ML17138A628
| ML17138A628 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/21/1979 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML17138A629 | List: |
| References | |
| NUDOCS 7906190565 | |
| Download: ML17138A628 (20) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 05/21/79 In the Matter of PENNSYLVANIA POWER AND LIGHT CO.
ALLEGHENY ELECTRIC COOPERATIVE, INC.
(Susquehanna Steam Electric Station, Units 1
and 2)
)
)
)
Docket Nos.
50-387
)
50-388
)
)
)
NRC STAFF'S FIRST ROUND DISCOVERY REOUESTS OF MS.
COLLEEN MARSH, As allowed by 10 CFR 2.740b of the Comnissions regulations and the Licensing Board's Special Prehearin Conference Order dated March 6,
- 1979, the NRC Staff requests that Ms. Marsh answer the interrogatories set forth below.~
As required by 10 CFR 2.740b(b),
each interrogatory shall be answered separately and fully, in writing and under oath or affirmation, and the answers shall be signed by the person(s) making them.
In addition, as allowed by 10 CFR 2.741, the NRC Staff requests that Ms. Marsh make available for Staff inspection and cooying (or provide copies of), those documents designated by Ms. Marsh in her answers. 2/
The answers are to be provided by June 29, 1979, as required by the Licensing Board's S ecial Prehearin Conference Order dated March 6, 1979 (at p.
79 Of course, if the document was prepared by the NRC Staff or its 2l consultants, or was submitted by the Applicant in connection with the capttoned matter, it need not be made available by Ms'. Marsh.
'F 906 1 905/5
General -Interro atories~
G-l.
I State whether you intend to present any expert witnesses on the subject matter at issue in:
a) Contention 4
b) Contention 6
c) Contention 9
f) Contention12 g) Contention13 h) Contention14 d) Contention 10 e) Contention 11 If so, provide the names, addresses (residence and business),
and pro-fessional qualifications of those persons you expect to call as expert witnesses, state the subject matter on which the expert is expected to testify, state the substance of the facts and opinions to which the expert is expected to testify and provide a summary of the grounds for each opinion.
G-2.
Identify by title, author, date of issuance or publication, and issuer or publisher, all documents that you intend to use (refer to or offer in evidence) in presenting your direct case on the contentions listed
\\
in Interrogatory G-1 and all documents that you intend to. refer to in conducting your cross-examination of witnesses for other par ties who may testify in connection with any admitted contention, and make available those documents for Staff inspection and copying (or provide copies of them).
These interrogatories should be answered seoarately with respect to each contention.
0 S ecific Interro atories Contention 4
S-4.1.
Specify the growth rate of peak electric load that you believe will occur in the Applicants'ervice areas over the life o the Susquehanna faci 1 ity.
S-4.2.
Provide your projections of peak load and available capacity in the Applicants'ervice areas over the life of the Susquehanna facility.
S-4. 3.
Specify the models used in making your calculations of peak load and available capacity, and state why you believe those models should be used.
S-4.4.
Set forth in detail each calculation made and specify, and state your basis for, all assumptions made in reaching your conclusions about peak load projections and available capacity.
Contention 6
S-6. 1.
Identify (if necessary for clarity provide a map marked to show) the area in which (in the event of a design basis accident at the Susquehanna facility and without prompt notification and evacuation) you believe persons may be exposed to radiation doses in excess of those permitted by existing radiation exposure standards for the general public and pro-tective action guides.
l
S-6.2.
Specify the numerical values (in appropriate units) of the exposure standards and guides which you believe will be exceeded and state why you believe they will be exceeded.
S-6,3.
Specify the models used in making your dose-distance calculations and state why you believe those models should be used.
S-6.4.
Set forth in detail each calculation made and specify, and state your bases for, all assumptions made in reaching your conclusions about the adequacy of the emergency plan.
S-6. 5.
Specify in detail how you believe the Applicants'mergency plan fails to satisfy the Commission's regulations.
Cite each regulatory require-'ent that you believe is not satisfied.
State the basis for your con-clusion that the requirement is not satisfied by the Applicants'roposed plan.
Contention 9
S-9.1.
Specify with particularity why you believe that the monetary costs of decommissioning the Susquehanna facility will at least be equal to the cost of its construction and provide an estimate of those monetary costs.
S-9.2.
Provide an itemized list showing what you believe the monetary costs of decommissioning the facility will be.
S-9.3.
Set forth in detail each calculation made and specify, and provide your bases for, all assumptions made in reaching your conclusions about the monetary costs of decommissioning the Susquehanna facility.
S-9. 4.
Specify with particularity why you believe that decommissioning the Susquehanna facility will result in serious radiation hazards, particular-ly for workers.
S-9.5.
Identify and provide estimates of these "new" occupational hazards to workers.
S-9.6.
Specify with particularity the "new" environmental hazards that you believe wi 11 result from decorrmissioning the Susquehanna facility.
S-9.7.
Specify with particularity why you believe that the decommissioning
- costs, when added to other monetary and health'osts of the facility and the nuclear fuel cycle, tilt the cost-benefit balance against authorizi ng operation of the facility.
Contention 10 S-10. 1.
Describe in detai 1 the "significant" rail accident that you allege has already occurred at the Susquehanna facility.
S.-10.2.
Define with particularity the term "significant" as it is used in the context of contention 10 and state clearly why you believe that the accident described in answer to interrogatory S-10.
1 was significant.
0 S-10.3.
State clearly whether the accident, referred to as having occurred, occurred on-si.e.
S-10.4.
Describe in detail the actual damage that occurred to safety structures, systems or components of the Susquehanna facility.
S-10. 5.
Specify with particularity your reason(s) for believing that the rai 1 line is not adequately designed to assure that on-site accidents, that will damage safety systems, structu~ or components (to the extent that they will not be able to perform their intended safety functions) will not occur in the future.
S-10.6.
Identify with specificity the safety structures, systems or components that you believe will be damaged should a rail accident occur on-site, and state in detail the basis for your conclusions.
S-10. 7.
Describe
.in detail the extent and consequences of the damage that you believe would occur.
S-10.8.
Identify with particularity the standards (criteria) wi h which you believe the on-site portion of the ra'il line should be designed to comply.
S-10.9.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reaching your conclusions about rai 1 accidents at the Susquehanna facility.
Contention 11 S-ll.l.
Specify with particularity your reasons for believing that the Applicants'lleged failure to provide adequately for safe on-site storage, for periods of up to 10.to 15 years, of spent fuel and low-level radioacti've wastes creates an unreasonable risk of harm to the health and safety of the public.
S-ll.2.
Define the terms "adequately,"
"safe" and "unreasonable risk of harm" as they are used in the context of contention 11.
S-ll.3.
State whether, and if so why, you believe that the method of on-site storage of spent fuel and low-level radioactive wastes to be used at the Susquehanna facility will be unsafe.
S-ll.4.
How many spent fuel elements and what volume of low-level radioactive wastes do you believe can be stored at the facility as oroposed?
S-ll.5.
How many spent fuel elements and what volume of low-level radioactive wastes (that must tie stored on the site) do you believe will be produced in the first 10-15 years of normal operation of the Susquehanna facility?
S-ll.6.
State in detail how you believe the conditions, that you alleged, con-stitute a violation of 10 CFR 20.1 or 10 CFR 20. 105(a) of the Commission's regulations.
0 S-ll.7.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reaching your conclusions about spent fuel and 1 ow-1 eve 1 waste s tor age.
Contention 12 S-12.1.
Specify with particularity your reasons for believing that the alleged failure to solve the problem of flow-induced vibration in the core causes in-vessel sparger failure and creates an unreasonable risk of harm to the health and safety of the public.
S-12.2.
Define the terms "sparger," "in-vessel sparger failure" and "unreasonable risk of harm" as they are used in the context of contention 12.
S-12.3.
Specify with particularity the nuclear facilities, if any, at. which such "in-vessel sparger failure" has occured.
S-'l2.4.
What were the actual consequences to public health and safety of such "in-vessel sparger failure?"
S-12.5.
State in detail how you believe the condi tions, that you alleged, con-stitute a violation of 10 CFR 20.1 or 10 CFR 20.105(a) of the Commission,'s regulations.
S-12.6.
Set forth in detail all calculations
- made, and specify, and state your basis for, all assumptions made in reaching your conclusions about "in-vessel sparger failure."
Contention 13 S-13. 1.
Specify with particularity your basis for the statement that the Applicants have failed to respond adequately to and comply with NRC's Notice of Violation involving preliminary alignment of the safety-related
[reactor]
core isolation [cooling system pump (IP-203)].
S-13.2.
Oefine the terms "adequately" and "comply" as they are used in the context of,~contention 13.
S-13.3.
State whether, and if so specify with particularity why, you believe that this alleged infraction warrants the withholding of operating licenses for the Susquehanna units.
S-13. 4.
In light of the fact that the NRC has closed out Noncompliance 387/78-03-04, "Failure to Inspect Preliminary Alignment of Rotating Equipment to Pre-scribed Criteria," state your basis for believing that the Applicants have failed to respond adequately to and comply with the NRC's Notice of Violation involving preliminary alignment of the RCIC system pump.
(See letter dated March 14,
- 1979, "Combined Inspections 50-387/79-01; 50-388/79-02").
S-13.5.
In light of the facts stated in the reference cited in interrogatory S-13.4, do you plan to press contention 13 or withdraw it?
~
i Contention 14 I
S-14.1.
Specify with particularity why you believe that the capacity factors used in estimating the benefits of the Susquehanna units are overly optimistic and thus that the amount of electricity produced will be less than pre-dicted.
S-14.2.
Specify the capacity factors that you believe should be used (provide the numerical values as a function of time after the units begin operation) and state in detail the basis for your conclusion.
S-14.3.
Set forth in detail each calculation made and specify, and state your bases for, all assumptions made in reaching your conclusions about capacity factors for the Susquehanna units.
10 CFR 2.740(e) of the Commission's regulations states that a party is under a duty seasonably to supplement his response with respect to questions directly addressed to the identity of each person exoected to be called as an expert witness at the hearing, the subject matter on which the witness is expected to testify and the substance of the witnesses'estimony.
Section 2.740(e) also states that a party is under a duty seasonably to amend a prior response if he obtains information upon the basis of which
(i) he knows that the response was incorrect when made, or (ii) he knows that the response though correct when made is no longer true and the circumstances are such that a failure to amend the response is in substance a knowing concealment.
Respectfully submitted, James M. Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Maryland this 21st day of May, 1979
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