ML18031A137
| ML18031A137 | |
| 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 7906190560 | |
| Download: ML18031A137 (12) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 05/21/79 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANIA POHER AND LIGHT CO.
ALLEGHENY ELECTRIC COOPERATIVE, INC.
(Susquehanna S team El ectric Sta tion, Units 1
and 2)
)
)
)
Docket Nos.
50-387
)
50-388
)
)
"NRC"STAFF'S FIRST ROUND DISCOVERY REQUESTS'
'OF THE CITIZENS'AGAINST NUCLEAR DANGERS CAND 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 CAND 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 CAND make available for Staff inspection and copying (or provide copies of), those'documents designated by CAND in its answers.2/
4 ll The answers are to be provided by June 29,
- 1979, as required by the Licensing Board's Snecial Prehearino Conference Order dated March 6, 1979 {at p.
79 Of course, if the document was orepared by the NRC Staff or its 2/
consultants, or was submitted by the Applicant in connection with the captioned matter, it need not be made available by CAND.
Gener a 1 Interroaa tories 3/
G-1.
State whether you intend to present any expert witnesses on the subject matter at issue in:
a) Contention 2
b) Contention 4
c) Contention 6
f) Contention ll g) Contention 16 h) Contention 17 d) Contention 9
e) Contention 10 If so, provide the names, addresses (residence and business),
and pro-fessional qualifications of those persons you expect to call as exper t t
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 evidencq) 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 seoarately with respect to each contention.
S ecific Interro atories Contention 2
l S-2.1.
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 for th 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 beligve 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 reaching your conclusions about the health effects of cesium-137, cobalt-60 and chlorine.
S-Z.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 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 facility.
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.
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 requi re-ment that you believe is not satisfied.
State the basis for your con-elusion 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 4
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.
I S-9. 5.
Identify arid 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.
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-benefi't balance against authorizing 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.
S-10.3.
State clearly whether the accident, referred to as having occurred, occurred-on-s5te.
S-10. 4.
Describe in detai 1 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 rail line is not adequately designed to assure that on-site accidents, that will damage safety
- systems, structures 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) 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.
S-11.1.
Contention ll
'S 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 he stored at the facility as oroposed?
S-ll.5.
How many spent fuel elements and what volume of low-level radioactive wastes I
(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.
-11.7.
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 16 S-16.1.
Specify with particularity your basis for the stater.". nt that seventy million gal'lons of radioactive evaporated water are to be vented daily from the Susquehanna facility's cooling towers.
S-16.2.
Set forth in detail each calculation made and specify, and state your.
bases for, all assumptions made in reaching your conclusions about the amount, radioactive content, and environmental impact of water evaporated in the cooling towers.
S-16.3.
Specify the effect that you believe inclusion in the cost-benefit analysis of this allegedly now improperly evaluated economic threat will have on the outcome of that analysis and state in detail the basis for your conclusion.
Contention 17 S-17.1.
Spe ify with particularity whether, and if so why, you believe that the environmental impacts of'he 500 kV transmission lines for the Susquehanna facility are such as to tip the cost-benefit balance against 'authorizing operation of'he facility.
S-17.2.
Specify with particularity
- whether, and if so why, you believe the results of "mini" cost-benefit balances would support requiring either:
a) use of transmission lines of voltages no greater than 230 kV, or b) placing the 500 kV lines (using compressed gas as an insulator) underground, S-17.3.
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 500 kV transmission lines and the costs and ben its of 230 kY and underground transmission lines.
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 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 2.740(e) also states that a party is under a duty seasonably to amend a prior response if he obtains information uoon 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'ircumstances are such that a failure to amend the response is in substance a knowing concealment.
Respectfully submitted,
~'ames M. Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Maryland this 21st day of May, 1979