ML17138A631
| ML17138A631 | |
| 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 7906190576 | |
| Download: ML17138A631 (35) | |
Text
UNITED STATES OF AMERICA NUCLEAR PEGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 05/21/79 In the Matter of PENNSYLVANIA POWER AND LIGHT CO.
ALLE<HF'NY ELECTRIC COOPERATIVE, INC.
(Susquehanna Steaq Electric Station, Units 1 and 2)
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)
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Docket Nos.
50-387
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50-388
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NRC STAFF'S FIRST ROUND DISCOVERY REOUESTS OF THE ENVIRONMENTAL COALITION ON NUCLEAR POWER ECNP)
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 ECNP 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 ECNP make available for Staff inspection and copying (or provide copies of), those documents designated by ECNP in its answers.
/ 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 2/ Of course, if the document was orepared by the NRC Staff or its consultants, or was submitted by the Applicant in connection with the captioned matter, it need not be made available by ECNP.
General Interro atories~3/
G-1.
State whether you intend to present any expert witnesses on the subject matter at issue in:
a) Contention 1
b) Contention 2
c) Contention 3
d) Contention 4
f) Contention 6
g) Contention 7
h) Contention 8
i) Contention 9
e) contention 5
j) Contention 18 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
~3 each contention.
S ecific Interro atories S-l. 1.
Contention 1
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-1.2 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
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calculation made and specify, and state your bases for, all assumptions made by you in estimating the releases.
S-l.7.
Specify with particularity all of the errors that you believe to exist in the estimates oV the health effects of radon-222, the magnitude of such errors and the causes of such errors.
S-l.S.
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-l.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).
S-I.12.
Specify with particularity all of the errors that you believe to exist I
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-1.13.
Identify each isotope other than radon-222 that you believe will cause
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health effects, specify with particularity each health effect that you believe will occur and state in detail how that health effect is caused.
S-1.14.
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-1.15.
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 2
S-2. l.
Specify with particularity all of the errors that you believe to exist in the estimates of the health effects of cesium-137, cobalt-60 and chlorine releases from the Susquehanna facility, the magnitude of such errors and the causes of such errors.
S-2.2.
Specify the amount of cesium-137, cobalt-60 and chlorine 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-2.3.
Specify with particularity each health effect of cesium-137, cobalt-60 and chlorine that you believe will occur and state in detail how that health effect is caused.
S-2.4.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reachi ng your conclusions about the health effects of cesium-137, cobalt-60 and chlorine.
S-2. 5.
Specify with particularity the effect that you believe correct inclusion in the cost-benefit analysis of these allegedly now inadequately assessed health effects of cesium-137, cobalt-60 and chlorine 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 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.
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 5
S-5. l.
Specify with particularity the models used to calculate individual and population radiation doses that you believe to be inaccurate and obsolete and set forth in detail your basis for that belief.
S-5.2.
Specify with particularity the models that you believe should be used to calculate individual and population radiation doses and set forth in detail your basis for that belief.
S-5.3.
Set forth in detail each calculation made and specify, and state your basis for, all assumptions made by you in reaching your conclusions about radiation doses and dose models.
S-5.4.
Specify with particularity (not merely by general reference to an article h
h i I
b i f h <<h<<h i1 f
coefficient for iodine (as used in the individual and population dose
models) has been underestimated.
Specify the coefficient that you believe should be used.
S-5.5.
Set forth in detail each calculation made and specify, and state your basis for, all assumptions made in reaching your conclusions about the milk transfer coefficient for.iodine.
S-5.6.
Specify with particularity (not merely by general reference to an article Ph i
i b i f h <<
<<h<<h used in the individual and population dose models) for conversion of alpha-particle dose in rads to rems are far too low.
Speci fy the factors that you believe should be used.
S-5.7.
Set forth in detail each calculation made and specify, and state your basis for, all assumptions made in reaching your conclusions about the factors for conversion of alpha-particle dose in rads to rems.
S-5.8.
Specify with particularity (not merely by general reference to an article
~H11Ph i iy b
i f I<<<<h<<h used in the individual and population dose models) for estimating radiation effects of low energy beta and gamma radiation, as from H-3 and C-14, underestimate those effects.
Specify the factors that you believe should be used.
0 S-5.9.
Set forth in detail each calculation made and specify, and state your bases for, all assumptions made in reaching your conclusions about the factors for estimating the radiation effects of low energy beta and gamma radiation.
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.
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-ment that you believe is not satisfied.
State the basis for your con-clusion that the requirement is not satisfied by the Applicants'roposed pl an.
Contention 7
S-7.1.
Specify with particularfty your basis for the statement that the Sus-quehanna containment structures may not be strong enough to withstand the dynamic forces that could occur during blowdown.
S-7.2.
Identify with particularity each dynamic force "realized during blowdown" that you believe the containment should be designed to withstand and state your basis for believing that the containment may not be able to withstand such force(s).
S-7.3.
Set forth in detail each calculation made and specify, and state your bases for, all assumptions made in reaching your conclusions about the ability of the containment to withstand the dynamic forces that could occur during blowdown.
S-7.4.
Specify with particularity why you believe that the type of pipe cracking that has occurred at other BWR facilities renders the Susquehanna units unsafe to operate.
0 S-7.5.
In what types of stainless steel piping has this cracking mainly occurred?
S-7.6.
Has such cracking occurred at nuclear facilities in piping made of materials other than stainless steel?
If so, identify those materials.
S-7.7.
What condi tions have been found to make piping susceptible to the occurrence of intergranular stress corrosion cracking?
S-7,8.
What measures can be taken during design and fabrication of piping to prevent, or reduce the likelihood of, pipe cracking at the Susquehanna facility?
S-7.9.
What. were the actual consequences to public health and safety of the pipe cracking to which you refer as having occurred?
S-7." 10.
Set forth in detail each calculation made and specify, and state your basis for, all assumptions made in reaching your conclusions about pipe cracking.
S-7.11.
Specify with particularity why you believe that the type of nozzle cracking that has occurred at other BWR facilities renders the Susquehanna units unsafe to operate.
S-7.12.
In what types of nozzles other than "core spray" nozzles has cracking occurred?
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S-7.13.
What conditions caused this nozzle cracking'?
S-7.14.
What measures can be taken during the design, fabrication or operation of the nozzles to prevent, or reduce the likelihood of, nozzle cracking at the Susquehanna facility?
S-7.15.
What were the actual consequences to public health and safety of the nozzle cracking 'to which you refer as having occurred?
S-7.16.
Specify with particularity what you would consider to be an acceptable demonstration of the low contribution to risk of an anticipated transient without scram
{ATWS), and state in detail the basis for your conclusion.
Contention 8
S-S.1.
Specify with particularity your basis for the statement that the Appli-cants have not adequately demonstrated "compliance" with part II.6.
"Operating Conditions," of Standard Review Plan, 55.3.3, "Reactor Vessel Integrity."
S-8.2.
Define the terms "adequately" and "compliance" as they are used in the context of Contention 8.
S-8.3.
Identify the specific requirements of the Commission's regulations that the reactor pressure vessel does not meet and provide the basis for your conclusion.
S-8.4.
Set forth in detail each calculation made and specify, and state your bases for, all assumptions made in reaching your conclusions about the inability of the reactor pressure vessel to withstand thermal shock.
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.
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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 will result from decommissioning the Susquehanna facility.
0
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tL h S-9.7.
Specify with particularity why you believe that the decommissioninq
- costs, when added to other monetary and health'osts of the facility and the nuclear fuel cycle, tilt the cost-benefit balance against authorizing operation of the facility.
Contention 18 S-18.1.
State whether, and if so specify with particularity why, if use of herbicides is prohibited you believe that some alternate means (for
- example, cutting and pi ling the brush) of maintaining the clearance of transmission line rights-of-way cannot be used.
S-18.2.
State whether, and if so specify with particularity why, you believe that the environmental impacts of periodically cutting and piling the brush that may grow in the transmission line rights-of-way would be
- adverse, environmentally significant and sufficient to tip the cost-benefit balance against authorizing operation of the Susquehanna facility.
S-18.3.
Set forth in detail each calculation made and specify, and state your bases for, all assumptions made in reaching your conclusions about the environmental impacts of methods for maintaining the clearance of trans-mission line rights-of-way.
10 CFR 2.740(e) of the Commission's regulations states that a party is under a duty seasonably to suoplement 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 expected to testify and the substance of the witnesses'estimony.
Section 2.743(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 resoonse 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 "1. Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Maryland this 21st day of May, 1979
e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 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 CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FIRST ROUND DISCOVERY REQUESTS OF THE CITIZENS AGAINST NUCLEAR DANGERS (CAND)", "NRC STAFF'S FIRST ROUND DISCOVERY REQUESTS OF THE SUSQUEHANNA ENVIRONMENTAL ADVOCATES (SEA)",
"NRC STAFF'S FIRST ROUND DISCOVERY REQUESTS OF MS.
COLLEEN MARSH", and "NRC STAFF'S FIRST ROUND DISCOVERY REQUESTS OF THE ENVIRONMENTAL COALITION ON NUCLEAR POWER (ECNP)" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comnission's internal mail system, this 21st day of May, 1979:
Charles Bechhoefer, Esq.,
Chairman*
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Glenn 0. Bright*
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Oscar H. Paris*
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Jay Silberg, Esq.
- Shaw, Pi ttman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State
- College, PA 16801 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania P.O.
Box 2063 Harrisburg, PA 17120 Ms. Colleen Marsh Box 538A, RD¹4 Mountain Top, PA 18707 Mrs. Irene Lemanowicz, Chairperson The Citizens Against Nuclear Dangers P.O.
Box 377 RD¹1
- Berwick, PA 18503
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Susquehanna Environmental Advocates c/o Gerald Schultz, Esq.
500 South River Street Wilkes-Barre, PA 18702 Atomic Safety and Licensing Appeal Board Panel*
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel*
U.S. Nuclear Regulatory Comnission Washington, D.C.
20555 Docketing and Service Section*
Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 James M. Cutchin, IV Counsel for NRC Staff
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