ML18219D207
| ML18219D207 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/07/2018 |
| From: | Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18219D207 (70) | |
Text
UNITED,STATES OF AMERICA ATOMXC ENERGY COMMISSION Before the Atomic Safet and Licensin Board (Donald C.
Cook Nuclear Plant, Units 1 and 2)
In the Matter of
))"
INDIANA & MICHIGAN ELECTRIC COMPANY )
)
and
)
)
INDIANA 6 MICHIGAN POWER COMPANY
)
)
)
Docket N
50-315 50-APPLXCANTS'NITIAL INTERROGATORIES TO INTERVENORS BROOKS ET AL.
AND REQUESTS FOR DOCUMENTS Pursuant to section 2.740b of the Rules of Practice, Applicants hereby request that Intervenors Brooks et al.
answer separately and fully in writing, under oath and in accordance with the provisions of said section 2.740b, the following written interrogatories.
Applicants also request.
that Intervenors provide the documents listed in Section II below pursuant to section 2.741 of the Rules of Practice.
I.
INTERROGATORIES The following Interrogatories Nos.
1 through ll represent a list of general interrogatories, all of which will be asked in conjunction with the individual contentions specified in Intervenors'uly 28, 1972 Petition to Intervene.
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Following the list of general interrogatories will be the specific interrogatories which Applicants request Intervenors to answer with*respect, to their contentions.
\\
A.
List of General Interro atories l.
Is the allegation based. on calculations?
If. so:
a ~
Describe the calculations and provide a copy of the calculations.
b.
Who performed the, calculations?
c.
When were the calculations performed?
d.
Describe the parameters used in the calculations and the values assigned to the parameters,,and describe the source of your data.
e.
What are the results of such calcula-tions?
f.
Explain in detail how such calculations provide a basis for your contention.
2.
Is the'llegation based upon any"type of study or analysis?
If so:
a.
Describe the nature of the study or analysis and provide a copy of the study or analysis.
t
[3l b..
Who performed -the study or analysis?
c..
When was the study or analysis per-formed'?
d.
Describe in detail the information that was studied,or'analyzed.
e.
What were the results of such study or analysis?
f.
Explain how such study or analysis provides a basis for your contention.
3.
Is the allegation based upon any existing documents?
If so:
a.
Furnish a copy of all,such documents.
b.
Identify the, information in the..docu-ments which supports your contention.
c.
Explain how such information provides a basis, for your contention'.
4.
Is the allegation based upon research?
If so:
a.
Describe all such research and provide a copy of any documents describing or reporting on such research.
b.
When was the research conducted?
c.
By whom was the research conducted?
, ~
d.
=- Explain how such research provides a
basis for your -contention.
- 5. 's the allegation, based upon conversations, consultations, correspondence or any other type of communications with individuals?
Ig so:
a.
Identify by name and address all such individuals.
b.
State the educational and professional background of such individuals, includ-ing occupation and institutional affil-iations.
c.
Describe the nature of the communications with such individuals, when it occurred, and identify all of the individuals in-volved.
d.
Describe the information received from such individuals and explain how it pro-vides a basis for your contention.
e.
Furnish copies of all letters, memoranda,
'tapes, notes or other records related to conversations, consultations, correspon-
- dence, or other communications with such C
individuals.
6.
Provide the identity and location of all
.persons having knowledge which would tend to support or deny the allegations 'in your contention.
7.
In your answers to Interrogatories 1-6
- above, explain how the factual basis for the allegation relates specifically to the Cook facility.
B.
Specific Interrogatories Related to Contentions In the July 28, 1972, Petition to Intervene of Brooks et-al..
Please respond to the following interrogatories as they relate to the contentions in your July 28, 1972, Petition to Intervene.
- 1. Contention No.
17 a
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation in the contention that the temperature differential between the thermal discharge and the receiving water willresult in.massive 'fish 'kills off-"si't'e the Plant.
Please include in your answer an indentification of the species of fish b;
you believe will be killed and the reasons why they will be unable to avoid the alleged lethal conditions.
Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
'I
c ~ Please answer general interrogatories A.l I
through A.'.7. with respect to each'allega-tion 'in the contention.
2 ~ Contention No. 17 b I'
Please state.in detail all the facts and infor-mation in your possession which form the basis for your allegation or allegations in the con-tention, including but not limited to, the allegations that the heat transmitted to'he receiving water from the thermal discharge will result in algal blooms in the near-shore areas of Lake Michigan surrounding the Plant, that the type of algae which will occur in an exploding fashion will be blue-green types, that such algae will produce noxious characteristics in the receiving water, and that such algae make said water unpleasant for recreational uses in the summer.
- b. Please provide your source for such facts and information and explain in detail why. you believe such. facts and information support the allegation or allegations.
r
h
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
3.-Contention No.
17 c
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to the allegations that the rise in the tempera-ture of the receiving water due to the thermal discharge from the proposed'pa~ycle cooling system will result in inhibiting the spawn-ing of certain species of fish in the Lake, including smelt and other sport species, that these species will only spawn within a limited range of temperatures, and that this range will be exceeded by the alleged temperature rise caused by the thermal dis-
'charge.
Please include in your answer the various species of fish which are referred to in the contention, the source of your allegation that spawning will occur in the thermally influenced area of the Lake, and C
the temperature range which is referred to in the contention for'ach species.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
Contention No. 17 d
- a. Please state in detail all the facts and infor-mation in your possession which form the basis for your allegation or allegations in the con-tention, including, but not limited to, the al-legations that there are certain species of fish which migrate in the near-shore areas of Lake Michigan (please identify these species of fish), that the temperature differential between the thermal discharge from the plant effluent and the receiving water will cause a thermal shock, that the young of the species of fish which migrate in the near-shore areas of Lake Michigan will be unable to withstand
such thermal shock, and that this will result in"interruptions of patterns of migration and reduction of population of these species in the Lake.
- b. Please provide your source for such facts and information and explain in detail why you believe such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A..7 with respect to each allegation in the contention.
Contention No. l7 e
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that Lake Michigan is in a critical state with respect to eutrophication, that one of the principal indications of rapid eutrophication of a lake such as Lake Michigan is decreased oxygen content, that the addition of heat to water will cause a decrease in the oxygen content through a rapid explosion in the varieties of certain minute organisms and the
synergistic effect of the heated effluent with existing, pollutants 'in. the receiving water.
Moreover, please specify the degree to which you allege that oxygen content will be decreased in Lake Michigan due. to the opera-"
tion of the Cook Plant, identify the "certain minute organisms" and existing pollutants in the receiving water, and explain chemically and biologically how the alleged decrease in oxygen content will result from operation of the Cook Plant.
- b. Please provide your source for such facts and information and explain in detail why you believe such facts and information sup-port the allegation or allegations.
- c. Please answer general interrogatories A.l through A..7
. with respect to each allega-tion in the contention.
- 6. Contention No. 17 f
- a. Please state in detail all the facts and,in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that the thermal plume created
by the discharge from the open-cycle cooling system will, the majority of the time, approx-
,imate an area of lake thousands of acres in size running in a general north-south direc-tion with the shoreline, that the existence of this thermal ~lume in the'winter will. re-sult in the melting of shore ice, that such shore ice is the chief protection against wind and water erosion during the winter months of the year, that the melting of this ice barrier will result in a rapid increase in erosion during the winter months (please specify the amount of erosion involved),
and that such all'eged erosion will result in destruc-tion to Petitioners'roperty.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations. "
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
7.
Contention No. 17(h).
a.
Please state in detail'll the facts and information in your possession which form the basis for'our allegation or allegations in the contention, including,"
but not limited to, the allegations that certain undesirable species of, fish, particularly alewives (please identify the other species of fish referred to) will be attracted to the thermal plume from the Cook Plant, that an alewife die-off will occur, that such alewife die-off will be substantially increased in the area of the plant and that such die-off will result in an undesirable deposit of dead fish on the Petitioners'roperty.
b.
Please provide your source for;such facts and information and explain in detail why you believe such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7
. with respect to each allegation in the contention.
- 8. Contention No. 17 i
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that literally millions of micro-organisms existing in the Lake (please ident'ify these micro-organisms) constitute the lower steps of. food chain cycles, that these micro-organisms will be drawn across the condenser with the intake water and killed, that this process will have the effect of reducing the desirable micro-organisms in the Lake from the standpoint of the food chain, that this will result in millions of dead organisms, and that this will contribute to the rapid eutrophication of the area of
Lake Michigan near the plant..
Please include in your answ'er an'xplanation of how and to what extent the" "desirable micro-organisms" will be reduced and how and to what extent "rapid eutrophication" will be enhanced.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the the allegation or allegations.
- c. Please answer general interrogatories A.l
-through A.
. with respect to each allegation in the contention.
- 9. Contention No.
17
- a. Please state in detail all the facts and information in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that certain species of fish (please identify these species) will be
attracted in winter,to the warmer water within the thermal,di,scharge, that these species will then require the approximate temperature of the thermal plume in the winter months in order to survive, and that the shutdown of the plant will result in cold water shock which would result in massive fish kills in the area of the plant.
- b. Please provide your source for such facts and information and explain in detail why you believe such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
- 10. Contention No. 17 k
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to,
the allegations. that the temperature of the thermal discharge will result in a rapid in-crease in undesirable'filamentous green E
- algae, and that this will make the area in the near-shore area of Lake Michigan undesirable for recreational uses in the summer.
- b. Please provide your source for.such facts and information and explain in detail why you believe such facts and information sup-port the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
ll. Contention 17 1
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the
[181 allegations that juvenile yellow perch and alewives are frequently found in the in-shore
.area, that smelt spawn in the near-shore area and tributary streams, and that the habits of these small juvenile fish will result in there being fish kills particularly affecting the juvenile of these species.
Please provide all facts and information which form the basis of your allegation that such juvenile fish and spawning activities occur in the vicinity of the Cook Plant.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support h
the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allega-tion in the contention.
- 12. Contention No. 18.
- a. Please identify and describe all of the aspects of Applicants'reoperational environmental monitoring program which you allege to be
"seriously deficient in scope and in methodology" and explain how such aspects
.are deficient.
- b. Please identify all "outdated and out-moded information and invalid assumptions" upon which you allege Ay~licantsprogram is based.
- c. Explain and describe all instances in which the program fails to "adequately picture the existing environment in the area of the plant to provide a base on which to
)udge the effect of the plant in Lake Michigan".
- d. Explain and describe all instances in which the program fails to "adequately predict the effect of the thermal effluent or other environmental effects of the plant (describe such other environmental effects) on the immediate environment".
- e. Identify the lake maps which you allege are inaccurate.
- f. In what respects are the lake maps inaccurate'?
- g. Exactly how and by whom have the lake maps--
been discredited'?
- h. Explain and describe all instances in. which the data concerning the near-,shore bathymetry is "incomplete, inadequate, and inaccurate."'xplain and describe all instances in which the studies fail to adequately or accurately assess the effect of the bottom topography of Lake Michigan on water current movements.
Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, and in your answers to inter-rogatories a-i above, including, but not limited to, the allegations that the environmental monitoring programs, particularly those car-ried out in the Benton Harbor Limnological
- Studies, are seriously deficient in scope and methodology, that they are based on out-dated and out-moded information and invalid assumptions,,that they fail to adequately picture the existing environment in the area of the plant to provide a base on which to
)udge the effect of the plant on Lake Michigan, that they fail to adequately predict the effect of the thermal effluent or other environmental effects of the plant on the immediate environment, that the heat; imparted to the receiving water will tend to accumulate in the lake at times when the temperature of the lake is higher than the air tempera-ture over the water, that studies of the behavior of the thermal discharge fail to assess the water-air heat transfer under wave condi'tions other than essentially calm con-ditions, that the monitoring program is based on a study which was based on lake maps which are inaccurate and which have been discredited prior to the time they were submitted, that the data concerning the near-shore bathymetry is incomplete, inadequate and inaccurate, and that the thermal discharge studies fail to adequately or accurately assess the effect of the bottom topography of Lake Michigan on the water current movements with the result
that, the predictions of the thermal plume behavior are inaccurate.
- k. Please provide your source for such facts and information and explain in detail'hy you believe such facts,and information sup-port the allegation or allegations.
- 1. Please answer general interrogatorie's A.l through.A.7 with respect to each allegation in the contention and your answers to inter-rogatories a-i. above.
- 13. Contention Mo. 19.
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations 'in the contention, including, but not limited to, the allegations that there will be a long-term buildup of dissolved solids over the life term of the plant, that such long-term build-up of dissolved solids will be caused by the Cook Plant, and that the combined effect of the buildup and the heat from other plants will "most rapidly speed up eutrophication".
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l thr'ough A.7 with respect to each allegation in the contention.
- 14. Contention No. 20.
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to,
'he allegations that under certain wind and
~ water conditions the thermal plume will reach and contaminate the potable water intakes for water supplies in the area, that the effluents reaching these intakes will contain levels of radiological and non-radiological impurities (please elaborate on the identity and amount of all radiological and non-radio-logical impurities that allegedly will be pre-sent),
and that these impurities will be harm-ful to the public health.
~~ 7.,',.-;;;:~~4
[24 ]
- b. Please provide your source for such facts and allegation or allegations'.
C ~ Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
- 15. Contention No. 21.
information and explain in detail-why you be-lieve such facts and info'rmation support the
- a. Describe and explain the relationship between the conversion of chlorine to chloramines and the "level of eutrophic conditions of Lake Michigan in the Bridgman area."
- b. What is the "level of eutrophic conditions of'ake Michigan in the Bridgman area
- c. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention and in your answers to.Xnterroga-tories a and b above, including, but not limited to, the allegations that "given the level of eutrophic characteristics in the Bridgman area" the chlorine to be discharged by the Cook Plant may be converted into
chloramines, that the chloramines will spread into dozens of square miles of the Lake, and that this will induce avoidance behavior in advanced species (please identify the species) and decimate benthic invertebrates (please'dentify-0'e species)'.
Please specify in detail any contention you'may have with respect to NA2SOg and state in detail the facts and information which form the basis for all allegations in such contention.
- d. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- e. Please answer general interrogatories A.l through A.7'ith respect to each allegation in the contention and your answers to inter-rogatories a and b above.
- 16. Contention No. 22.
- a. Describe and explain in detail how Applicants'ethod of thermal plume dispersion will be completely invalidated.
- b. Please state in detail all the facts and in-formation.in your possession which form the basis for your allegation or allegations-in the contention and in your answer to inter-rogatory a above, including, but not limited to, the allegations that the structures which Applicants have installed-extending into the near-shore areas of Lake Michigan, par-ticularly a cofferdam and a temporary harbor, have resulted in a disruption of the along-shore currents in the near-shore environment of the Lake, that this alleged, disruption has resulted in the creation of turbulent currents and the "piercing of-the sensuous, along-shore sandbars",
that the disruption of 'currents and creation of transverse channels in. the along-shore bars has resulted in the complete invalidation of Applicants'tated'ethod of thermal plume dispersion, and that the creation of transverse channels and turbulent currents in conjunction, with the prevailing offshore winds will result in visiting all of
f27]
the undesirable effects of heated effluents as "described in Contention 17, on the beaches and dunes, of Petitioners'roperty.'c.
Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- d. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
- 17. Contention No.
2
- a. Please describe the alleged "disruption" of the near-shore environment caused by the con-struction of the Lake structures.
- b. Please describe the extent of the "massive erosion damage to the beaches and dunes on Petitioners'roperty."
- c. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention and in your answer to inter-rogatories a and b above, including, but not limited to, the allegations that the
structures referred to in Contention 22 have resulted in a disruption of the near-shore environment, that this alleged disruption has caused massive erosion damage to the beaches and dunes on Petitioners'roperty and that this has resulted in severe economic harm to Petitioners, which will continue as long as the structures remain in the Lake.
- d. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- e. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention and your answers to inter-rogatories a and b above.
- 18. Contention No. 25.
- a. Please describe and explain in detail the alleged negative reaction of heat from the plant and chemical elements in the Lake.
- b. Please describe and explain in detail the alleged impact o'f such reaction.
'I
- c. Please describe and explain in detail the alleged reaction "as has.
happened at the Big Rock Point Nuclear Plant".
- d. Please state in detail all the facts and infor-mation in your possession which form the basis for your allegation or allegations in the contention, and in your answers to inter-rogatories a-c above, including, but not limited to, the allegations that the heat in the effluent will react negatively with the chemical elements in and at the bottom of Lake Michigan at the point of discharge of the effluents, and that this has happened at the Big Rock Point Nuclear Plant at Charlevoix, Michigan.
- e. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- f. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention and your answers to inter-rogatories a-c above.
l9. Contention No. 26.
- a. Please describe in detail the nature an'd extent of the alleged "adverse erosional effect on the properties to the south of the Cook Plant" caused by the seawall.
- b. Please state in detail all the facts and in-formation in your possession which form the basis for your allegations in'he contention and in your answer to interrogatory a above that the seawall which. Applicants intend to construct at the shoreline in front of the Cook Plant site will have an adverse erosional effect on properties south of the Cook Plant site.
- c. Please provide your source for such facts and information 'and explain in detail why you be-lieve such facts and information support the allegation.
- d. Please answer general interrogatories A.l through A.7 with respect to the allegation in the contention and your answer to inter-rogatory a above.
- 20. Contenti'on No. 27.
Please. state in detail all the facts and in-formation in your. possession which form the basis for your.allegation or allegations in the contention, including, but not limited to, the allegations that Applicants have installed a cofferdam and temporary harbor structures in violation of applicable State and Federal law and that the permits obtained for the con-struction of these structures are void and of no force and effect for lack of statutori.ly required findings and for lack of valid com-pliance with State law.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
- 21. Contention No. 28.
- a. Please state in detail all the facts and in-formation in your possession which form the
basis for your allegation or allegations in the contention, including,= but not limited to, the allegations that the sampling methods used at the Palisades study are inadequate, that such sampling methods arbitrarily refuse to consider species which comprise less than.gg of the total'ish samples, that this alleged arbitrary refusal results in ignoring 20 of 28 species found (please identify species) and a failure to consider the environmental impact of the plant on species which may permanently or temporarily be rare or endangered in the area of the Cook Plant, and that this sampling technique is inadequate to assess the environmental impact on the fish popula-tion in the area of the Cook Plant.
- b. Please provide your source for such facts and information and explain in detail why you believe such facts and information sup-port the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
f333
- 22. Contention No.
29
-a. Describe and explain the specific as-pects of Applicants'reoperational study programs with respect to biologi-cal organisms in the water offsite of the Cook Plant that are inadequate and explain why they are inadequate.
- b. Identify the referenced biological organisms.
- c. Describe in detail the "subtle effects of the significant changes in the en-vironment" which you allege "will, in all probability, be caused by the plant's effluent."
- d. Please state in detail all the facts and information in your possession which form the basis for your allega-tions in the contention and in your answers to interrogatories a-c above.
e.
Please provide your source for such facts and information and explain in
L34j detail why you believe such facts and information support the all'egations.
- f. Please answer-general interrogatories A. l through A.7 with respect Co the allegation in Che contention and.your answers Co interrogatories a-c above.
- 23. Contention No.
30
- a. Please state in detail all Che facts and information in your possession which..form Che -basis for your.allega-Cion or allegations in the contention',
including, but not limited Co, Che allegations Chat, with respect; Co the radiological monitoring and surveil-lance programs planned by Che Appli.
- cants, Chere are Coo few monitoring.
- sites, the monitoring data is not collected frequently enough to be useful and informative, Che type of monitoring proposed will hot de-termine Che concentrations and
biological magnifications of ma)or. radio-nucleides in animal and plant life and terres-trial and aquatic food chains in'the vicinity of the plant, that the proposed instrumenta-tion for monitoring is not adequate, that it wi11 result in giving a false picture of the plant's emissions, that there is no assurance in the proposed monitoring program that all the radio-nucleides of significance to terrestrial, aquatic and human life will be regularly monitored in a manner sufficient to detect hazards before they have already had a signi-ficant deleterious effect, and that such radio-logical monitoring program is insufficient to protect the health and safety of the public.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
[36]
2l. Contention No. 31.
Please state in detail all the facts. and infor- "
mation in your possession which form the. basis for your allegation or allegations in the contention, including, but not limited to, the allegations that the radiological moni-,
toring program is insufficient in that it fails to adequately assess the buildup of low levels of radioactivity over the 40-year period of the plant in the aquatic or terrestrial en-vironments and that it fails to adequately assess the impact of.low B.evel radiological releases on the various food chains which exist in the immediate environment of the plant
- b. Please provide your source for such facts and information and explain in detai,l why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l, through A.7 with respect to each allegation in the contention.
. 25. Contention No. 32.
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation in the contention that there is no need by Indiana
% Michigan Electric Company to have the Cook Plant in
service in order to adequately service its customers.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7
. with respect to each allegation in the contention.
- 26. Contention No. 33.
Please state in detail all the facts and in-formation in your possession which'orm the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that Applicants'nalysis of pro)ected load forecast overstates the future
industrial growth of the Company's service area, that there will be a leveling-off of demand and that Applicants'nalysis fails to take this into account.
- b. Please provide your source for. such facts, and information and explain in detail why you believe such facts and information sup-port the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allega-tion in the contention.
Contention No. 34.
Please state in detail all the facts and information in your possession which form the basis for your allegation in the con-tention that 'Applicants'nalysis of pro-jected load forecast is unsound in that it fails to adequately assess the environmental b.
impact or the projected capabilities of al-ternate sources o'f power.
Please provide your source for such facts and information and explain in detail why
you believe such facts and information sup-port the allegation.
- c. Please answer general interrogatories A.l through A.7 with respect to the allegation in the contention.
'28.- Contention No. 35.
- a. Please state, in detail all the facts and information in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to., the allegations that the demographic pro-jections used by Applicants overstate the population trends, that there will be a
leveling-off and downturn in certain demo-graphic factors affecting population growth,
'I that Applicants'emographic projections fail to recognize. this alleged leveling-off and L
downturn, that Applicants 'nalysis'f pro-jected load forecasts was based on a 1967 projection of peak winter demand for 1972, and that this causes the analysis to be defec-tive.
- b. Please provide your source for such facts arid information and explain in detail why you believe-such facts and information sup-port the allegation or allegations.
- c. Please answer general interro'gatories A.l through A.7 with, respect to each allega-tion in the contention.
- 29. Contention No.
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that Applicants'nvironmental report is inadequate and misleading in its assessment of the impact of alternative cool-ing water systems and that the environmental effects of alternative cooling systems such as mechanical or natural draft cooling towers will have significantly less impact on the en-vironment than the proposed once-through cool-ing system.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention.
- 30. Contention No. 37.
- a. Please state in detail all the facts and information in your possession which form the basis for your allegation or allegations in the contention, including, but.not limited to, the allegations that the design of the present open-cycle cooling system does not utilize the best available technology to dif-fuse the heat from the thermal effluents and that Applicants'nvironmental report and sup-plements admit the failure to have complete studies of alternative designs.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each-.allegation in the contention.
- 31. Contention No. 38.
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that the Michigan Depart-ment of Natural Resources emphatically objects to the thermal discharges from the Cook Plant, that lake trout and chinook will concentrate in the immediate area, that coho salmon will use this area for spawning rather than migrating north within Lake Michigan and that all of these fish species will be subjected to thermal shock and cold water shock.
Please
- provide, and give the factual basis for, any, allegations you may have with respect to the nature and extent of the adverse impact to which these species will be subjected.
- b. Please provide your source for such facts and information and explain in detail why you be-'ieve such facts and information support the allegation or allegations-.
- c. Please answer. general interrogatories A.l through A.7 with respect to each allegation in the contention.
- 32. Contention No.
3
- a. Please state in detail all the'facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that there will be radioactive wastes discharged diluted in the thermal effluent which will have an impact on Petitioners'ells and that there will be a subsequent invasion of Petitioners'ells by dangerous long-lived radionucleides in the ground water, making Petitioners'ater supply unfit for drinking.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
'I
- c. Please answer general interrogatories A.l through A.7 with r'espect to each allegation in the contention.
'3. Contention No. 40.
- a. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that the radionucleides refer-red to in Contention No.
39 will find their way into the aquatic food chains and that Applicants'adiological monitoring program fails to assess or monitor the buildup of these radionucleides in fish and other aquatic life forms in Lake Michigan.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A. 7 with respect to each allegation in the contention.
- 34. Contention No..4l.
- a. Please state in detail all the facts and in-formation in your possession which form the I
basis for your allegation in the contention that Applicants'mergency plan is insuf-ficient. in its provision for protection of members of the -public offsite of the Cook Plant.
- b. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through.A..7 with respect to each allegation in the contention.
3 instance where you allege that the ECCS fails to meet the Commission's Interior Acceptance criteria.
- 5. Contention No.
42.
- a. Please identify and explain in detail each
'. Please identify and explain in detail each instance in which you allege that the ECCS is "inadequate and unsafe f'r other reasons."
- c. Please state'n detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention and. in your answers to interrogatories a and b above, including, but'ot limited to, the 'allegations that the emergency core cool-ing system is inadequate and fails to meet the interim acceptance criteria for emergency core cooling systems and that the ECCS is also inadequate and unsafe for "other reasons".
- d. Please provide your source for such facts and
,information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- e. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention and your answers to interroga-tories a and b above.
- 36. Contention No.
43.
- a. Please identify. and explain in detail the "numerous other aspects in which the con-struction and design of the Cook Plant fail to meet the nuclear safety requirements of the Atomic Energy Act of the Commission's regula-tions and accepted design construction procedures."
f47]
- b. Please state in detail all the facts and in-formation in your possession which form-the basis for your allegations in the contention and in your answer to interrogatory a above, S
including, but not limited to, the allegation that there are numerous other respects in which the construction and design of the Cook Plant.
faQ. to meet the nuclear safety requirements of the Atomic Energy Act, of the Commission's regulations'nd accepted design construction procedures.
- c. Pl'ease provide your source for such'acts and information and explain in detail why you oe-lieve such facts and information support the allegation.
d..Please answer general interrogatories A.l through A.7 with respect to the allegation in the contention and your answer, to inter-I rogatory a above.
- 37. Contention No. 44.
- a. Please identify the earthquakes "of an intensi.ty of those which have occured in the continental
[48j United States within the past few years" which.you allege will rupture the con-tainment.
- b. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation in the contention that there have been inadequate seismic and geological studies to determine the ability of the Cook Plant to withstand an earthquake of an intensity of those which have occured in the continental United States within the past few years and the implied allegation that such an earthquake might result in a rupture of the containment and consequent release of large amounts of radioactivity to the environment.
- c. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation.
- d. Please answer general interrogatories A.l through A.7 with respect to the allegation in the contention and your answer to inter-rogatory a above.
- 38. Contention No. 45.
'a. Please identify and explain in detail all specific instances in which the "quality assurance program of Applicants at the Cook Plant and the quality control exercised with respect to conduct of construction" has been inadequate and fails to comply with the require-ments of the quality assurance criteria in Appendix B to Part 50 of the Commission's re-gulations.
- b. Please state in detail all the facts and in-formation in your possession which form the basis of all of your allegations with respect to this contention, including your answers to interrogatory a above.
- c. Please provide your source for such facts and information and explain in detail why you believe such facts and information support your allegations.
- d. Please answer general interrogatories A.l through A.7 with respect to each of your allegations.
[~gal
- 39. Contention No. 46.
ao Please identify and,explain in detail all specific instances in which proper supervision has not been provided over 'construction crews in the installation of piping.in the nuclear.
system; all specific instances in which im-proper and incorrect pipes have been installed; and all specific instances in which adequate information with respect to the installation of'umerous systems in the plant has not been provided.
Include all specific details, including names of individuals, dates, and specific defects in specific systems.
- b. Please state in detail all the facts and in-for'mation in your possession which form the basis for your allegation or allegations in the contention and in your answer to inter-rogptory a above, including, but not limited to, the allegations that Applicants'uality control organization has failed to provide pro-per supervision over construction crews in the installation of piping in the nuclear steam
system resulting in the installation of im-proper and incorrect pipes at times and that it has failed to provide adequate information with respect to the inst'allation of numerous systems in the plant.
- b. Please prov~6e;.~~~uce for such facts and information.wad e~lwxw.mm detail why you be-lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention and your answer "to inter-rogatory a above.
- 40. Contention No. 47.
a..Please identify and explain in detail'all specific instances in which supervisors qualified to oversee the construction of sensitive nuclear safety systems within the plant have not been provided.
Include all specific details, in-eluding names of i.ndividuals, dates, identifi-cation of systems, and results of such failure to provide adequate supervision.
- b. Please state in detail all the facts and information.in your possession which form the basis for your allegations in the contention and in your answer to interrogat'ory a above that Applicants'uality assurance program has failed-M'="pr~e".~~"gervi'sors qualified to oversee the construction of sensitive nuclear safety systems within the plant.
- c. Please provide your source for such. facts and information and explain in detail why you be-lieve such facts and information support the allegation.
- d. Please answer general interrogatories A.l through A.7 with respect to the allegation in the contention and your answer to interroga-tory a above.
- 41. Contention No. 48.
- a. Please identify and explain in detail all speci-fic instances in which the failure to provide specific direction to quality assurance person-nel resulted in "numerous occasions of con-fusion of duties between the day crew and night crews on the construction of the Cook
Plant"; in "instructions being ignored";
and in "reports. falsified.with respect to work performed."
Include all specific details, including dates, names of individuals, and identification of falsified reports,.ignored
'nstrucCians'"~5'.m'Z~~MM work.
- b. Please state in QetaXl a%1 the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention and in your answer to inter-rogatory a above, including, but not limited to, the allegations that Applicants'uality assurance program has not provided specific direction to quality assurance personnel,.
that this alleged failure has resulted in numerous occasions of confusion of duties between the day crews and night crews on the construction of the plant, and that this al-leged failure has resulted in instructions being ignored and reports falsified with respect to work performed.
- c. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention and your answer to inter-rogatory a above.
- 42. Contention No.
4
- a. Please identify and explain in detail each specific instance of construction practices which have resulted in construction inadequacies and identify and explain in detail said con-struction inadequacies.
- b. -Please state in detail all the facts and information in your possession which form the basis for your allegation or allegations in the contention and in your answer to inter-rogatory a above.
- c. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support your allegations.
- d. Please answer general interrogatories A.l through A.7'ith respect to each allegation N
in the contention and in your answer to in-terrogatory a above".
- 43. Contention No.'.
a.
P3.ease identify and explain in detail each
'c instance where, in the construction of numerous safety systems in the plant, welds have not been properly documented and/or inspected.
Provide all specific details, in-eluding names of individuals, dates, identi-fication of specific welds on specific
- systems, etc.
- b. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention and in your answer to inter-rogatory a above, including, but not limited to, the allegations
+hat in the construction of numerous sensitive systems in the plant, welds have not been properly documented and that this has resulted in the failure of numerous welds to be inspected by Applicants
or AEC personnel, and that these welds include Class l (nuclear safety) welds.
- c. Please provide your source for such facts and'nformation and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- d. Please answer general interrogatories A.l through A.,7 with respect to each allegation in the contention and your answer to inter-rogatory a above.
- 44. Contention No. 5l.
- a. Please identify and explain in detail all instances in which "welds have been documented and reports submitted on same prior to the time piping on which said welds supposedly I
had been made had even been installed."
Pro-"
vide all specific details, including names of individuals, dates, and specific identification of welds,
- systems, and reports.
- b. Please state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in in the contention and in your answer to inter-rogatory a above, including, but not limited
to, the'allegations that in at least one instance welds have been documented and reports submitted on same prior to the time piping on which said welds.supposedly had been made had even been installed.
- c. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation or allegations.
- d. Please answer general interrogatories A.l through A.7 with respect to each allegation in the contention and your answer to inter-rogatory a above.
- 45. Contention No. 52.
- a. Please identify and explain in detail all instances in which inadequate welding on partic-ular systems has been called to the attention of Applicants and such systems have been re-paired in patchwork fashion, resulting in the creation of weaknesses in the construction of critical nuclear safety-related systems.
Provide all specific details, including names
1 of individuals, dates, identification.of
specific welds on=specific
- systems, etc;
- b. Please state in'detail all the facts and in'-
formation in your possession which form the basis for your allegation or allegations in the contention and in your answer to in-terrogatory a above, including, but not limited to, the allegations that there has been inadequate welding on particular
- systems, that this alleged inadequate welding has been called to the attention of Applicants, that said systems have been repaired in a patchwork fashion, and that this has re-sulted in the creation of weaknesses in the construction of critical nuclear safety-re-lated systesm.
- c. Please provide your source for such facts and information and explain in detail why you believe such facts and information sup-port the allegation or allegations.
- d. Please answer general interrogatories A.l through A..7 with respect to each allegation in the contention and your answer to inter-rogatory a above.
t 59]
- 46. Contention No. 53.
- a. Plea'se state in detail all the facts and in-formation in your possession which form the basis for your allegation or allegations in the contention, including, but not limited to, the allegations that Applicants'tate-ment that long-term arrangements for large blocks of power on the order of several thousand megawatts are "neither practical, economical nor available" is false and that there is no reason to believe that purchase of such large blocks of power would be necessary to meet load demands.
- b. Please provide your source for such facts. and information and explain in detail why you be-I lieve such facts and information support the allegation or allegations.
- c. Please answer general interrogatori,es A.l through A.7-. with respect to each allegation in the contention.
- 47. Contention No. 54.
- a. Please state in detail all the facts and in-formation in your possession which form the
[6o]
/
basis for all of the allegations in your contention, including the allegations that heated water in'plumes frequently dives bec'ause of sub-surface configuration and other fac-tors that are imperfectly known at this time and that this phenomenon has been documented by a secret aerial infra-red photograph study
'one for Consumers Power Company concerning the Big Rock Nuclear Plant by the University of Michigan Willow Run Laboratories.
- b. Please provide your source for such -facts and information and explain in detail why you be-lieve such facts and information support the allegation.
- c. Please answer general interrogatories A.l through A. f'ith respect to the allegations in the contention.
- 48. Contention No. II.3.
- a. Please describe, in detail all damage (1) which has been suffered to date by Petitioners and (2) which Petitioners expect to suffer in the N
future if the construction permits are not conditioned, modified or terminated.
- b. Identify all of the damages which will be, irreparable and explain how such damages will be irreparable.
- c. Please state in detail all the facts and in-'-
formation in your possession which form the basis for your allegation or allegations in the contention and in your answer to inter-rogatories a and b above, including, but not limited to the allegations that Petitioners have suffered extensive damage to their real property from the past and present construction practices of Applicants, specifically from the construction of facilities offshore of the
- plant, and from other construction practices of applicant, and that unless the construction permits are appropriately conditioned, modi-fied or terminated, they will continue to suffer damage, which damage will be irreparable in part.
- d. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support tne allegation or allegations.
[62]i
- e. Please answer general interrogatories A.l through A.:7'ith respect to each allega-tion in the contention and your answers to interrogatories
'a and b above.
- 49. Contention No. iX.4.
- a. Describe in detail all irretrievable com-mitments detrimental to environmental values which will be made if the construction permit is not modified or conditioned.
- b. Please state in detail all the facts and in-formation in your possession which form the basis for your allegations in the contention and in your answer to interrogatory a above, including, but not limited-to, the allegations that unless the construction permits are ap-propriately modified or conditioned to resolve the radiological and environmental considera-tions stated herein, irretrievable commitments of resources will be made which are detrimental to environmental values.
- c. Please provide your source for such facts and information and explain in detail why you be-lieve such facts and information support the allegation.
[63]
- c. Please answer general interrogatories A.l through A.i'ith respect to the allegation in the contention arid your answer to inter-rogatory a above.
II.
REQUEST FOR DOCUNENT
'Applicants req'uest that Intervenors Brooks et al. produce for Applicants'se, or produce and permit Applicants to inspect and copy, at a specific time and place and 'in'a mariner to be agreed. upon, all of the docu-ments requested in Section I above.