ML17138A630
| ML17138A630 | |
| 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 7906190572 | |
| Download: ML17138A630 (25) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS ION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 05/21/79 In the Matter of PENNSYLVANIA POHER AND LIGHT CO.
ALLEGHENY ELECTRIC COOPERATIVE, INC.
(Susquehanna Steam Electric Station, Units 1 and 2)
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Docket Nos.
50-387 50-388 NRC STAFF'S FIRST ROUND DISCOVERY RE(UESTS OF. THE SUS UEHANNA ENVIRONMENTAL ADVOCATES SEA As allowed by 10 CFR 2.740b of the Commissions regulations and the Licensing Board's Special Prehearin Conference Order dated March 6, 1979, the NRC Staff requests that SEA answer the interrogatories set forth below.~
As required by 10 CFR 2.740b(b),
each interrogatory 1i 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 SEA make available for Staff inspection and copying (or provide copies of), those documents designated by SEA in its answers.~
The answers are to be provided by June 29,
- 1979, as required by the Licensing Board's Special Prehearin Conference Order dated March 6, 1979 (at p.
79 Of course, if the document was prepared by the NRC Staff or its 2I consultants, or was submitted by the Applicant in connection with the captioned matter, it need not be made available by SEA.
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General Interro a tories 3/
G-1.
State whether you intend to present any expert witnesses on the subject matter at issue in:
a) Contention 1
b) Contention 3
c) Contention 4
d) Contention 6
e) Contention 9
f) Contention 10 g) Contention 11 h) Contention 15 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 parties 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 separately with respect to each contention.
0 S ecific Interro atories Contention 1
S-l.l.
Set forth in detail your basis for the statement that the radon-222 to be released as a result of the fuel cycle for the Susquehanna facility has not been adequately assessed.
S-1.2.
Set forth in detail each incorrect assumption that you believe to have been made in estimating the radon releases, and state with specificity all your reasons for believing that the assumptions made are incorrect.
S-l.3.
Specify with particularity the effect that you believe each assumption listed in answer to interrogatory S-l.2 has on the estimate of radon releases.
S-1.4.
Set forth in detail the assumptions that you believe should be made in estimating radon releases.
S-l.5.
Specify with particularity the effect that you believe each assumption listed in answer to interrogatory S-l.4 has on the estimate of radon releases.
S-1.6.
If you allege that radon-222 releases are underestimated, specify the amount that you believe will be released and set forth in detail each
calculation made and specify, and state your bases for, all assumptions made by you in estimating the releases.
S-1.7.
Specify with particularity all of the errors that you believe to exist in the estimates of the health effects of radon-222.
the magnitude of such errors and the causes of such errors.
S-l.8.
Specify with particularity each health effect of radon-222 that you believe will occur and state in detail how that health effect is caused.
S-1. 9.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reaching your conclusions about the health effects of radon-222.
S-1.10.
Specify with particularity the effect that you believe inclusion in the cost-benefit analysis of these allegedly omitted health effects of radon-222 will have on the outcome of that analysis and state in detail the basis for your conclusion.
S-l. 11.
Specify with particularity your basis for the statement that the health effects of all isotopes, other than radon-22, to be released during the fuel cycle for the Susquehanna facility have been underestimated (and misrepresented).
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S-1.12.
Specify with particularity all of the errors that you believe to exist in the estimates of the health effects of isotopes other than radon-222, the magnitude of such errors and the causes of such errors.
S-l.13.
Identify each isotope other than radon-222 that you believe will cause health effects, specify with particularity each health effect that you believe will occur and state in detail how that health effect is caused.
S-l.14.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reaching your conclusions about the health effects of isotopes other than radon-222.
S-l.15.
Specify with particularity the effect that you believe correct inclusion in the cost-benefit analysis of these allegedly now underestimated health effects of isotopes other than radon-222 will have on the outcome of that analysis.
and state in detail the basis for your conclusion.
Contention 3
S-3.1.
State with particularity why you believe that known and assured reserves of uranium are not sufficient to supply the lifetime fuel requirements of Susquehanna 1 and 2.
S-3.2.
Specify the values that you assumed (or calculated) for:
(1) known and assured, reserves of uranium, (2) lifetime fuel requirements of
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Susquehanna 1
and 2, and (3) total uranium requirements of all types during the lifetime of Susquehanna 1
and 2 and state in detail the bases for your assumptions (or calculations).
S-3.3.
Specify with particularity your basis for the statement that much uranium for the facility will have to.be imported and state the amount that you believe will have to be imported.
S-3. 4.
Set forth in detail each calculation made and specify, and state your basis for, all assumptions made in estimating fuel requirements, reserves and imports.
S-3.5.
Specify with particularity why you believe that fuel costs for the facility, when added to other costs, will tip the cost-benefit balance against authorizing operation of the facility.
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 of 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.
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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'sed.
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.
S-6.1.
Contention 6
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.
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.
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S-6.5.
Specify in detail how you believe the Applicants'mergency plan fails to satisfy the Commission's regulations.
Cite each regulatory require-ment 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'onetary 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.
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1 S-9.6.
Specify with particularity the "new" environmental hazards that you believe will result from decommissioning the Susquehanna facility.
S-9.7.
Specify with particularity why you believe that the decommissioning
- costs, when added to other monetary and health costs of the facility and the nuclear fuel cycle, tilt the cost-benefit balance against authorizing operation of the facility.
Contention 10 S-10. 1.
Describe in detail 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.
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
0 damage safety systems, structuresor 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 rai 1 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) with which you believe the on-site portion of the rail 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 rail 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-11.3.
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-11.4.
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-11.5.
How many spent fuel elements and what volume of low-level radioactive wastes (that must be 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.
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 low-level waste storage.
Contention 15 S-I5.1.
Specify with particularity each health effect caused by the exposure to radiation of maintenance workers and workers working on Unit 2 while Unit 1 is in operation that you believe wi 11 occur and state in detail how that health effect is caused.
S-15.2.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reaching your conclusions about the health effects to workers on Unit 2 while Unit 1 is in oper ation.
S-15.3.
Specify with particularity why you believe that the health effects caused by exposure to radiation of the workers completing construction of Unit 2 after Unit 1 is in operation, when added to other costs, will tip the cost-benefit balance against operation of Unit 1 until construction of both units is complete.
S-15.4.
Specify with particularity why you believe that under the "as low as is reasonably achievable" standard of 10 CFR 20.1(c), there need be no ex'posure of workers completing construction of Unit 2 aft'er Unit 1 is in ope.ation.
S-15.5.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reaching your conclusion that occupational radiation exposures are not "as low as is reasonably achievable."
10 CFR 2.740(e) of the Commission's regulations states that a party is under a duty seasonably to supolement his response with respect to questions directly addressed to the identity of each person expected to be called as an expert witness at the hearing, the subject matter on which the witness is exoected to testify and the substance of the wit-nesses'estimony.
Section 2.740(e) also states that a part y 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 H. Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Haryland this 21st day of May, 1979
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