ML17297A586
| ML17297A586 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/21/1981 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Hourihan P AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8107240226 | |
| Download: ML17297A586 (14) | |
Text
REGULATOR NFORMATION DISTRIBUTION S EM (RIDS)
ACCESSION NBR ~ 8 1 07240226 DOC o DATEI B 1/07/2 1'OTARIZED! NO, DOCKET FACIE:STN 20 520 Pe'lo Verde.'uclebri Stethoni Untt Ii Arteone Publ!~COS000'Sl@
STN 50 529 Palo Verde Nuclear" Stations Unit 2r. Ar)zona Public 05'000529 STN 50 530 Palo" Verde Nuclear'tations Unit 3i Arizona Public 05000530 AUTH INANE'UTHOR AFFILIATION MCGURRKNiHNJ.
Hear ing Branchy i.
REC IP ~ NAMEI REC'IPXKNT AFFIL>>IAiTION HOURIHANiP,L, Affiliation Unknown.
SUBJECT:
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Docket Nos.
STN 50-528 STN 50-529 STN 50-530 In the 11atter of ARIZONA PUBLIC SERVICE COI'1PANY, ET AL.
(Palo Verde Nuclear Generating Station, Units 1, 2 and 3) 07/21/81 UNITED STATES OF 01ERICA NUCLEAR REGULATORY C01111ISSION
~ ~~ g 5 BEFORE THE ATONIC SAFETY AND LICENSING BOARD
)
NRC STAFF SECOND SET OF INTERROGATORIES TO, AND RE UEST FOR DOCUMENTS FROM PATRICIA LEE HOURIHAN INTRODUCTION AND INSTRUCTIONS The NRC Staff heretg requests that Patricia Lee Hourihan (Intervenor), pursuant to 10 C.F.R. 55 2.740b and 2.741, answer sepa-rately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying, all documentary material identified in responses to interrogatories below.
Each response to the interrogatories below shall be under oath or
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affirmation of the individual(s) who contributed thereto.
For all refer-ences requested in these interrogatories, identify them by author, title, date of publication and publisher if the reference is published, and if it is not published, identify the document by the author, title, the date it was written, the qualifications of-the author relevant to this pro-
- ceeding, and where a copy of the document may be obtained.
g5o 1
5
Contention No. 1+
"Applicants will fail to maintain annual releases of radioactive materials from the normal operation of PVNGS 'within the levels set forth as numeral
[sicJ guides for design objectives in Section II's required by Section IV of 10 C.F.R. 50, Appendix I."
(Safety).
1-4.
Identify any and all documentary or other material that you intend to use during this proceeding to support this contention and that you may offer as exhibits on this contention or refer to during your cross-examination of witnesses presented by joint applicants and/or the NRC Staff.
1-5.
Provide the analysis that leads to the basis for Contention No.
1.
Include in your response:
a.
A description of the models, parameters and the basis for selecting the models and parameters used; b.
The specific transfer factors and other data used which may underestimate the dose equivalents to the population; c.
Show quantitatively the difference in using the ground level release model versus the elevated release model and the signifi-cance of the effect on the doses calculated; d.
Provide a list of all references used and'a copy of all references that are not readily available.
Ql The numbering and wording of the contentions stated in these inter-rogatories conforms to that accepted by the Licensing Board in its tlemorandum and Order dated April 16, 1981.
~
f
w 3 1-6.
a.
If none of the estimated doses from the Palo Verde facility are "expected to be due to the a actinide isotopes"+
and the super-linear hypothesis only applies to "alpha-emitters",+ explain how I
the super-linear hypothesis relates to and supports Contention 1.
1-6.
c.
Specify the basis for your view (item 4 of the "Explanation" to Contention No.
- 1) that there is an ever-growing number of scientists favoring the super-linear hypothesis.
Include in your response the names and professional qualifications of specific scientists who favor this philosophy.
1-7.
Provide the basis for you> assertion in item 3 of the "Explanation" to Contention No.
1 that pressurized water reactors larger than 1000 HWe have less efficient operational history and consequently can be expected to release larger curie-quantities of noble gases via gaseous effluents than pressurized water reactors operating at less than 1000 HWe.
Include in your response the following:
a.
The reactors you have considered in your analysis indi-cating for each reactor the specific years of operation.
b.
The data you used for each of the reactors noted in Inter-rogatory No. 1-7a, above, including for each reactor the power level, failed fuel level and annual noble gas release rate.
c.
The gaseous waste management system parameters for each of the 16 reactors, including the fill time and hold up time in the decay tanks and inputs into the gaseous waste decay tanks.
Q2 Intervenor's Answers to NRC Staff first Set of Interrogatories, at page 4.
Q3 Id., at page 3.
t
e.
The references you have used to gather these data.
1-8.
Since your study of the PWR's noble gas releases for the year
- 1977, have you studied or collected any data which concerns reactor noble gases released for any other years.
If you have, provide such data and the results of your findings.
Contention No.
8 "The base mats for Units 1 and 2 are not structurally able to support the systems and equipment inside containment, because some of the concrete slump tests performed by Engineering Testing Labs for Units 1 and 2 were falsified."
(Safety).
'-1.
a.
Upon what person or persons do you rely to substantiate in whole or in part your case on Contention No. 87 b.
Provide the addresses and education and professional qualifi-cations of any persons named in your response to a.
above.
c.
Identify which of the above persons or any other person you may call as witnesses on this contention.
8-2.
Provide summaries of the views, positions or proposed testimony on Contention No.
8 of all persons named in response to Interrogatory No. 8-1, that you may present during this proceeding.
8-3.
State the specific bases and references upon which any person named in response to Interrogatory Ho. 8-1 rely to substantiate in whole or in part his views regarding Contention No. 8.
8-4.
Identify all documentary or other material that you may use
, during this proceeding to support this contention and that you intend to offer as exhibits on this contention or refer to during your cross-
(J I
't
examination of witnesses presented by Joint Applicants and/or the NRC Staff.
8-5.
Identify the specific portion or portions of the Palo Verde base mats for Units 1 and 2 that are not structurally able to support the systems and equipment inside containment.
8-6.
With regard to your assertion that the slump tests performed by Engineering Testing Labs for Units 1 and 2 were falsified:
a.
Identify which specific tests were falsified.
b.
Indicate for each such test the basis for your belief that such tests were falsified.
Respectfully submitted, Dated at Bethesda, maryland this 21st day of July, 1981.
H r
J. tlc urren Counsel for NRC Staff
e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ARIZONA PUBLIC SERVICE COMPANY, ET AL.
(Palo Verde Nuclear Generating Station, Units I, 2 and 3)
)
)
)
)
)
)
Docket Nos.. STN 50-528 STN 50-529 STN 50-530 CERTIFICATE OF SERVICE I hereby certify that cooies of "NRC STAFF SECOND SET OF INTERROGATORIES TO, AND REQUEST FOR DOCUMENTS 'FROM, PATRICIA LEE HOURIHAN" in the above-caotioned proceeding have been served on the following by deposit in the United States mail, f'irst class, or, as i'ndicated by an asterisk, through deposit in the Nuclear Regulatory Commi'ssi'on s internal mail system, this 21st day of July, 1981:
Robert M. Lazo, Esq.,
Chairman*
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission llashington, DC 20555 Dr. Richard F. Cole*
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Or. Dixon Callahan Union Carbide Corporation P.O.
Box Y
Oak Ridge, TN 37830 Arthur C. Gehr, Esq.
Charl es Bischoff, Esq.
Snell E l<ilmer 3100 Valley Center
- Phoenix, AZ 85073 Bruce Meyerson Arizona Center for Law in the Public Interest 112 Worth Fifth Avenue
- Phoenix, AZ 85003 Ms.
Lee Hourihan 6413 S.
26th Street
- Phoenix, AZ 85040 Atomic Safety and Licensing Board Panel*
U.S.
Nuclear Regulatory Commission llashington, DC 20555 Atomic Safety and Licensing Appeal Board*
U.S. Nuclear Regulatory Commission washington, DC 20555 Docketing and Service Section*
Office of the Secretary U.S.
Nuclear Regulatory Commission Hashington, DC 20555 H n
'cGurren Couns for NRC Staff
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