea Bo consignee of the shipment using form
8.0 INVENTORY OF SPECIAL NUCLEAR
MATERTAL
8.1
At least semi-annually a complete inventory of all
new, irradiated, or Reactor contained special nu-
clear material shall be taken.
8.2
8.3
8.4
8.5
8.6
435
A physical inventory of new and irradiated units
of special nuclear material shall be taken and their
individual serial numbers recorded. The identity
of units of special nuclear material contained in the
Reactor Core shall be taken from Control Room
records.
The special nuclear material content (isotope and
element) of new units of special nuclear material
shall be assumed to be that represented to be con-
tained in each unit by the fabricator and which
may be subject to inspection verfication.
The Central Accountability Office shall be notified
by the site staff of the depletion of special nuclear
material stated in both total uranium and Uranium
235 and plutonium production. The values so re-
ported shall constitute the special nuclear material
inventory of the Reactor Core.
The special nuclear material content (isotope and
element) of irradiated units of special nuclear mate-
rial shall be assumed to be that as computed and
submitted to the Central Accountability Office as
described in Section 5.6.
The limit of error in determining (or estimating)
the amount of special nuclear material contained
in the units of special nuclear material comprising
the inventory shall be established and the overall
measurement uncertainty for the inventory shall
be determined by propagation of error techniques.
9.0 RECORDS AND REPORTS
91 The Central Accountability Office shall maintain
records of receipts, transfers and shipments of spe-
9.2
9.3
436
cial nuclear materials as defined in Section 2.1B
items 1 and 6 in each material balance area. These
records shall show serial numbers for each unit of
special nuclear material and the weight of con-
tained special nuclear material (element and iso-
tope), the composite limit of error associated with
the determination of the latter, and a reference for
the determination of the limit of error involved
(such as the fuel fabricator’s shipping document
and the Reactor Engineer’s calculated burn-up).
These records shall be organized such that a run-
ning inventory of special nuclear material can be
determined readily from the records.
The Central Accountability Office shall maintain
records of receipts, transfers, and shipments of
special nuclear materials held off-site by other
licensees for Vermont Yankee is financially re-
sponsible for these materials. The Central Ac-
countability Office shall also maintain records of
materials owned by others but residing in the facil-
ity of Vermont Yankee. These records shall show
the same information as set forth in (1), above.
The fabricator of units of special nuclear material
shall provide a special nuclear material transfer
document to the Central Accountability Office for
each shipment of special nuclear material to Ver-
mont Yankee. This transfer document shall con-
tain, or shall have attached thereto, and made a
part thereof, supplementary data sheets showing:
(a) Unit of special nuclear material identification
numbers.
(b) Weight of special nuclear material (element
and isotope) contained in each fuel assembly.
9.4
9.5
437
(c) The measurement uncertainty connected with
the determination of the special nuclear ma-
terial content of the material contained.
Additionally, it is desireable that the fabricator
provide for Vermont Yankee, and Vermont Yankee
will try to obtain the following information from
the fabricator for units of special nuclear material
furnished as fuel assemblies:
1) Fuel rod identification numbers for each fuel
assembly.
2) Weight and lot number of fuel material in
~se each fuel rod.
3) Weight of special nuclear material (element
and isotope) contained in each fuel rod.
4) A correlation between the UQ: pellet lots and
the fuel rod numbers wherein the pellets are
contained, and the results of special nuclear
material analysis of each UQOz pellet lot (ele-
ment and isotope).
The documentation described in Section 3.3 con-
cerning receipts of units of special nuclear material
shall be checked against the special nuclear mate-
rial transfer document provided by the shipping
licensee. Discrepancies shall be investigated and
resolved promptly.
The transfer document and the stated special nu-
clear material content of the units of special nu-
clear material shall be certified by a responsible
member of the shipping licensee’s management
staff. The shipping licensee’s values of the special
nuclear material content units of special nuclear
material shall be entered in the Accountability
Ledger for Vermont Yankee on an individual basis.
458
9.6 Two Control Accounts shall be maintained showing
9.7
9.8
9.9
total amount of special nuclear materials held on
lease or owned. One Control Account shall show
total uranium, Uranium 235, and total dollar valu-
ation of the material leased or owned. The second
Control Account shall show total plutonium total
Plutonium 239 plus Plutonium 241, and dollar val-
uation of the material leased or owned.
The Central Accountability Office shall prepare a
special nuclear material transfer document for
each shipment of special nuclear material. This
transfer document shall have attached thereto, and
made a part thereof, VY0010 supplementary data
showing:
(a) Unit of special nuclear material identification
numbers.
(b) Estimated weight of special nuclear material
(element and isotope) contained in each unit
of special nuclear material as obtained from
burn-up ealeulations described in Section 5.6.
(c) An estimate of the measurement uncertainty
involved in the burn-up calculations.
The values shown on the transfer document for the
special nuclear material content of the units of
special nuclear material shipped shall be entered
in the Accountability Ledger for the Power Re-
actor Facility on an individual shipment basis.
Upon receipt of the reprocessor’s report of meas-
urements of the special nuclear material content of
the irradiated units of special nuclear material
during reprocessing, and approval thereof, the
Accountability Ledger shall be adjusted to reflect
the results of the reprocessor’s measurements.
439
9.10 The Central Accountability Office shall prepare a
material balance for special nuclear materials for
each six month period showing beginning inven-
tory, receipts, shipments, burnup, ending inventory
and the uncertainty connected with each.
QUESTION III1.2
How long does the process of loading and reloading take?
ANSWER IIL.2
Loading and reloading is defined as the time required to
remove designated used fuel from the reactor, relocate par-
tially used fuel to new core positions and install new fuel
into the reactor. The stated times do not include time for
preparation and completion of loading such as reactor
vessel head removal and replacement.
The process for loading and reloading the fuel initially
will require twelve days. On subsequent reloadings after
the plant has been operational, the twelve days will be re-
duced to approximately seven days. This reduction in time
required on the subsequent reloadings is due primarily to
the fact that some work can be accomplished prior to the
refueling. Channeling, for instance, which consists of in-
stalling a fuel assembly into a shroud-like enclosure, is per-
formed on a partial number of fuel assemblies prior to the
actual loading operation.
QUESTION II1.3
Ilow many workers are involved in this process?
ANSWER II1L.3
The total number of workers involved in this process are
twenty-one. This is broken down into seven per shift. The
operation will involve around the clock work consisting of
three shifts.
440
QUESTION IIl.4
What precautions are taken in the selection of personnel
to handle this task to assure that none will steal or lose fuel
materials during receiving, storage, or loading of fuel
materials?
ANSWER III.4
All applicants for plant staffing are screened and inter-
viewed in a manner that would disclose if any person is
mentally disturbed. All applicants meet and are inter-
viewed by a minimum of three plant supervisory staff mem-
bers, who explore applicants background history and pres-
ent and future goals.
J
QUESTION 11.5
What precautions will be taken to assure that no nuclear
material will be removed from the plant grounds by workers
at the plant?
ANSWER IIL.5
A Station Security Program has been established to pro-
vide physical security, protection against impairment of
necessary plant functions, and theft of Company equipment.
A Security Force is established and is responsible to achieve
these goals. The detailed Industrial Security Plan is con-
sidered to be proprietary since divulging its contents to the
public would seriously impair its effectiveness.
The physical size and weight of the fuel is a major factor
in preventing its removal from the plant site. Each as-
sembly is approximately 14.5 feet long, 5.4” x 5.4” square
and weighs approximately 580° pounds. Once fuel has been
irradiated in the reactor, it has to be handled under water
1 This is a typographical error in the original and should read “680”
instead of “580”. See FSAR (Ez. 1) §1.7, Table 1-7-1.
441
or in a heavily shielded cask. Such a cask would weigh
many tons, requiring the use of a large crane to handle it.
QUESTION II1.6
What is the percentage of nuclear fuel material expected
to be lost, stolen, or otherwise unaccounted for at the plant
site over the expected life of the plant, based upon previous
experience of the Atomic Energy Commission?
ANSWER III.6
The percentage of nuclear fuel material expected to be
lost, stolen, or otherwise unaccounted for at the plant site
over the expected life of the plant is zero. Since we are
unable to speak for the Atomic Energy Commission, this
statement is based upon eleven years of operation at the
Yankee Rowe Plant and four years of operation at the
Connecticut Yankee Plant.
QUESTION 111.7
What would be the maximum impact upon the environ-
ment, including persons, should this amount of material
find its way into the environment outside the plant grounds?
ANSWER III.7
Since zero loss of nuclear material is expected, there
would be no impact upon the environment.
QUESTION IIL8
How much of the material expected to become lost, stolen,
or unaccounted for at the plant site during the life of the
plant, is expected to find its way into the environment, based
on the past experience of the Atomic Energy Commission?
ANSWER IIL8
Since none of the material is expected to become lost,
stolen, or unaccounted for at the plant site during the life
442
of the plant, none is expected to find its way into the en-
vironment.
QUESTION I1.9
Supply any relevant studies upon which the judgments
called for above are based.
ANSWER IIL9
The above judgments are based on a total operating ex-
perience of fifteen years. This operating experience consists
of eleven years at the Yankee Nuclear Power Plant in Rowe,
Mass. and four years at the Connecticut Yankee Haddam
Neck Plant. During five of the years at the Yankee Rowe
Plant, per agreement with the U. S. Government, the Plant
was under voluntary inspection performed by the Inter-
national Atomic Energy Agency. The purpose of these
inspections was to verify that no nuclear material had been
lost, stolen, or diverted from the Plant. It should be noted
that the Yankee Rowe Plant was the only nuclear plant
whose management volunteered to submit to such periodic
inspections. The results of these inspections again verified
that no nuclear material was lost, stolen, or unaccounted
for at the Plant site.
Vv. TRANSPORTATION — FUEL FOR THE PLANT
Comment: New fuel shipped to the plant is in the form
of fuel assemblies. The uranium oxide and mixed uranium-
plutonium oxide is in the form of high density, ceramic pel-
lets contained in sealed Zircaloy tubes which together with
other hardware are assembled into fuel assemblies.
1. Q. Describe the package in which fuel will be delivered
to the Vermont Yankee plant. Include information as
to its weight, size, and markings.
443
A. The packages used for delivering fuel must be spe-
cially-designed for the type of fuel assembly and spe-
cially approved by the Atomic Energy Commission
(AEC) and the Department of Transportation (DOT)
prior to their use. A description of the package being
used for Vermont Yankee’s first fuel together with
weight and size information is contained in Exhibit
V-A. The package is marked in compliance with DOT
regulations for shipping purposes as follows:
Consignee’s name and address
y
Shipper’s name and address
e. DOT Special permit number
d. Type of package
e. Transport Group number
f. Fissile Class number
g. Radioactive Material label
h. CG mark (Center of Gravity)
The package(s) to be used for subsequent fuel assem-
blies is unknown; however, it will comply with AEC
and DOT requirements. The radioactivity level at the
surface of the package is approximately 1 mr/hr.
Q. What amount of radioactive fuel material will be
contained in each package? Express this in terms of
mass — e.g. in kilograms — and in terms of its chem-
ical composition and radioactivity (in appropriate
units).
A. The fuel assemblies in each package contain ap-
proximately 440 kilograms of uranium dioxide (387
kilograms of uranium) and will have no more than 0.5
euries of radioactive material.
444
3. Q. What percentage of the fuel to be used at the Ver-
mont Yankee plant over its useful life will be pluton-
ium: Give the information asked for in V.1 and 2
above with respect to this fuel material.
A. It is planned to include in the first fuel used, four
assemblies that are partially fueled with plutonium for
the purpose of obtaining technical data. These assem-
blies are nearly identical in design to all-uranium
assemblies, the major difference being that some of the
sealed rods contain uranium-plutonium mixed oxide
pellets rather than all uranium oxide pellets. The plu-
tonium in these assemblies will comprise about 0.009%
of the combined uranium and plutonium in the initial
fuel loading. At some time in the future it is probable,
after having obtained the required regulatory ap-
provals, that plutonium will be used to replace some of
the uranium in new fuel assemblies. If it is assumed
that all plutonium produced in Vermont Yankee is used
in new fuel as early as possible and is continued to be
used until fast breeder reactors require plutonium for
fuel, the schedule for new fuel insertion and its uran-
ium-plutonium composition might be as follows:
Percentage
Year of Plan lomposition o
@nane tion When . New Fuel .
New Fuel is
Inserted Uranium Plutonium
0 99.991 0.009
1- 4 100 0
5-19 99.3-99.0 0.7-1.0
20-30 100 0
Therefore, it is expected that no appreciable quantity
of plutonium will be used in new fuel until after 45
years of plant operation and that it will then be used
445
for a period of about 15 years. The package to be used
for shipping the four part-plutonium assemblies will
be the same as that used for all-uranium assemblies as
described for Question V.1. The package to be used for
future part-plutonium assemblies is unknown. All
packages and shipments will comply with AEC and
DOT requirements. The mass of material will be about
the same as in V.2, above. The chemical composition
of material in the sealed Zirealoy rods will be a mixture
of uranium dioxide and plutonium dioxide. If future
part-plutonium assemblies are similar in design to the
first four the amount of radioactivity per container is
estimated to be about 18,000 curies. Measurements on
rods making up the first part-plutonium assemblies in-
dicate a gamma activity of only 2 mr at a distance of 2
feet from the rods and 12 mr at a distance of one inch.
@. How many packages of uranium fuel will be deliv-
ered on each truck/train (whichever will be used for
delivery — both if both apply)?
A. The first fuel is being shipped by truck. Each
truckload consists of up to 16 containers, each contain-
ing two fuel assemblies. It is not known whether future
new fuel shipments will be by truck or by rail. Facili-
ties for receiving both types of shipments exists at the
VY plant. It is not known how many containers will,
in the future, be loaded onto each vehicle. However,
all shipments made will be in compliance with AEC and
DOT regulations which specify limits for the number of
containers on a vehicle.
. Q. Where will this fuel be shipped from?
A. All of the first fuel assemblies (710,840 kg uran-
ium) and 2.4 reloads of fuel assemblies (55,440 kg
446
uranium) are shipped from Wilmington, N. C. Since
the manufacturers of subsequent fuel reloads have not
been selected it is not known from what locations such
reloads will be shipped.
. Q. By what route will the fuel travel in order to reach
the Vermont Yankee plant? Give route numbers of
roads which will be used, specifying any cities through
which trucks will pass. If railroad is to be used, spe-
cify cities through which the trains will pass and indi-
cate clearly where these train routes are.
A. The route of first fuel shipments begins by taking
US-421 from Wilmington, N. C. to its junction with
Interstate-95; thence north on Interstate-95 to its june-
tion with US-301 in Richmond, Va. Take US-301
north, bypassing Washington, D. C. to east and cross
Chesapeake Bay via the Annapolis-Queenstown Bridge
to Wilmington, Delaware. Through Wilmington and
across the Delaware River over the Delaware Memorial
Bridge on Interstate-295. Travel 295 to its junction
with US-130. North on US-130 through Camden, N. J.
but bypassing Trenton, N. J. to the junction of US-130
and US-1 and 9. North on US-1 and 9 over the George
Washington Bridge in New York City to its junction
with Interstate-95. East on 95 through Bridgeport,
Conn. to New Haven where connection is made with
Interstate-91. Through New Haven north on Inter-
state-91 through the cities of Hartford, Conn., Spring-
field, Mass. and Brattleboro, Vt. At Brattleboro con-
nect with State Route-142 south to the plant site at
Vernon, Vt.
. Q. What, if any, calculations have been made to de-
termine the chances of an accident involving fuel-
447
carrying vehicles over the life of the plant? If such
calculations have been made, what are the results?
A. The National Safety Council publishes as public
information, yearly statisties of all highway accidents,
including as part of the report, truck accidents involv-
ing hazardous materials. These reports indicate there
are so few nuclear fuel truck accidents each year that
any statistic obtained by this method would not be of
worthwhile significance if we attempted to use it as a
life-of-the-plant vehicular accident probability factor.
Note, however that in the event that an accident did
occur involving nuclear fuel, simulated accident tests
which the fuel containers have successfully withstood
demonstrate that the fuel would remain intact, more-
over even if through some catastrophic event, the fuel
material (UO, pellets) were dispersed, no significant
environmental effect would occur.
. Q. What, if any, tests have been conducted using the
type of containers in which fuel elements are to be
shipped, to determine the conditions under which they
might burst open or otherwise release radioactive ma-
terial?
(a) Have any of these tests been conducted under
actual conditions — involving dropping the container
from a moving truck or train, for example — as Op-
posed to in a laboratory with standard bursting and
puncture tests?
(b) If such tests have been conducted, describe the
tests and the results.
A. The fuel package tests conducted are the water
immersion, fire and 30-foot drop tests. Specifications
and standards are established by the AEC as pre-
10.
448
seribed in LOCFR, Part 71: 31, 32, 34, 35, 36 and Ap-
pendices A & B and for the DOT as prescribed in
49CFR, Part 173:393 & 398. Results for first fuel
packages are documented in Exhibit V-A.
(a) No tests for first fuel packages have been
conducted under actual conditions involving dropping
the containers from a moving truck or train.
(b) See (a).
Y. Describe the methods used to secure the containers
in which fuel elements will be shipped to the Vermont
Yankee plant to the trucks or railroad cars on which
they will be shipped.
A. The method used to secure first fuel containers to
the truck is to pass 3¢” steel link chain up the sides of
the containers, over the top of the container block and
down the other side. Both ends of the chain are
hooked loosely to the trailer stake pockets. A chain
binder is then placed at one side of the chain to pick up
the slack in the chain. The slack is picked up one link
at a time until the chain is so tight that one man using
a length of steel pipe can scarcely close the binder.
Three chains are used on each container or container
block, spaced equi-disiantly from each other along the
length of the containers.
(. Approximately how long will be required to re-
lease the containers from these fasteners? How is this
accomplished ?
A. Releasing the containers is accomplished by open-
ing the chain binders. Normally, this requires very
little time — 15 minutes at most. Subsequent unload-
ing of the containers, however, is not so easily accomp-
11.
12.
13.
449
lished because of their weight (2800 pounds each) and
materials handling equipment is required.
(. How many stops will be made hciween the time the
truck(s) or train(s) leave the original shipping point
and the time they reach the Vermont Yankee plant?
A. All first fuel shipments are by truck. Normally
four to six stops are required by the truck from the
time it leaves Wilmington, N. C. until arrival at the
plant site at Vernon, Vt.
@. What is the value, in dollars, on the present Amer-
ican market of the quantity of fuel to be shipped on
each truck/train?
A. Each full truckload of 16 containers of the first fuel
will carry fuel assemblies valued at $1,800,000. Of this,
the value of the contained uranium is $1,000,000, the
balance of $800,000 being for fabrication of the fuel
assemblies. For the fuel assemblies as such, to have
the full value of $1,800,000 to another party on the
American market the other party would need to have a
reactor nearly identical in design to VY in which to use
them. For the contained uranium to have value to
others, in itself, it wonld be necessary to reprocess the
assemblies to recover the uranium in a usable form.
In addition to destroying the fabrication value, repro-
cessing could only be done at considerable expense
which would effectively reduce the value of the uranium
to others. If the uranium recovery were done in a
reprocessing plant the uranium value would be de-
ereased from $1,000,000 to about $800,000.
Q. What is its value on the international market?
A. On the present international market the situation
would be essentially the same as for the American mar-
14.
15.
450
ket (Question 12) except that the contained uranium
might be slightly less in value.
@. What studies have been made to determine the
likelihood of hijacking or theft of fuel or fuel contain-
ers during transit to the Vermont Yankee plant? Sup-
ply studies and describe their conclusions.
A. Although there have been no specific studies made
to determine the likelihood of hijacking or theft of fuel
during transit to Vermont Yankee, the manufacturer of
the first fuel assemblies has an established fuel moni-
toring system requiring each vehicle transporting fuel
to report its position and other important information
by telephone every six hours during the trip to a re-
sponsible monitoring unit. This frequent telephonic
surveillance of each shipment would quickly alert the
fuel manufacturer to any attempted hijack or theft of
nuclear fuel. Fuel shipments are made by direct sleep-
er truck-trailer service with two drivers and no trans-
fer of equipment or drivers straight through to desti-
nation. The size and weight of the fuel containers
would very likely preclude any theft or hijacking ex-
cept by use of heavy duty special purpose handling
equipment.
Q. What is the present best estimate of the chances
of a hijacking or theft of fuel during shipment to the
Vermont Yankee plant over the estimated life of the
plant, assuming presently planned precautions are
taken?
A. The present best estimate is that the chance of a
hijacking or theft occurring during shipment of Ver-
mont Yankee fuel is remote because of the precautions
taken during shipment, and lack of any illegal use for
16.
17.
18.
451
the material. To the best of our knowledge, there has
never been a theft or hijacking, or an attempt at theft
or hijacking, during the shipment of nuclear fuel as-
semblies.
@. What would be the likely environmental impact,
including impact on persons, of the release of radio-
activity from a shipping container which was stolen or
lost in transit, and later opened?
A. There is absolutely no environmental impact or
effect on living creatures upon contact with or proxim-
itv to intact nuclear fuel assemblies because of their
insignificantly low radiation level.
(). How many containers of plutonium or other fuel
would have to be stolen in order for someone who stole
them to assemble enough material to create a critical
mass?
A. If the fuel assemblies were removed from the con-
tainers and arranged closely in water criticality could
be achieved with assemblies from two containers (that
is 4 assemblies).
(. How many such containers will be shipped to the
Vermont Yankee power plant over its expected useful
life?
A. Assuming the plant will have a useful life of 30°
years it is estimated that 1700 such containers would
be shipped during that period.
1 This is a typographical error in the original and should read “40” in-
stead of “30”.
452
EXHIBIT V-A
Description of Model RA-1] Package Used For
Vermont Yankee’s First Fuel Assemblies
1.0 Package Description — Packaging
(a) General: A right rectanguwar box consisting of a
wooden outer container and a metal inner container
separated by cushioning material.
(b) Gross Weight: 2800 pounds.
(c) Containment Vessel: A metal box consisting of an
outer shell and perforated inner basket separated
by struetural angle iron. Outer shell formed of
16-gange carbon steel plate with an integral welded
end of same material. Four 1%” thick one-inch
angle stiffeners are welded on 4” centers to the
outer surface of the end plate. Approximate di-
mensions 9” high, 18” wide and 174” long.
Inner basket of 16-gauge steel plate with 34” per-
forations on 134” centers welded to upper edge of
outer shell to form two U-shaped channels 67%”
square which may be lined with cemented low-
density cushioning with perforations matching size
and location of those in basket.
Inner basket supported within inner shell by four
1%” thick 3” x 3” angle iron spacers positioned
longitudinally along entire length of body. Cover
and end cap constructed similar to the box to pro-
vide 2” annulus around fuel when closed except at
ends. A manually operable pressure relief valve
passes 2 cfm air automatically at .5 psi pressure
difference. Gasket of 14” thick hollow neoprene
provides full seal with cover in place. Closure
li
453
effected by latches (“Camloe”, 3711 series or equiv-
alent) which are inaccessible during transport.
(ad) Outer Container: Box 33” high, 32” wide and up to
207” long fabricated of 14” plywood, 2 x 4 cleated,
on 2 x 6 tongue and groove platform with bolted
4 x 4 skids.
(e) Internal Cushioning: Three 3” layers of 34” ceil
phenolic resin impregnated kraft fiber honeyeomb
line the box at ends; one layer at top, bottom and
sides. Remaining space at ends filled with ex-
panded polyethylene cushioning. Three-inch-thick,
12” wide pads of same material centered over
transverse skids at sides, top and bottom. No
attached lifting or tiedown devices.
2.0 Package Evaluation
A sample Model RA-1 package was subjected to the
tests or assessments set forth in Subpart C of 10 CFR
71. Results of these tests and assessments were sub-
mitted for the AEC’s review as part of the fuel manu-
facturer’s application for an amendment to its special
nuclear materials license for authorization to use con-
tainer Model RA-1 for shipments of fuel assemblies.
This evaluation data is given below.
2.1 General
There are no components of the packaging or its
contents which are subject to chemical reaction in
normal transportation environment. The package
cannot be opened inadvertently, uses no coolant,
and has no lifting devices or tiedown attachments.
454
2.2 Normal Transport Conditions
(a)
(b)
(c)
(d)
Thermal —None of the components of the
fuel assemblies or the inner metal container
on which containment integrity and nuclear
safety depend are significantly affected by tem-
peratures within the range of —40°F to 130°F.
Pressure — The breather valve opens auto-
matically when the inner container is subjected
to =.5 psi pressure differential. Therefore
there is no effect on the packaging from an en-
vironment of .5 atmosphere.
Vibration— A 6” thick layer of cushioning
material surrounds the inner metal container
at the sides, top and bottom with an additional
3” thickness at the ends. The Ethafoam cush-
ioning is slightly compressed in final closure
and banding of the outer container and is
therefore not free to shift during transport.
Since the latches on the metal container are
pinned they cannot loosen during normal trans-
port vibration or shock even were such vibra-
tion able to penetrate the cushioning material.
Water Spray and Drop Tests — The complete
package is designed to protect the fuel as-
semblies within the inner metal container
from loss of containment integrity or change
in nuclear safety reliability by virtue of the
thick enshioning material surrounding it. The
shock absorbing qualities of this material and
of the heavy wooden cleats at the corners,
edges and at all joints in the plywood, supple-
mented by the inherent resiliency of nails and
(e)
(f)
(g)
455
steel bands used in final closure of the outer
package constitute a more than adequate buf-
fer against the subject tests. This conclusion
is further supported by analysis of high speed
motion pictures recorded during the 30-ft
drop test, described in Section 3.0, in which
the flexibility of the package under impact is
clearly evident.
Penetration — Tests were conducted in which
the flat circular end of a vertical steel cylinder
1144” in diameter weighing 13 lbs. was dropped
four feet onto the center of the 4%” plywood
outer container. No damage resulted after
four drop tests.
Compression — Tests were conducted in which
six loaded packages were stacked. There was
no visible nor measurable damage to the con-
tainer on the bottom of the stack.
Reactivity—In the normally undamaged
condition, fuel assemblies are dry. Con-
sideration was given to the effect of the hydro-
genous outer packaging materials between ad-
jacent metal containers. However, the analysis
of water immersion of an infinite array of
packages without water inside the inner con-
tainer, described in detail in Section 3.1 below,
demonstrates that condition would produce a
more reactive array than the as-shipped con-
dition. Results of conservative calculations of
the as-shipped condition indicate a value for
ko of 0.8. This seemingly high value is par-
tially explained by the degree of moderation of
the packaging material and partially by the
456
conservative approximations, e.g., greater fuel
size and assembly reactivity, than will actually
he shipped. The criticality analysis conclu-
sively demonstrates substantia] subcriticality
under all of the conditions of temperature,
pressure, puncture, impact and exposure to
incidental water during anticipated maximum
potential damaging conditions of normal
transport.
3.0 Accident Evaluation
3.1 Free Drop Test
Height: 30 ft. measured by weighted string
hung from package.
Attitude of Long axis about 25° from vertical.
impact:
Impact surface Top edge of end which has the
of package: clamped end cap on the inner pack-
age. (From a series of drop tests
of an earlier prototype, it was
clearly established that the end
cap and cover edge was the most
vulnerable impact attitude. Previ-
ous drops also included flat on the
cover surface and flat on the bot-
tom.
Surface struck: 18” thick concrete pad. Pad not
damaged by test drop.
Contents: Two simulated fuel assemblies
each fabricated of 34” diameter
steel rods 157” long over a wood
core and welded to typical reactor
Results:
3.2 Puncture Test
457
fuel assembly hardware at both
ends. Dummy dimensions: 6” x 6”
x 174” long; weight 632 lbs. each.
Damage confined to impacted area.
End of outer box separated from
hody exposing inner container but
inner container still in position in
outer container. End cap of inner
container was still latched but gas-
keted surface not in contact with
shell flange along one edge of end
cap. Subsequent immersion would
have permitted water leakage into
inner container. End cap had to
be unlatched and pried off with a
tool in order to permit subsequent
removal of cover and fuel assem-
blies. Two-inch annulus remained
intact except in a 5” long area at
one end of the cover where result-
ing space averaged about one inch ;
an insignificant (1) portion of the
total container surface.
In view of the fact that the inner metal container
remained firmly within the outer packaging and,
since the inner package was properly designed to
remain subcritical with water inleakage such as that
which could result from a puncture, an actual punc-
ture test was not conducted.
3.3 Thermal Test
An actual thermal test was not conducted but the outer
packaging and cushioning material was assumed to
3.4
3.9
458
be completely consumed under thermal test condi-
tions. However, the remaining inner package is con-
structed of noncombustible material and the mini-
mum melting point of the fuel material is 4360°F.
The pressure relief valve permits escape of heated
air from the metal container. Therefore, this device
would prevent rupture of the container even if the
gasket did not melt to allow pressure relief. The
18-gauge steel container is internally braced with
lengthwise angle iron on both sides and bottom; the
cover is similarly braced. Previous tests of an 18-
gauge 55-gallon drum in a jet fuel fire which exceeded
an exposure temperature of 1475°F for more than 30
minutes produced no melting or distortion of the
outer surface. It is therefore concluded that a sim-
ilar thermal test at 1475°F for 30 minutes would
result in no damage to the Model RA-1 container nor
its contents more severe than the assumed condi-
tions considered in the criticality analysis presented
below.
Water Immersion Test
Since the package is designed to remain subcritical
assuming any degree or credible mode of water in-
leakage, it was unnecessary to subject the package
to an immersion test.
Analysis of Damaged Packages
From the above tests and assessments, the damaged
package is assumed to be as follows:
(a) All materials outside of the inner metal con-
tainer have been consumed by fire or otherwise
removed.
459
(b) Package contents (fuel assemblies) remain in-
side the metal container.
(c) Metal container retains an annulus approxi-
mately 2” thick around the fuel assemblies.
(d) The assemblies are of the most reactive type
which could be shipped under the authorization
requested herein, Le., 514” square cross-section,
64 rods of 0.580” diameter clad in 0.020” zir-
conium at 5% U-235 enrichment. The geometric
buckling of a reflected two-assembly container is
0.0188.
(e) The ko value of the assembly defined above is
taken at 1.54. This value is conservative since
the value used for design of fuel storage facili-
ties including storage pools is 1.4; maximum ko
values for presently planned fuel are approxi-
mately 1.3.
Based on the above factors, two cases were analyzed,
namely, the flooded and nonflooded inner package. If
the metal containers were flooded with water and
closely “stacked” in an infinitely-large, three-dimen-
sional array, the calculated ko value would be .954;
a 250 container array would have a calculated ko
value of 0.943. Assuming, more conservatively, the
annulus thickness had in some manner been reduced
over the entire surface of 250 containers from 2 to
1.5 inches, the array would still be subcritical.
In the second case, it was assumed that the metal
containers were submerged in, or sprayed with,
water but did not permit inleakage. Considering
differing degrees of water moderation that could
result from differing degrees of separation between
_ a
460
packages, a maximum k~ value of approximately 0.93
was calculated at the most reactive spacing of about
0.15 inches. The following table indicates values over
the range of analysis:
bebesen anskaieass (Calculated)
0 nm
15 93
50 78
1.00 69
1.50 53
These calculations considered effects of interspersed
moderation between the containers over a sufficiently
wide range of moderation to demonstrate suberiti-
eality under all credible conditions.
Caleulative methods incorporated standard reactor
design techniques utilizing Muft-type slowing down
calculations with heterogeneous corrections to ob-
tain two-group averaged epithermal cross-sections.
Cross-sections averaged over the thermal range were
obtained from solutions of the Wilkins equation com-
bined with a P-3 approximation to the Boltzman
equation. Accuracy of these techniques for systems
of this type has been well demonstrated by reactor
operating experience and other experimental data
for similar systems. These methods are described in
detail in Section 5 of the applications for license filed
under these dockets.
Thus, regardless of whether water were present as
the result of a spray, through immersion, or for any
other reason, the fuel assemblies would remain suh-
critical in any number. This same calculation demon-
461
strates subcriticality also for the “as-shipped” pack-
ages in which the wood and plastic material, either
wet or dry, contributes a certain degree of modera-
tion because of its hydrogen content.
In summary, therefore, an infinite number of pack-
ages, either in the damaged condition or undamaged
but in a water environment, would remain sub-
critical in any arrangement.
EE
462
Supplementary Information
IV TRANSPORTATION:
HIGH LEVEL WASTES FROM THE PLANT
I. Basic Information
Waste material will be in several forms at the Vermont
Yankee plant. The largest source of waste material and
the only source of high level waste material will be the
spent fuel. Water treatment resins are used in various
plant process streams to purify and remove radioactive
constituents from them. The major portion of these ex-
hausted resins are low activity. Oiher smaller quantities of
miscellaneous radioactive wastes consisting of rags, floor
sweepings, worn out equipment and paper will also require
disposal. These items and their disposal will be discussed
individually.
Il. Spent Fuel
A. Description
The majority of all waste materials are contained within
the spent fuel assemblies and are shipped intact to the re-
processor. The physical dimensions of a spent fuel as-
sembly are identical to a new fuel assembly; about 1414
feet long x 5.4 inches square and weigh about 500' pounds.
Over the 30-year lifetime of the plant, about 2600 fuel as-
semblies will be used and require shipment to a reprocessor;
this is equivalent to approximately 3500 cubic feet and
1,300,000? pounds of waste material.
1 This is a typographical error in the original and should read “680”
instead of “500”. See FSAR (Ez. 1) §1.7, Table 1-7-1,
See also supra at A-26.
? This is a typographical error in the original and should read “1,800,000”
instead of “1,300,000.”
463
B. Spent Fuel Shipping Cask
Vermont Yankee intends to let a contract for the ship-
ment of spent fuel and, if possible, to include the reproc-
essing in the same contract. The casks which will be used
to transport the spent fuel are not known at this time so
that only general design features can be discussed. The
cask will be a large steel, lead and possibly depleted
uranium shielded cask. If truck shipment is used, the
cask will weigh in the neighborhood of 30 tons and one cask
per truck will be shipped. A rail cask may weigh upwards
of 100 tons and onlv one would be sent in each train. A
truck cask could hold up to 6-8 spent fuel assemblies, while
a rail cask would hold up to 20 assemblies. The cask will
be designed and built to conform to all applicable regula-
tions of the AEC and DOT in effect at that time. Present
design conditions include the requirement to survive intact
without leakage a 30-foot free fall and a 1475° fire for 30
minutes. Depending upon cask size, between 130-430 ship-
ments may he anticipated over the life of the plant.
Ill. Spent Resins
A. Description
The Powdex resin is utilized at Vermont Yankee for sys-
tem cleanup. The resins are finely divided solid particles
which remove unwanted particulate matter by filtration and
soluble ions by the ion exchange process. Approximately
1500-1800 eubic feet of this resin will be used annually at
Vermont Yankee. All but about 65 feet of this will be
relatively low level, approximately 0.3 curies per cubie foot.
The remaining 65 cubic feet per year will be somewhat
higher in activity and could approach 15 ecuries per cubic
foot. Cobalt is expected to be major radioactive isotope
present in this material when it is shipped. Co-58 is ex-
pected to make up 80-95% of the activity and Co-60 the
remainder. When a resin bed becomes exhausted (usually
chemically and not radioactively), water is added to make
a slurry and it is pumped to the waste disposal area of
the plant where a centrifuge will remove the excess water.
Directly below the centrifuge is the resin shipping cask into
which the resins are piped and remain until the cask is full.
The resins in the cask with the free water removed would
have a consistency quite similar to wet concrete.
B. Cask Description
Vermont Yankee is in the process of entering into a con-
tract for waste disposal service in which the shipping casks
will be supplied and the shipping and disposal handled by
the contractor.
Two shipping casks will be utilized by Vermont Yankee,
one heavily shielded cask of relatively low volume for the
higher activity resins and a larger moderately shielded one
for the lower activity resins.
The first cask consists of 1 inch structural steel shell,
334 inches of lead shielding, and 3% inch steel inner shell.
The inner shell is designed as a pressure vessel to withstand
400 psi, although it is normally unpressurized. The cask
is approximately 514 feet in diameter and 514 feet high and
weighs a total of 45,000 pounds loaded. The total useable
volume for waste is about 70 cubic feet. An additional dis-
posable steel liner is placed within the cask prior to the
resin loading operation.
Loading is accomplished through a small diameter hole
in the center of the inner liner. When the cask is filled, the
inner disposable leak tight liner is sealed with a non-
removable cap prior to shipment. Depending upon the
isotopes present, this cask can safely contain up to 3500
465
curies of waste. It is estimated that one shipment per year
will be made with this cask.
The second cask has all the same design features of the
first cask but is larger in outside dimensions, has about
1 inch of lead shielding, and will accept an inner liner of
about 160 cubic feet capacity. The total loaded weight is also
about 45,000 pounds. The dimensions of this cask are 7 feet
in diameter and 7 feet high. It is designed to safely trans-
port up to 185 curies of low specific activity waste, depend-
ing upon its isotopic makeup. Approximately 7-10 ship-
ments per year will be made with this cask.
(. ‘Transportation
Both of these casks are intended for truck transportation.
One design limitation placed upon them is that the loaded
eask trailer, tie-down devices, tractor and associated equip-
ment will not exceed maximum legal weight limit for over-
the-road transportation. This limit is presently 73,280
pounds. A single cask will be placed in the center of the
trailer and firmly anchored in place. One cask per truck
is all that can be transported.
IV. Miscellaneous Wastes
These wastes will be the normal wastes found around any
machine shop, except they have the potential of being
slightly contaminated with radioactive material. The nor-
mal procedure will be to place these wastes in open-top 55-
gallon drums and sealing them when they are full. Nor-
mally these drums will be of such low activity that the
waste disposal contractor would take them along with one
of the larger casks for disposal. However, the larger
shipping casks described previously are designed to accept
a number of 55-gallon drums, so that shipments of higher
activity drums will be shipped in an adequately shielded
466
container. The annual shipments are subject to variation,
but they should not exceed 50 drums per year.
QUESTION IV.1
How many containers of waste materials, assuming the
use of presently planned containers, will have to be shipped
from the plant to some other location during the useful life
of the plant?
ANSWER IV.1
Vermont Yankee estimates between 370 to 760 containers
will be shipped over the 30-year life-time of the plant. Refer
to Section II.B, III.B and IV of the Supplementary Infor-
mation for the details.
QUESTION IV.2
Assuming present shipping arrangements, how many
shipments of waste containers by truck will have to be made
over the useful life of the plant? How many shipments by
train?
ANSWER IV.2
Rail utilization would mean approximately 130 rail ship-
ments and 570 truck shipments. If only trucks are used, ap-
proximately 760 shipments would be made. Refer to See-
tions II.B, III.B and IV of the Supplementary Information
for details.
QUESTION IV.3
Describe in detail the package in which high level radio-
active wastes will be transported to the reprocessing plant,
or disposal site or both, if both apply. Inelude size, weight,
and markings of the container, and a description of any
systems in the container which will be required because of
467
the chemical and radiological composition of the waste
materials.
ANSWER IV.3
Refer to Sections II B and III B of the supplementary
information.
QUESTION IV.4
What physical state—e.g., solid or liquid—vwill the
waste materials be in when they are transported?
ANSWER IV.4
Refer to Sections II A, III A and IV of the supplemen-
tary information.
QUESTION IV.5
What is the capacity of each container, and, if there is
any difference, how much waste material will normally be
shipped in each container?
ANSWER IV.5
Refer to Sections II B and III B of the supplementary
information.
QUESTION IV.6
How many containers will be shipped on each truck or
train, whichever applies (if both will be used, answer for
both and indicate percentage of containers which will be
shipped each way)?
ANSWER IV.6
Only one cask is sent per shipment, either truck or rail.
The percentage is not known. Refer to Sections II.B and
IIL.C of the Supplementary Information.
QUESTION IV.7
Describe in detail the chemical and radiological compo-
sition of the high level wastes. Include the following, and
whatever else is relevant:
a.) What toxie chemicals will be present in the material
shipped to the reprocessing plant, in what quantities,
and proportions of the total material shipped in the
container?
b.) What radioisotopes will be present in the material?
List, with respect to the major ones:
1. The total mass of each isotope within the con-
tainer ;
2. the proportion of this mass to the total mass of
the material within the container;
3. the total radioactivity (in appropriate units) ac-
counted for by this isotope;
4. the proportion of this radioactivity in the same
units to the total radioactivity within the con-
tainer;
5. the half-lives of each isotope described.
c.) What is the total radioactivity (in appropriate units)
which will be contained in each waste container?
ANSWER IV.7
a.) No toxic chemicals will be shipped with any of the
waste material,
b.) With respect to spent fuel, attached is a table of the
fission product inventory after 90 days decay, which
is the minimum cooling time prior to shipment. The
469
table of significant radionuclides presented in re-
sponse to Question II.1.(d) is also applicable here.
With respect to spent resins, refer to Section IIT.A
of the Supplementary Information for the major
radionuclides. The mass of radionuclides in com-
parison with the total mass is extremely small and
has not been caleulated. The half life of cobalt 60 is
5.3 years and the half life of cobalt 58 is 71.4 days.
Refer to the table of fission product inventory after
90 days decay. This accounts for essentially all of
the activity present in a single fuel assembly. The
heavily shielded resin shipping container is not ex-
pected to contain more than 300 curies of Vermont
Yankee wastes, and the moderately shielded cask is
not expected to contain more than 50 curies of Ver-
mont Yankee wastes.
~~
oe aon onoor WS We
1l
12
BESSESNSRESRSESSEAIAGAES
470
VERMONT YANKEE
FISSION PRODUCT INVENTORY
1 Spent Fuel Assembly
90 Days Decay
HALF-LIFE
(SEC.)
0.829E 04
0.198E 04
0.180E 03
0.563E 02
0.505E 15
0.695E 06
0.695E 06
0.828E 04
0.755E 05
0.315E 04
0.241E 05
0.840E 02
0.686E 04
0.158E 05
0.334E 09
0.468E 04
0.100E 05
0.192E 03
0.103E 07
0.198E 06
0.459E 06
0.935E 03
0.326E 05
0.234E 03
0.101E 04
0.108E 04
0.672E 02
0.150E 04
0.119E 03
0.108E 04
0.900E 03
0.161E 03
CURIES AFTER
90 DAY DECAY
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.433 E-02
0.423E 02
0.659E 01
0.763E-03
0.275 E-25
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.164E 04
0.000E 00
0.000E 00
0.000E 00
0.104E 02
0.161 E-07
0.242E 01
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
RATIO TO
TOTAL
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.485 E-08
0.474E-04
0.738E-05
0.855E-09
0.308E-31
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.184E-02
0.000E 00
0.000E 00
0.000E 00
0.116E-04
0.180E-13
0.271E-05
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
RB91
RB92
SR89
SR90
SR91
SR92
SR93
SR94
Y90
Y91M
Y91
Y92
Y93
Y94
Y95
ZR95
ZR97
NB5M
NB95
NB7M
NB97
M099
MOO01
MO02
M005
TCIM
TCOL1
TC2A
TC2B
TC05
RU03
RU05
RU06
RUO7
RH3M
RH5M
RH05
RH06
471
HALF-LIFE
(SEC.)
0.840E 03
0.800E 02
0.441E 07
0.884E 09
0.350E 05
0.972E 04
0.420E 03
0.119E 03
0.230E 06
0.300E 04
0.529E 07
0.129E 05
0.359E 05
0.990E 03
0.630E 03
0.563E 07
0.613E 05
0.323E 06
0.302E 07
0.597E 02
0.444E 04
0.244K 06
0.900E 03
0.693E 03
0.119E 03
0.215E 05
0.857E 03
0.498E 01
0.269E 03
0.597E 03
0.344E 07
0.161E 05
0.315E 08
0.287E 03
0.341E 04
0.450E 02
0.126E 06
0.300E 02
0.000E
0.909E 05
0.155 E-32
0.186E 04
0.155E 06
0.152E-32
0.170E-32
0.652 E-04
0.000E 00
0.000E 00
0.000E 00
0.626 E-04
0.000E 00
V.000E 00
0.000E 00
0.000E 00
0.239E 05
0.000E 00
0.108E 05
0.000E 00
0.240E 05
0.000E 00
0.983E-14
0.109E 05
0.000E 00
0.000E 00
0.600 K-01
9.162E-01
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.162E-01
0.000E 00
0.916E-01
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.101E 00
0.174E-38
0.209K-02
0.173E 00
0.171E-38
0.190E-38
0.731E-10
0.000E 00
0.000E 00
0.000E 00
0.702E-10
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.268E-01
0.000E 00
0.121E-01
0.000E 00
0.269E-01
0.000E 00
0.110E-19
0.122E-01
RHO07
SN27
SN28
SN30
SB27
SB28
SB29
SB30
SB31
SB32
SB33
TE7M
TE7A
TE7B
TE9M
TE9A
TESB
TEIM
TE1A
TE1B
TE32
TE3M
TE33
TE34
CS37
CS38
CS39
CS40
CS42
BAT™
BA39
BA40
BA41
BA42
LA40
LA41
LA42
LA43
472
HALF-LIFE
(SEC.)
0.131E 04
0.741E 04
0.341E 04
0.156E 03
0.319E 06
0.597E 03
O.151E 05
0.597E 03
0.138E 04
0.126E 03
0.245E 03
0.907E 07
0.338E 05
0.341E 05
0.285E 07
0.372E
0.372E
0.103E
0.150E
0.150E
0.280E
0.378E
0.120E
0.263E
0.946E
0.192E
0.568E
0.660E
0.597E
0.156E
0.509E
0.110E
0.107E
0.660E
0.144E
0.136E
0.509E
0.114E
RSESESESESSRSRSLRLLSEL
&®
CURIES AFTER
90 DAY DECAY
0.000E 00
0.000E 00
0.000E 00
°.000E 00
0.251E-03
C.v00E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.763E 03
0.220E-03
0.443E 03
0.202E 04
0.000E 00
0.202E 04
0.434E-18
0.000E 00
0.989E-19
0.740E-03
0.000E 00
0.000E 00
0.000E 00
0.144E 05
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.134E 05
0.000E 00
0.183E 04
0.000E 00
0.000E 00
0.212E 04
0.000E 00
0.000E 00
0.000E 00
RATIO TO
TOTAL
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.281 E-09
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.855E-03
0.247E-09
0.497E-03
0.227E-02
0.000E 00
0.226E-02
0.487E-24
0.000E 00
0.110E-24
0.830E-09
0.000E 00
0.000E 00
0.000E 00
0.161E-01
0.000E 00
0.000E 00
0.000E 00
0.000E 00
0.151E-01
0.000E 00
0.205E-02
0.000E 00
0.000E 00
0.238E-02
0.000E 00
0.000E 00
0.000E 00
109 CE41
110 CE43
111 CE44
112 CE45
113 CE46
114 PR43
115 PR44
116 PR45
117 PR46
118 ND47
119 ND49
120 ND51
121 PM47
122 PM49
123 PM51
124 SM51
125 SM53
QUESTION IV.8
473
HALF-LIFE
(SEC.)
0.276E 07
0.118E 06
0.246E 08
0.180E 03
0.840E 03
0.120E 07
0.105E 04
0.215E 05
0.144E 04
0.100E 07
O.719E 04
0.900E 03
0.794E 08
0.194E 06
0.100E 06
0.230E 10
0.169E 06
CURIES AFTER
90 DAY DECAY
0.332E 05
0.466E-14
0.150E 06
0.000E 00
0.000E 00
0.289E 04
0.151E 06
0.000E 00
0.000E 00
0.384E 03
0.000E 00
0.000E 00
0.239E 05
0.362E-07
0.965E-19
0.114E 02
0.859E-10
TOTAL = 0.8923E 06
RATIO TO
TOTAL
0.372E-01
0.523 E-20
0.169E 00
0.000E 00
0.000E 00
0.324E-02
0.169E 00
0.000E 00
0.000E 00
0.431 E-03
0.000E 00
0.000E 00
0.369E-01
0.405E-13
0.108E-24
0.128E-04
0.963E-16
What impact would the chemical compounds described
above, in the quantities which will be present in each con-
tainer, have on the environment, including human beings,
if they escaped from the container by accident, sabotage, or
other means?
ANSWER IV.8
Not applicable.
QUESTION IV.9
What impact would the radioactivity described above, in
the quantities which will be present in each container, have
on the environment, including human beings, if ‘hey
escaped from the container by accident, sabotage, or other
means?
474
ANSWER IV.9
It is difficult to envision an act that would permit the
escape of radioactivity from a cask. The casks themselves
are rugged pieces of equipment. Casks must be designed to
withstand a 30-foot free-fall drop onto any unyielding sur-
face and a fire of 1475°F for 30 minutes without loss of
contents. In the case of spent fuel, even if the cask is
breached, the fuel cladding must also fail to have any re-
lease. If this were to occur, the small fraction of iodines,
xenons and kryptons contained in the fuel pellet gap, would
escape to the surroundings. The major constituent of any
postulated release would be krypton-85 and its release
would be far less than the 100 curie limit allowed in the
DOT regulation.* Release of this amount of activity should
result in no measurable impact on this environment. The
activity in the resin shipments is chemically bound to the
resin particles so that release of the resins will not cause
dispersal of the activity. Cleanup of this material might
be tedious but would not be hazardous to the environment.
QUESTION IV.10
Answer the previous two questions with respect to the
quantities of chemicals and radioactivity which will be
present in a typical shipment of waste material — by truck
or train, or both, if both are to be used.
ANSWER IV.10
Refer to the response to Question IV.8 and IV.9 above as
each shipment will consist of only one container (cask).
QUESTION IV.11
By what route or routes will containers of waste mate-
rials be taken from the Vermont Yankee plant to the re-
*Tariff No. 23, Hazardous Materials Regulations of the Department of
Transportation, section 173.389(¢)(1)(ii). [This footnote in original]
475
processing plant or disposal site, whichever applies?
Designate :
a.) The roads which will be used, by route numbers;
b.) The cities through which the containers will pass;
ec.) The number of stops expected and the places where
they are expected to be made;
d.) The train tracks which will be used, if any, specify-
ing clearly where they are.
ANSWER IV.11
Vermont Yankee does not know the travel routes to be
used.
QUESTION IV.12
What, if any, calculations or studies have been done to
determine the chances of an accident involving waste-carry-
ing trucks or trains from the Vermont Yankee plant over
the course of its useful life? If such calculations or studies
have been made, supply them and indicate their conclusions.
ANSWER IV.12
No accident studies have been made for Vermont Y ankee.
QUESTION IV.13
What, if any, studies have been done to learn the chances
that a waste container might burst open in the event of a
collision or accident involving a truck or train transporting
the wastes?
ANSWER IV.13 .
Vermont Yankee knows of no specific studies performed
to evaluate the probability of damage to a shipping con-
tainer in transit.
476
QUESTION IV.14
Have any of these tests been conducted under conditions
approximating actual conditions — involving dropping con-
tainers from moving trucks or trains, for example — as
opposed to testing with standard laboratory bursting and
puncture tests? Supply copies and summarize results.
ANSWER 1V.14
Vermont Yankee knows of no tests being performed with
full-sized containers under real accident conditions.
QUESTION IV.15
What, if any, calculations or studies have been done to
determine the liklihood of attempted sabotage or hijacking
of a truck or train carrying waste from Vermont Yankee
during the useful life of the plant? If such studies have
been done, supply them and indicate their conclusions.
ANSWER IV.15
Vermont Yankee knows of no studies that have been per-
formed in this area.
QUESTION IV.16
Is it possible to obtain a critical mass with any isotope or
isotopes or combination of isotopes and other materials
which will routinely be present in the high level waste ship-
ments being shipped from Vermont Yankee Nuclear plant?
If so, specify all such isotopes and/or combinations of
isotopes and other materials.
ANSWER IV.16
Reactor fuel is used until it no longer is capable of pro-
ducing a critical mass. Once the fuel is removed from the
reactor and allowed to decay for 90 days, it may be possible
to obtain a critical mass with fuel and water at room tem-
477
perature. As mentioned in response to Question V.17, it
would require four fresh fuel assemblies arranged closely
in water to obtain a critical mass; the number of spent as-
semblies to obtain a critical mass is dependent upon burnup.
No calculations have been made, but an estimate would be
at least six spent assemblies closely arranged in water
would be required. The isotopes involved are those of
uranium and plutonium.
QUESTION IV.17
If the answer to any part of Question 16 is yes, how many
containers of high level wastes would be required to obtain
enough material to obtain a critical mass?
ANSWER IV.17
The number of containers (casks) is dependent upon the
size of the container. One large rail cask would contain a
sufficient number of assemblies. The truck cask might con-
tain a sufficient number of spent fuel assemblies, but its
exact size (and hence capacity) is not known at this time.
QUESTION IV.18
If the answer to any part of Question 16 is ves, is a theft
of enough waste material to produce a critical mass a cred-
ible possibility? If the answer is no, explain in detail why
not, including information as to precautions to be taken to
prevent such a theft. Supply studies relied upon.
ANSWER IV.18
No. Vermont Yankee considers that the attendent prob-
lems associated with the handling of spent reactor fuel re-
moves this act from the relm of credibility.
QUESTION IV.19
What is the approximate value, in dollars, in America, of
the radioactive material which will be contained in each con-
478
tainer of high level waste materials? On the international
market?
ANSWER IV.19
As mentioned in previous responses, the number of fuel
assemblies in each shipment is not known at this time, but
is estimated to be between 6 and 20, dependent upon truck
or rail cask utilization. At present, the only radio-isotopes
of value are those of uranium and plutonium, which are
fissile. The spent fuel is considered worthless until re-
processed. The following prices are for the fissile materials
present in one spent assembly after separation but does not
include the cost of reprocessing.
Fissile American International
Element Market Market
Plutonium $7,000 $10,000
Uranium $8,000 <$ 8,000
QUESTION IV.20
What, if any, calculations or studies have been made of
the expected future loss of radioactive material, as a per-
centage of the total transported, over the useful life of the
plant? Supply the study, or studies, and its/their conclu-
sion(s).
ANSWER IV.20
No ealeulations or studies have been made.
QUESTION IV.21
If such ecaleulations have been made, how much of this
“lost” material is expected to be disseminated into the en-
vironment? What is the basis for this estimate, if any?
Supply the relevant study or studies.
ANSWER IV.21 —
Not applicable.
nce oc aa MEP An te TE Airdate
479
QUESTION IV.22
What would be the effect on the environment, including
human beings, of the dissemination of this material into the
environment? Supply relevant studies, if any, and their
conclusions.
ANSWER IV.22
Not applicable.
IV. DISPOSAL OF HIGH LEVEL WASTES
QUESTION IV.(DIS)*.1
Where will high level radioactive wastes from the Ver-
mont Yankee plant be disposed of? If the site or method of
disposal is expected to change during the useful life of the
plant, specify with respect to each expected site or method
and period.
ANSWER IV.(DIS).1
Refer to the response to Question |./ for the spent fuel.
The other wastes will go to a federally licensed disposal
site, which is responsible for ultimate disposal.
QUESTION IV.(DIS).2
What is the total volume and mass of the high level waste
materials to be shipped from the plant over its useful life?
ANSWER IV.(DIS).2
The total volume will be approximately 10,000' cubic feet
and weigh approximately 3,750,000° pounds. Refer to Sec-
Section IV. [This note in original]
*DISPOSAL OF HIGH LEVEL WASTES. [This note in original]
1 This is an error in the original and should read “3,500” instead of
“10,000”. See supra at A-45.
2 This is an error in the original and should read “1,800,000” instead of
“3,750,000”. See supra at A-45.
480
tions I1.A, IIL.A and IV of the Supplementary Information
for details.
QUESTION IV.(DIS):3
What is the total amount of radioactivity (in appropriate
units of radioactivity) with a half-life over 20 years which
will be produced at the plant over its useful life?
ANSWER IV.(DIS).3
Assuming that the reactor core will be replaced an equiv-
alent of 714 times over the 30-year lifetime of the plant, the
following quantities of fission products with the half-lives
greater than 20 years will be produced.
Isotope 30-year Total (Ci)
[-129 1.19 < 10°
Sr-90 4.00 < 10°
Cs-137 3.98 X 10°
Sm-151 3.03 X 10*
In addition to the above, it is estimated that 1.3 = 10°
euries of uranium and plutonium will be present in all the
spent fuel used in this period.
QUESTION IV.(DIS).4
What physical state will these wastes be in when they
are disposed of?
ANSWER IV.(DIS).4
Refer to Supplementary Information sections II and ITI.
QUESTION IV.(DIS).5
If it is intended that at some time during the life of the
Vermont Yankee plant the high level wastes are to be dis-
posed of in solid form, when is it expected that this process
will be in operation?
3
481
ANSWER IV.(DIS).5
Refer to Answer LV.(DIS).4.
QUESTION IV.(DIS).6
lf the wastes are expected to be solidified at some point
during the useful life of the plant?
a.) Describe the process by which the wastes are to be
solidified.
b.) Describe the chemical composition of the solid to be
manufactured.
ce.) Describe the physical properties of the solid to be
manufactured, including, but not limited to, its melt-
ing temperature, rate of expension with temperature,
and resistence to destruction from forces applied to
it gradually and suddenly.
ANSWER IV.(DIS).6
Refer to Answer [V.(DIS).4.
Vermont Yankee does not anticipate changing the state
of the wastes (as described in Supplementary Information
sections II and III) during the useful life of the plant.
QUESTION IV.(DIS).7
If the wastes are to be disposed of in liquid form at some
time during the life of the plant:
a.) Describe the physical, chemical, and radiological
characteristics of the liquid.
b.) Describe the method of disposal (e.g., in tanks, in-
jection into bedrock, etc.) to be used for the material.
ANSWER IV.(DIS).7
As far as Vermont Yankee knows, no high level wastes
are disposed of in liquid form, nor is it proposed for the
482
future. All high level wastes are solids or fixed in some
manner prior to ultimate disposal.
QUESTION IV.(DIS).8
Answer the following questions with respect to disposal
of both liquid and solid form high level wastes if both
methods are to be used during the life of the plant; if both
methods are not to be used, answer with respect only to the
method to be used:
a.) Describe the containers into which the waste matter
is put for disposal. Specify:
1.) the size of the container;
2.) the amount of waste material to be contained in
each container, by weight, volume, and amount
of radioactivity (using appropriate units of
measurement) ;
3.) any shielding for protection from radioactivity
which is built into the container;
4.) any devices or construction designed to control
or dissipate heat from the waste material;
5.) any devices or construction designed to resist
outside or inside pressure on the container;
6.) any devices or construction designed to prevent
the release of the radioactive material to its
immediate environment.
b.) Describe the facilities for storage of the containers
for radioactive wastes.
ce.) Describe the procedures for assuring that no radio-
active wastes from these containers will escape into
the environment at the site of the disposal facility.
d.) At what date in the future is it expected that these
wastes will be harmless to human beings and other
life?
483
e.) At what date in the future is it expected that secur-
ity measures will no longer be needed to prevent
human or other life from being endangered by the
stored wastes?
f.) What studies, if any, have been made to determine
how human and other life will be prevented from
being endangered by these wastes during the period
they are not harmless to life? Supply these studies,
if any, and give their conclusions.
g.) With respect to the foregoing estimates, give esti-
mates of the impact of each of these releases on the
environment, including human life. Describe the
probable route(s) through which such escaping ma-
terials would enter the environment, and through
which they would travel. Supply any relevant
studies upon which any conclusions are based.
h.) What strategies, if any, have been formulated to
recapture any material escaping from the storage
facility? Describe and supply relevant documents.
i.) How, if at all, can the storage facility be repaired
should it become sufficiently impaired to release
radioactive material? Describe and supply relevant
documents.
ANSWER IV.(DIS).8
We are advised by legal council that in view of the
Boards findings, no answer is required.
QUESTION IV.(DIS).9 |
What plans have been made for disposal of the highly
contaminated structures associated with the reactor facility
484
at the end of its useful life? Describe and supply relevant
documents.
ANSWER IV.(DIS).9
No plans have been made.
QUESTION IV.(DIS).10
What plans have been made for preventing damage to
the environment, including human life, from the radioactive
structures remaining on the site of the reactvr at the end
of its useful life? Describe and supply relevant documents.
ANSWER IV.(DIS).10
No plans have been made.
485
UNITED STATES OF AMERICA
ATOMIC ENERGY COMMISSION
IN THE MATTER OF
VERMONT YANKEE NUCLEAR Docket
POWER CORPORATION No. 50-271
(VERMONT YANKEE NUCLEAR POWER SraTION)
ORDER DENYING MOTION OF INTERVENOR
NATURAL RESOURCES DEFENSE COUNCIL, INC.
RESPECTING PREPARATION OF A NEW DETAILED
STATEMENT OF ENVIRONMENTAL CONSIDERATIONS AND
FOR REHEARING OF ORDER ON INTERROGATORIES
At the prehearing conference in this proceeding held on
June 22, 1971, Intervenor Natural Resources Defense
Council, Inc., filed a motion to require the preparation of a
new detailed statement of environmental considerations and
for a rehearing of Atomic Safety and Licensing Board’s
rulings with respect to contested interrogatories. Oral
argument’ was had respecting the motion which appears to
be primarily directed to the environmental impact of nu-
clear waste material transportation, reprocessing and dis-
posal. Movant contends that since a nuclear plant opera-
tion will produce nuclear waste material, the entire sequence
of events following that production of waste material is
within the scope of the issues assigned to the Atomic Safety
and Licensing Board for determination. Movant contends
that the National Environmental Policy Act (NEPA) re-
quires that this issue be included in this proceeding and that
1 Later, and on July 7, 1971, a brief by New England Coalition on Nu-
clear Pollution was filed in further support of the motion,
486
the detailed environmental statement, required by that Act,
reflect these considerations.
At the oral argument, the Board noted that separate
licensing procedures are prescribed by the Commission for
the consideration of authority to undertake nuclear waste
material transportation as well as separate procedures for
reprocessing and disposal. The separate procedures imply
different issues than would be pertinent for nuclear power
plant operation.
The seope and effect of an environmental statement re-
quired by NEPA in relation to procedures provided by the
Atomic Energy Commission, particularly Appendix D to
10 CFR Part 50 of the Commission’s Regulations, are under
consideration in the United States Court of Appeals, Dis-
trict of Columbia Cireuit Jn the Matter of Calvert Cliffs Co-
ordinating Committee v. Atomic Energy Commission (Case
24,871). This Atomic Safety and Licensing Board believes
that it would not be in harmony with the quasi-judicial sys-
tem to render a ruling granting the motion here involved
while that Court decisional activity is underway. (See
California v. Federal Power Commission, 369 U. S. 482
(1961).)
Insofar as the motion herein seeks a reconsideration of
Board rulings concerning “certain interrogatories” to which
objections were sustained by Order of the Board on May
11, 1971, it is the opinion of the Board that no additional
facts have been asserted nor any different law advocated to
warrant any different ruling than as shown in the Order
of May 11, 1971, nor has adequate basis been shown to
justify a certification of this motion to the Commission or
to the Atomie Safety and Licensing Appeal Board.
WHEREFORE, in accordance with the Atomie Energy
Act, as amended, and the Rules of Practice of the Commis-
2 be) vp whee thas ~~ N
‘ —_ — se.
487
sion, IT IS ORDERED that the aforesaid motion of Na-
tural Resources Defense Council, Inc. be and it is denied.
ATOMIC SAFETY AND
LICENSING BOARD
By Samus. W. Jenscu, Chairman
Issued :
July 20, 1971
Germantown, Maryland
[2010] 488
UNITED STATES OF AMERICA
ATOMIC ENERGY COMMISSION
IN THE MATTER OF:
VERMONT YANKEE NUCLEAR Docket
POWER CORPORATION No. 50-271
(Vermont YANKEE Nuciear STATION)
Vermont National Guard Armory
Brattleboro, Vermont
Thursday, October 21, 1971
Hearing in the above-entitled matter was reconvened,
pursuant to adjournment, at 9:00 a.m.
BEFORE:
Samvue. W. Jenscu, Esq., Chairman,
Atomic Safety and Licensing Board.
Dr. Davin Hatt, Member.
Dr. Ina ZantTMan, Member.
APPEARANCES:
(As heretofore noted.)
[2149]
low power consideration includes environmental matters, in
fact they receive serious consideration. So we do have a lot
involved besides the mechanics and the hardware for No-
vember 29 for low power testing.
If other attorneys are prepared and ready, and will so
indicate to Applicant, we can have the necessary witnesses
here and the other attorneys can go forward. But I think
all attorneys should be prepared to use the week in what-
489
ever order is convenient to the attorneys. Because the
Board finds it somewhat inconvenient to have fragmented
hearings, but this is the best we can do.
Mr. Ayres, were you going to say something?
MR AYRES: Yes, I just wanted to ask one further
question.
We have had so far no mention of the pending motion
on waste disposal and transportation issue. I didn’t know
whether you wanted to bring that up. Basically I wanted
to ask whether we could expect some kind of resolution of
that between now and say the next session, so that we could
prepare for the environmental session.
CHAIRMAN JENSCH: Let’s give some consideration
to that right now.
Ilave you received the so-called September letter from
the Director of Regulation, which had included in the trans-
mittal as I believe we discussed before, the unauthored, un-
dated, and [2150] unsigned and without any reference to
the Atomic Energy Commission, a statement that indicated
the scope of matters for environmental statements?
In that transmittal it indicated that, as I understand Staff
counsel the other day, that that does represent a Commis-
sion action. I wonder whether the Commission action has
not thereby disposed of your motion as to which you may
have objection and may want to preserve some record re-
garding it.
MR. AYRES: Mr. Chairman, maybe I am not clear on
what you are saying, but we did submit an argument as a
response to that, to the memo from the Staff, which included
that September 1 unauthored memo. And it was our con-
tention there that that was probably no sort of expression of
490
the Commission intention which should be given any cred-
ence, that it was made out well before the time when Ap-
pendix D was finally promulgated.
Given it was the impression of at least one of the groups
that responded, namely, Vermont, that the Commission
later expressed a different policy in a similarly informal
way and given that in all of the formal expressions of posi-
tion in Appendix D, the Commission appears to accept the
position more like ours.
Now perhaps I am confused about what you are saying. ”
Am I construing what you say as a ruling or not?
[2151]
CHAIRMAN JENSCH: No, I was inquiring for your
discussion really. I wondered whether this item that was
transmitted — it is dated September 1 — didn’t dispose of
the motion. I take it that it is your position that it does
not because you say something transpired when Appendix
D was issued on September 3, 1971 or was it September 9?
MR. AYRES: My position is that Appendix D is ineon-
sistent with that letter. It seems also to me that that letter
in itself is rendered less reliable by the counter-questions
suggested by the State of Vermont, for example, in its
response.
What I am saying is that what is at stake here is simply
a question of authority.
Is it Appendix D that controls or some sort of very un-
clear, as to its legal status, memo, which was written before
the Commission had come to a final conclusion, presumably
therefore before the Commission had completely considered
the question of what should be covered?
CHAIRMAN JENSCH: Can you refer to the partieu-
lar part of the Appendix D to which you say overruled or
491
presents a different view than the September 1 memoranda
included in Harold Price’s letter of September 3?
MR AYRES: Appendix D, in Section 1 I believe or See-
tion A, quotes essentially the language of the National En-
vironmental Policy Act.
[2152]
Yes, it is Section A, paragraphs la and be for ex@mple, in
Appendix D.
[2153]
CHAIRMAN JENSCIHL: Will you read that, please, for
the record?
MR. AYRES: I don’t have it hefore me. Just a moment.
Well, it says it is a diseussion of what either the supple-
mental or original envirenmental impact statement should
inelude, pursuant te Appesdix D.
And it deseribes, under section A-1, paragraph (a) what
should go into — as one of the elements of what should go
into that, the environmente! impact of the proposed aetion,
and paragraph (b) says “Any adverse environmental ef-
fects which cannot be avoided should the propesal be im-
plemented.”
Now, standing on its own, their own, neither of those
might be considered clear, except for the fact that in both
areas what is described is either “any” adverse effects or
“all” of the environmental impact.
I think the meaning of those phrases is a lot clearer by
virtue of Calvert Cliffs. It seems to me Appenu:x D is a
response to the Calvert Cliffs, and that this language is no
more than restating what the court said when it said that
environmental impact statement should include “any and
all” adverse effects.
492
It has been our contention all along and it remains so
that the issues we would like to present to the Board are
included within the meaning of any and all adverse effects.
CHAIRMAN JENSCH: I think one of the problems that
[2154]
the Board has discussed in reference to that matter is what
is the nuclear reprocessing plant that would be pertinent
to this proceeding, assuming we gave consideration to that
phase of the transportation?
MR. AYRES: Mr. Chairman, I think that is one question
that has to be answered. We have no description so far
of which one that might be.
CHAIRMAN JENSCH: Well, I think —
MR. AYRES: For all I know, it may be the problems
are very common, that the dangers involved to the environ-
ment in the reprocessing at one plant or another are swnilar
enough so that the Board can evaluate them ‘rom knowing
basically what dangers are involved im amy reprocessing of
this sort of material, as it is presently expected to be done.
CHAIRMAN JENSCH It has been my understanding
that there were several reprocessing sites within New York,
Georgia, the State of Washington — I don’t know what the
status is with reference to the State of Kansas.
And in order to have something certain for meteorologi-
cal considerations 1 presume we would have to, under your
theory, consider all of those five locations and then maybe
they wouldn’t ship it there anyway.
MR. AYRES: Mr. Chairman, I think the Applicant
could probably reduce the number of locations which might
have to be considered. I might point out also that even
within [2155] memorandum from the AEC that we were
discussing a moment ago the Applicant’s environmental re-
493
port is required to describe the environmental effects from
transportation of fuel elements from the fuel fabrication
plant to the reactor, as well as the transportation of spent
fuel elements from the reactor to the fuel reprocessing plant.
CHAIRMAN JENSCH: Yes.
[2156]
MR. AYRES: Now, if that description is required in
the environmental report, even under this memorandum,
then presumably the Applicant is going to have to tell us at
any rate where that material is going to go.
CHAIRMAN JENSCII: Unless the transportation to
any fuel reprocessing plant is the same as it would be to
any other reprocessing plant, so that the problems are in
common amd alike, he may not be able to identify it, or se-
lect it — I den’t know if they have selected the site or not.
MR. AYRES: Swppose one of the reprocessing sites
was in Wyoming, and the ether one was in South Carolina
or New York. Presumahily, the dangers imvolved are dif-
ferent, if only in qwantity, merely by virtue of the greater
distanee involved.
Now, it may well be that the problems in reprocessing
are more similar, even to each other, no matter whieh plant
does the job, than the problems of transportation.
| think what the Commission has done, even in this
memorandum, is to say they want the location and they
want a deseription of the problems associated with it. And
the same kind of reasoning would apply if vou were talking
about reprocessing plants, it seems to me.
DR. HALL: Does the Applicant have any knowledge
about where the reprocessing plant is going to send this?
MR. AYRES: I have asked that question on [2157] in-
terrogatories.
494
DR. HALL: Did you get an answer?
wR. AYRES. I received an answer, a choice of several,
but it seems to me that maybe that question is one which
the Applicamt ought properly to answer.
DR. HALL: Yow have asked it, and you have gotten
an answer to the interrogatory. Was it not specific?
MR. AYRES: No, it wasn’t specific.
DR. HALL: My question is, do you have reason to be-
lieve the Applicant knows definitely that one particular site
will be the recipient of the fuel processing plant’s ship-
ments?
MR. AYRES: No, [| don’t have reason to believe one
way or the other at this point.
DR. HALL: Do you have any notion that in the future
the Applicant will always be using the same fuel processor
fuel reprocessor?
MR. AYRES: I don’t know.
DR. HALL: May they not change from one to another,
depending on the best contract terms available to them?
MR. AYRES: In that case, maybe what is involved is
a description of the dangers in more than one place. It
seems to me at least —
DR. HALL: So we go back to what the Chairman said,
we have to look at the whole country, the future plans of all
[2158] parts of the country. Is that right?
MR. AYRES: I don’t know. That depends on what the
Applicant tells us about what his plans are. That is at
least one answer. The other is this —
DR. HALL: The thing that keeps getting me is I am
sure the Applicant — I guess I could ask him — but I doubt
495
the Applicant has any plans beyond the fuel processing.
They want to get rid of the fuel element and buy new ones.
But once he seils the fuel elements to the reprocessor, he
loses control.
MR. AYRES: That may well be true. But it seems to
me the fact that the Applicant himself would like not to be
concerned with that question does not mean that it is not a
relevant question to be asked before this Board when deal-
ing with the environmental impact of the plant. It may be
that the information sought will have to come partly from
the Applicant and partly from the Commission.
DR. HALL: I think the Commission doesn’t know this,
either. They have licensing procedures for processing
plants. It seems to me analogous to the fact that I put my
garbage can on the street and | pay somebody to come along
once a week to haul this material off. And this is basically
the thing, that I deal with the vendor and the disposal man
has to get a license from my community on where he takes
the garbage. If somebody asked me, | wouldn’t know where
it went.
[2159]
MR. AYRES: I think that is a very accurate descrip-
tion or parallel case. In both cases, it seems to me the same
thing applies. That is, if someone was asked, if this Board
or some other Board were asked to describe and consider
the environmental impact of your garbage or the operation
of your household, put it that way, although you might say
to them, “I put out my garbage and someone takes it away,”
that Board, it seems to me, would be required to look at
where the garbage went.
DR. HALL: But then you have to get the garbageman
in, which, in this case, is the frel reprocessor.
MR. AYRES: It is also true that the garbageman has
to get a license from the Atomic Energy Commission. We
496
are not dealing with the numbers of factors that we would
be dealing with in that situation. Even in planning, [
gather there are not a great number of disposal sites.
DR. HALL: But we are considering the license for this
reactor from now for 40 years, which is the economic life
of the plant, at least | assume that, and it seems to me you
are asking us to crystal gaze into the future as to what will
be the situation at that time.
MR. AYRES: I think to some extent the National
Environmental Policy Act does ask you to do that, although
I think it certainly is willing to make some compromise on
practicality. It seems to me the Board’s duty would be
[2160] . .
probably to look at as clear a picture as it can get now 0
what is expected to be done with these wastes.
DR. HALL: In spite of what Justice Wright wrote, it
seems impossible to look in the future and if you ask me,
we just have to extrapolate.
MR. AYRES: Dr. Hall, we are extrapolating a lot of
factors in this proceeding. It seems to me you may be
forced to extrapolate and do the best you can.
DR. HALL: Extrapolation of those things which are
extrapolatable is proper, but to say where is not. The
amount, yes, the total volumes, yes, I think that can be fore-
cast, assuning power growth.
MR. AYRES: Can’t we also forecast, though, the gen-
eral type of reprocessing mechanisms that are expected to
be used now, general type of disposal process that is ex-
pected to be used now?
DR. HALL: I would not want to.
CHAIRMAN JENSCH: Did you receive a copy of a
letter from Dr. Wilson, who has given a limited appearance
497
statement in the proceeding and who later sent in a letter in
reference to this waste disposal matter? I think there was
intended to be general distribution by the public proceed-
ings branch of this letter.
DR. HALL: It was ineluded in the transcript.
MR. AYRES: Yes, I have seen it.
[2161]
CHAIRMAN JENSCH: The letter to which I refer is
that wherein Dr. Wilson said, well, if there is anybody in
the United States that doesn’t want a reprocessed waste
disposal location, that there were several places in England
that | think he said would be interested in, places where
they would be interested in having that. 1 wonder if we
assumed that for a moment, that there were not any more
places authorized for disposal in the United States, is it
your thought we would go to England?
MR. AYRES: I don’t know why you would have to £0
to England.
CHAIRMAN JENSCH: England or Canada.
MR. AYRES: I am not asking we go to Kansas, either.
CHAIRMAN JENSCH: Would you feel happier if you
had an assurance that there would be a public hearing at
the licensing proceeding for a waste disposal plant?
[2162]
MR. AYRES: No, Mr. Chairman, | wouldn’t, and the
reason is quite simple. What we are asking is that this
plant be examined along with the other reactors that are
being built now from the point of view of what it means as
a complete system for producing power to the ecology and
to possible future generations of human beings.
Now if we were to go to a hearing in Lyons, Kansas, or
some other place in Kansas, or wherever it was, on the dis-
498
posal site, we would be able to examine there on the impact,
environmental impact of that site.
dut even if at the end of the hearing, the Licensing Board
involved said well, this isn’t the place to put it, it would
not be empowered to say all right, vou better shut down
Vermont Yankee and all of the other plants, because we
haven’t got any place to put this waste, and we don’t think
it is a safe thing to put away.
In short what I said is the only Board that has an ability
to judge this system as a whole is the one that is looking at
this plant, which will produce the waste and therefore the
Board which has the power to decide whether these wastes
will be produced.
CHAIRMAN JENSCH: Isn’t it something in the tech-
nical specifications that there can be only a certain amount
of radioactivity stored on the site, which would automati-
cally mean if there weren’t some outlet for disposal, you
would have [2163] to make some adjustments, so that they
can’t store in excess of a certain amount, they would have to
ship it somewhere or stop? It isn’t a question of whether a
licensing board on reprocessing or waste disposal location
would do about that, it would automatically apply to any
plant.
But I thought you indicated, and I thought that is where
wou were going to start vour development, that there is
probably some limit on practcality. I think that really is
the test.
I think the Staff used a little different language, but to
the same effect. They said it gets so remote. For instance,
let me ask you your view on this: Assuming a burst re-
lease of some radioactivity from the plant in the course of
normal operations. That burst has measurements made
499
regarding the level of radioactivity, they trace it out to a
certain point, and they get to a point where, with all of the
best evidence that is known, there is no exposure, no dam-
age, no injury to any person or being or property or con-
tamination of any foods and so on.
As to that, that is kind of the end line of any possible
danger or concern. But there is still some radioactivity, it
may be very minute.
Now doesn’t that kind of a limit likewise apply here?
There is a limit to where your interest goes, where you have
to stop and let somebody else pick up the concern. For
instance, [2164] it seems to me if I read this September 1
item, in the September 3 letter of Harold Price, they are
trying to fix a limit of practicality. And they are saying
you can have inquiry to the fullest extent about transporta-
tion, from the fuel fabricator to the reactor and from the
reactor to a processing site of the spent fuel, or rather the
package of radioactive waste to a waste disposal area. But
they are trying to, within the realm of something that is
reasonable, say, well, that is the extent of the control by the
Applicant.
It seems to me that the responsibility for any activity
depends on control . Once there is a loss of control, there is
no fixation of responsibility.
MR. AYRES: I think we —
CHAIRMAN JENSCH: I think you ean conceive of
minute effects from radioactive bursts, a cloud going off to
the moon. Maybe it will go that far, if it has anything in
there that has a half life, I don’t know how long it takes to
get to the moon, but suppose it goes up to the moon.
Are we going to go up to the moon and find out, are we
going to trace radioactivity to the moon?
5)
MR. AYRES: I think we are talking about two different
kinds of practicality. One of them is what I think the Staff
was talking about when it used the notion of proximity.
And what I think you were talking about when you de-
scribed the situation where a burst of radioactivity goes out
and we lose [2165] track of it, because we can no longer
measure it, it becomes so small, At that point in both cases
I think you do indeed consider it impractical to follow that
effect any further. The reason is because it has become neg-
ligible. But that is not the same sort of situation that we
are speaking of here. What we are speaking of here is a
situation where there is nothing in the slightest bit remote
about the likelihood that something is going to occur, name-
ly, that the wastes will be taken to a reprocessing plant or a
disposal site. We know all that, it is not remote in that
sense.
CHAIRMAN JENSCH: But the control is gone.
MR. AYRES: That is true. The control is gone,
That is true. The control of the Applicant is indeed
gone, but the control of the Board in passing judgment on
the proprietary of granting an operating license is a dif-
ferent matter all together.
CHAIRMAN JENSCH: It must be related to the con-
trol that we can find this Applicant has over an activity that
is sought to be licensed to be effective.
MR. AYRES: There is control in the starkest sense,
you have it in the sense that you can decide to either license
this plant or not to license ti » plant.
CHAIRMAN JENSCH: Is it your thought that we
could issue an order to the Applicant and say now when
you send this spent fuel to the waste processing plant at
West Valley, New [2166] York, that when it comes out of
501
there, you have to ship it to England? You better tell that
West Valley, New York crowd that the Yankee stuff has got
to go to England, we are certainly going to ship it back on
the, whatever, what was the ship that came over a while
ago with teat?
MR. AYRES: No, [ don’t think that is what I had in
mind, What [ have in mind is the only decision which is
before you at the moment, which is whether or not to grant
an operating license to this plant.
What I am asking is for the Board to consider, among
the issues that it considers on that question, one issue, which
is quite different from asking the Board to decide sub-
issues like shall it require sending things to England,
[2167]
CHAIRMAN JENSCH: Well, the Board has consid-
ered this on several occasions, not only from the brief dis-
cussions which have been held and the briefs, which I might
say we thank the parties for their briefing, I think the brief-
ing on this subject has been very good.
I think it is a subject, that until this letter of September
3, which transmitted the item of September 1, was very
clear. The Board is inclined to accept the September 1
transmittal, as sent with the September 3 letter, as repre-
senting the Commission action,
Now, even that might be open to some question, since it
does not bear the imprints of an official Atomie Energy
Commission document. I think the parties are entitled to
that kind of an issuance,
MR. ROISMAN: Mr. Chairman, I wonder if I might
speak to the subject for a moment?
CHAIRMAN JENSCH: Yes.
MR. ROISMAN: To begin with, the statement attached
to the September 3 letter, this statement at its very best,
502
assuming it was promulgated under a regulation number
and so forth, and we didn’t have the procedural difficulties
that I share with the Board, is as stated in the title, “A
Statement of the Seope of the Applicant’s Environmental
Report with Respect to Transportation Lines and Acci-
dents.”
Now, I don’t see anything in that document which [2168]
says that the jurisdiction of this Board is narrowed in terms
of the issues that it should cover. In fact it seems fairly
logical to me. WU
The Applicant can’t tell us the kind of information that
needs to be known about the radioactivity releases at the
reprocessing plants or the radioactivity releases at the
waste disposal plant. The only thing that tells us what
are the issues that this Board can consider is what is in
Appendix D as it is written, or if there were a fuller de-
scription, which there is not, of exactly what the detailed
environmental statement should have, which would be state-
ment of what the Staff should consider in the proceeding.
What is in Appendix D seems to me to completely under-
eut the suggestions, and I couldn’t agree more with the
statement that was made by Mr. Ayres, that a quesation
involving the disposal of radioactivity is properly here,
despite the fact that the Commission does license reproces-
sing plants, and will at some time and has in some cases
already licensed high level waste disposal sites.
In Appendix D, and I have the copy that was not in the
Federal Register, but the one that was issued by the Com-
mission in part A, paragraph eight, near the end of the
paragraph, there is a discussion of what are the obligations
with regard to radiological safety matters, which is what
503
we are talking about here. It says “While satisfying AEC
standards [2169] and criteria pertaining to radiological
effects will be necessary to meet the licensing requirements
of the Atomie Energy Commission act, the cost-benefit anal-
ysis will, for the purposes of National Environmental Poli-
cies Act, consider the radiological effects together with the
thermal effects and the other environmental effects of the
facility.”
I don’t know of any other interpretation that can be
placed on that sentence than to be saying that the fact that
the wastes from this plant go first to a licensed reprocessing
plant, and then a licensed disposal plant does not mean that
the Board should not consider at this hearing the impact
on the environment.
Now, let me be clear what I mean when I say impact on
the environment, or in this case, the radiological effect of
the waste disposal, taking the words from the Appendix D.
We know the site where the reprocessing or the fuel dis-
posal is going to be or we don’t. Let’s take the case where
we know where it is going to go. If we know where it is
going to go, then we know what the impact on the environ-
ment is going to be of the additional waste produced by this
plant. We know that this plant is going to add so many
curies in the fuel, because we have estimates of how many
curies will be in the fuel, to the reprocessing cycle and the
reprocessing plant, we know how much that plant is de-
signed to release, under design basis conditions, all parts
of its licensing procedure and we [2170] can have in this
record, in relatively simple form, easy statement of when
you add another ten pounds or however these things are
computed, of this radioactivity waste, how much release do
you get. Now, that effect is not remote. That is not like
504
your example of sending a little tiny bit of radioactivity to
the moon. We are talking about some radioactive materials
that have lived for hundreds or thousands of years —
[2171]
CHAIRMAN JENSCH: May | interrupt.? That is just
where | wanted to ask if you would expand on that. Is it
your thought that we get into the effect of whatever these
high level wastes are if they have a half life of a thousand
years; are we going to speculate on the environmental im-
pact of the thousand year half life isotope? And what
would be the nature of society by that time?
You would think that somebody somewhere would have
to draw a line. I don’t know what is the most reasonable
place out of several possibilities. But if, as Mr. Ayres says,
I think his words were we may have to compromise on
practicality. Somewhere, even if it seems like an arbi-
trary line, somewhere something has to be done. And it
seems to me that may be done provided there are oppor-
tunities for hearing as to the other matters.
Now if you are going to take a half life of a thousand
years, we have really got a hearing going here and I don’t
know whether we aregoing to make it.
MR. ROISMAN: Mr. Chairman, I don’t find this at all
humorous from the Applicant’s side of the table, I find it a
rather serious matter. You put your finger on the whole
problem. That plant, if it turns on, will produce something
that will be with this world long after we are gone. And
the issue that the National Environmental Policy Act is
directed to is how much do we mortgage the future for our
benefit today.
[2172]
Now if we can’t predict what is going to happen to that
fuel, and those wastes a thousand years from now, then that
505
is a factor to consider in the wisdom of creating a nuclear
power plant. Nuclear power plants create wastes that
don’t go away very quickly. I am not saying to the Board
that we must be able to say that little Jimmy Jones living
a thousand years from now is going to have thyroid cancer
because of the releases from the waste of this plant. [ am
saying if there is as much doubt about that question as the
Board seems to feel there is, then that is an issue in deciding
on the wisdom of licensing this plant. We already have a
dirty river out there because nobody thought about that
when they put the Barrows Coal Company up, when they
put those other plants up up the river. And the National
Environmental Policy Act was passed almost two years ago
for the specific purpose of saying, stop it, start thinking
about what you are going to be doing in the future. And
the doubts are part of the environmental analysis.
If we don’t have the answer, that is not to say we have
to spend 16 months of hearings trying to get it. Let the
Applicants say they don’t know what it is going to be, they
know the radioactivity is high, they know if anybody
walked into the room where the waste was, and was ex-
posed to it, unless it was a different kind of human being,
they would be killed or seriously affected by the waste and
then let’s make a [2173] rational judgment about whether
or not we want that kind of material around a thousand
years from now.
The whole purpose of the Kansas site study was an at-
tempt to predict how reliably you could put wastes in the
ground in 1971 and be sure they would still be there, safe
and sound, without any contact with human beings at the
time that the waste’s danger level was gone.
Now we were talking about the question of the remote-
ness of the imapet. You are talking about an entirely dif-
506
ferent matter. You are saying there is a lot of doubt. If
we had that same doubt about the performance of the
emergency core cooling system in this plant, a seant 20
years from now, this Board would be bound to say there is
too much doubt about radiological safety, we don’t know
what will happen if there is a loss-of-coolant accident, it is
in the future, we do have to speculate, we don’t have
enough evidence on it, license denied,
Now until the National Environmental Policy Act was
passed, there was at least an issue as to whether or not we
had to consider the waste question.
Now the issue is gone. It was gone on January | of 1970,
and what Judge Wright said on July 23, 1971, was only
what Congress said some 15 or 18 months before that.
DR. HALL: I disagree.
May I interrupt your eloquent and passionate speech
[2174] for the press but —
MR. ROISMAN: Excuse me, Dr. Hall, but that speech
had nothing to do with the press. And if it would make
you feel beter, I will ask the press to leave. It had to do
with this Board’s responsibility and I resent the implica-
tion of your statement, Dr. Hall.
DR. HALL: All right, I withdraw the implications and
| apologize for any inference | made.
| am aware you were speaking to the Board. But let me
say I think you are speaking in the wrong forum, that the
Board has no jurisdiction in this in my opinion. I am not
trying to draw a legal conclusion. I am just saying that the
Congress has passed the Atomic Energy Act of 1954, I
understand that this is a question that you or some of your
colleagues, somebody I read in the press, is challenging, the
validity of a portion of the Atomie Energy Act, and of
course that is not my concern,
507
But in all of the problems associated with producing
power by nuclear energy have been brought to Congress
from time to time and the Joint Committee of Congress has
considered these, and is fully aware of the problems. And
the notion that the waste is a necessary concurrent or neces-
sary part of the generation of power by nuclear energy is
well known to Congress. There has been no move by Con-
gress to pass any law saying that they shall not be used for
generation of nuclear energy.
[2175]
To say that NEPA has changed this, the passage of the
National Environmental Policy Act has changed this, I
think is incorrect.
MR. ROISMAN: But, Dr. Hall, the point is this: We
are trying to decide whether this power plant should be
licensed.
Now there is going to have to be an analysis of its bene-
fits against its costs. I don’t disagree with you that as long
as Congress kecps the 1954 Atomic Energy Act as written,
that Congress has said as far as we are concerned, there
is a point at which the benefits from nuclear power plants
would seem to outweigh the disadvantages. But the ques-
tion is, is Vermont Yankee at that point, or did it fall under
the line or over the line? That is why we do a licensing
proceeding for an individual plant. We can’t get at the
wisdom of the Vermont Yankee Plant if we can’t at least
weigh in the balance all of its reasonably predictable im-
pacts on the environment. Or to be able to put in there
that as to some impacts, we know that they will happen,
but we can’t really say where or when.
All right, that is a factor. You factor that in. Just as
you factor in your doubts about the emergency core cooling
system in deciding whether or not to approve a plant.
508
DR. HALL: My problem is then that if you ask, if that
were the approach that thisBoard would have to take, I
[2176]
would have to say that I can’t foresee all of this so I
couldn’t license any reactor. And that to me is close to
defeating the will of Congress.
It is to the contempt of Congress, but it is certainly de-
feating the will of Congress.
(2177]
MR. ROISMAN: I think the problem is that you—I
can understand why this would happen — but that you are
seeing it in the context of the nuclear industry, rather than
in the context of this nuclear plant. It may be that what
we do here will have an impact on the nuclear industry, but
what we are concerned with —
DR- HALL: That doesn’t bother me.
MR. ROISMAN: — is this plant. And my concern is,
to take the example to perhaps a situation we would never
reach in this rather fuzzy cost benefit analysis, if you had
weighed all of the benefits of this nuclear power plant, and
you weighed all of the costs, environmental, monetary, and
so forth, with waste disposal held aside, and you came out
just about even, 50/50, maybe 50.1 in favor and 49.9 against,
that you would have to factor in this additional cost, the
fact that the plant was going to produce a waste product
which would require very careful handling in the reprocess-
ing part, and very careful storage in the waste disposal
part.
And then if it had a risk to the public health and safety,
as it went through those two steps, you might turn the bal-
ance the other way. Another plant in which the benefits
outweighed the costs by 90 to 1 or something, it might be
when you added in the incremental dangers associated with
509
the processing and storage of fuel, you would still come up
with an answer, yes, the plants should be licensed.
[2178]
. I am not saying there is a legal requirement, at least not
inherent, that the very fact that we don’t know what will he
happening to the long-lifed isotopes 1,000 years from now
or where they might be, means inherently that the Board
can’t license the plant. I think it certainly means that the
benefits from the plant are going to have to be very high
before we pay that price. But that is an issue that the
Board can grapple with. It doesn’t seem to me to be the
kind of overly-expansive issue that you were discussing at
all.
I think it is a relatively narrow kind of issue. The Appli-
cant can give a lot of “I don’t knows,” and the Board ean
weigh the “I don’t knows” in the process of deciding
whether to license the plant.
DR. HALL: I don’t know how to put the “I don’t knows”
into the balancing, so I am afraid what would have to result
here would be a total investigation of present reprocessing
plants, future plans for reprocessing plants, as well as the
disposal plants. I think the mechanism, as far as I can
understand the guidance, what we are asked to look at, is
the mechanism for transportation of spent fuel elements,
not to rule or to pass that these will go to a specific location.
And I think the narrowing of this issue to what towns
this goes to, what highways, is also foolish inasmuch as we
have no knowledge of the road situation [2179] in the
future, even what the towns will be then. We can’t do it in
that narrow and detailed scope. I think the only thing we
ean do is try to see that there are reasonable procedures,
techniques for moving the fuel from this plant to a place
where a reprocessing plant might be. I can’t see that the
510
Applicant can be controlling beyond that point. If we have
to sav that we consider the other, then the scope of this
hearing is enlarged, so that I think it just breaks of its
own weight.
MR. ROISMAN: But the inability of the Applicant to
discuss it, that was exactly my point about the statement
that came out in the September 3 letter, I can see a reason-
able basis for saying that the Applicant can’t do that. But
the Regulatory Staff will be the sponsor of the ultimate
environmental document that is introduced in this pro-
ceeding, namely, the detailed environmental statement.
And what we are talking about is whats the scope ot
that statement and then what is the scope of this Board’s
reviewing powers with regard to that statement?
DR. HALL: The Regulatory Staff just is the agency
that determines or tries to investigate whether or not the
procedures are within the rules and regulations of the
Atomie Energy Act and the Code of Federal Regulations.
They, I am sure, have no more idea than anybody else
about the future status of the reprocessing plant in this
country, where they [2180] are or will be or who will be
operating them or where they are going to send their waste.
MR. ROISMAN: We have in this proceeding already
a lot of predictions on things that seem to me to have no
greater doubt. The Applicant is going to tell us about the
integrity of the fuel rods. We don’t know that they will
keep buying from that manufacturer. They are going to
diseuss the questions of the reliability of their inspection
system, that have to last through probably people who are
not even here today and who are conceivably not even born,
if we are talking about 40 years.
Their financial qualifications are based on a prediction
of what h
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