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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Appendix — Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc. · 435 U.S. 519 | Frix