ML17138A802
| ML17138A802 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/21/1979 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML17138A801 | List: |
| References | |
| OTHR-790521, NUDOCS 7909270033 | |
| Download: ML17138A802 (16) | |
Text
UNITED STATES OF AllERICA NUCLEAP, PEGULA OR'( CO!,'!ISSIOH BEFORE THE ATOP!IC SAFETY AilO LIC""llSIllG BOARO 05/21/79 In the hatter of PEN ISYLVAilIAPOilER AiiD LIGHT CO ALLE<HF'lY ELECTRIC COOPERATIVE, INC.
(Susquehanna Steaq Electric Station, Units 1
and 2)
Oocket Hos.
50-387 50-388 HRC STAFF'S FIRST ROUHO DISCOVERY REOUESTS OF THE EilYIRO."NBITALCOALIT ON O.'I NUCLEAR PO'lER ECilP) r's. allowed by 10 CFR 2.740b of the Cornnissions regulations and the Licensing Board's Special Prehearing Conference Order dated i'!arch 6,
- 1979, the tlRC Staf requests that EC"lP answer the interrogatories set forth below.
As required by 10 CFR 2.740b(b),
each interrogatory 1/
shall be answered separately and fully, in writing and under oath or affirmation, and the answers shall be siqned by the person(s) makino them.
I E
I I
In addition, as allowed by 10 CFR 2.741, the tlRC Staff requests that ECHP make available for Staff inspection and copying (or provide copies of), those documents designated by EC,'lP in its answers.2/
~ The answers are to be provided by.3une 29,
- 1979, as required by the Licensing Board's Special Pre..carina Conference Or"er dated Harch 6, 1979 (at p. 79).
21 Of course, if the document was oreoared by the
'lRC St
= or its consultants, or 'ras submitted by the Aoolicant in connection wi "h the caotioned matter, it need not be made available by C.'P.
790927 0>35
General Interro atories-
~
3/
G-1.
State whether you intend to oresent 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 exoert witnesses, state the subject matter on which the expert is expec.ed to testify, state the substance of the fac.s and opinions to which the expert is expected to testify and provide a sutmary 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 Staf inspection and copying (or provide copies of them).
3/ These interrogatories should be answered seoarately with resoect to
>ach contention.
Soecif ic Interrogatories 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-l.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-1,3.
Specify with particularity the ef"ect that you believe each assumption lis.ed in 'answer to interrogatory S-1.2 has on the estimate of radon releases.
S-1.4.
Set for th in detail the assumptions that you believe should be made in estimating radon releases.
S-l.5.
Speci y 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-l.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 oV the heal th effects of radon-222, the magnitude of such errors and the causes of such errors.
S-1.8.
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-l.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 Chat analysis and state in detail the basi s for your concl us ion.
5-1.11.
Specify with particularity your basis for the stat ment that the health effects of all isotopes, other than radon-22, to be re1eased during the fuel cycle for the Susquehanna acility have been underestimated (and misrepresented).
S-1.12.
Specify with particularity all of the errors that you believe to exist in the estimates of the health ef ects of isotopes other than radon-222, the magnitude of such errors and the causes of such errors.
S-l. 13.
Identi y 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-I.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-I.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 tha t
- analysis, and state in detail the basis for your conclusion.
Contention 2
S-2.1.
Specify ~ith particularity all of the errors that you believe to exist in the estimates of the health effects o
cesium-)3?,
cobalt-60 and chlorine releases from the Susquehanna facility, the magnitude of such errors and the causes of such errors.
'-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 ef ect is caused.
S-2. 4.
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 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 ar not sufficient to supply the lifetime fuel requirements of Susquehanna I 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 beliere 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 par.icularity why you believe that fuel costs for the facility, when added to other costs, will tip the cost-bene it balance agains authorizing operation of the facility.
S-4. 1.
Contention 4
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 speci y, and state your basis for, all assumptions made in reaching your conclusions about peak load projections and available capacity.
Contention 5
S-5.1.
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 orth 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.
Soecify with particularity (not merely by general reference to an article coefficient for iodine (as used in the individual and popula.
on 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 b i<< <<h used in the individual and population dose models) for conversion of alpha-particle dose in rads to rems are far too low.
Specify 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 revs.
S-5.8.
Specify with particularity (not merely by general reference to an ar chicle h
i
)
i <<1
h I
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.
Soecifv the factors that you believe should be used.
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 ganja 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 faci lity 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 exposur standards and guides which you believe wi 11 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 for th in detail each calculation made and specify, and state your bases or, all assumptions made in reaching your conclusions about the adequacy of the emergency plan.
S-6.5.
Specify in detaiI how you believe the Applicants'mergency plan ails 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 7
S-7.1.
.Specify with particularity your basis for the statement that the Sus-quehanna containment structures may not be s.rong enough to wi hstand the dynamic forces that could occur during blowdown, S-7.2.
Identify with particularity each dynamic force "realized during blcwdown" that you believe the containment should be designed to withstand and state your basis for believing that th containment may not be able to withstand such force(s).
S-7.3.
Set forih 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 a. othe.
B'AR faciliiies renders the Susquenanna uniis unsafe to operate.
S-7.5.
In what types of stainless ste 1 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, identi y thos'e materials.
S-7.7.
Mhat conditions have been found to maLe piping susceptible to the occurrence of intergranular stress corrosion cracking?
S-7.8.
Mhat 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 particulari y why you believe that the type of nozzle cracking that has occurred at other 8'lR facilities renders the Susquehanna units unsafe to ooerate.
S-7.12.
In what types or nozzles other than "core spray" nozzles has cracking occurred?
' 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 coniribution to risk of an anticipated transient without scram (ATWS), and state in detail the basis or your conclusion.
Contention 8
S-8.1.
Specify with particularity your basis. for the siatement that the Apoli-cants have not adequaiely demonsirated "compliance" with pari II.6, "Operating Conditions," of Standard Review Plan, 55.3.3, "Reactor
~lessel Integrity. "
S-8.2.
Define the terms "adequately" and "compliance" as they are used in the con texi of Con ten tion 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.
/
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.
1 S-9.4.
Specify with particularity why you believe that decommissioning the Susquehanna facility will result in serious radiation hazards, particular-ly or workers.
S-9.5.
Identify and provide estimates of these "nev" occupational hazards to workers.
S-9.6.
Specify with particularity the "new" environmental hazards that you believe will result from decorrmissioning the Susouehanna facility.
S-9. 7.
pecify 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 cos -benefit balance against authorizing opera tion of the faci 1 i ty.
Contention 18 S-18.1.
State whether, and if so specify with particularity why, i= use o,
herbicides is prohibited you believe that some alternate means (for example, cutting and piling 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 iip 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 impacis of methods formaintaining 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 resoonse 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 2.74A(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 resoonse is in substance a knowing concealment.
Respectfully submitted, James
'I. Cutchin, I~I Counsel for i'IRC Sta f Gated at Sethesda, Maryland this 21st day of May, 1979