ML18283A556

Intervenors Answers to Interrogatories of the Applicant

ML18283A556
Person / Time
Site:	Browns Ferry
Issue date:	05/14/1976
From:	Garner W Atomic Safety and Licensing Board Panel
To:	Atomic Safety and Licensing Board Panel
References
Download: ML18283A556 (13)

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i Before the Atomic Safety and Licensing Board

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In the i'1atter of TENNESSEE NLLEY AUTHORiTY

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Brooms Ferry Nuclear Plant

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(Units 1 and 2)

)

Oocket Nos.

50-259 go-26O INTER'lBiOR'S ANS':ERS TO DJTKPRCGATORXi 3 01'HE APPLICANT

't!,'ithout waiving his right to ob)ect to their admissibility into evidence, Intervenor makes the followed.ng ans.iers to the interrogatories of the Applicant.

1. (a) At the present time the f: ctu al bases are:

NZLPIA L<epoit dated May 1975.

15 pages plus attachments.

NELPXA Interoffice Communitcation from John J.

C rney-Farmington, Proposed Heeting on Fire Protection for "able

Systems, dated O'Iay 23, 1975.

Letter from Ralph Nader to ':/illiam Anders, dated. August 13, 1975.

Memorandum to Browns Ferry File, Meeting with NZlPIA, June

. 26,

1975, from Stephen H. Hanauer, dated July 10, 1975, with Appendix.

(b)

On May 3, 1976, Intervenor ob,jected to this Interrogatory as follows, "the system names end identity of the "Engineered Safe-guards Equipment" are more 'ailable to Applicant than they are to Intervenor."

{o)

On Hay 5, 197$, Intervenor objected to this Interrogatory as follows, "it is not Intervenor's job to define technical terms for the Applicant."

(d)

See documents cited in answer to 1a.

(e)

The consequences wculd be future fires which mi.";ht cause damage resulting in situations ranging from a short outage to a core meltdown, (f)

At the present time see documents cited in 1a.

The brevity of the documents precludes the necessity of cit;ing sections or pages.

/f (g)

At the present time, Xntvenor is studzng the documents cited

/a in answer to 1a.

He is also attempting to obtain addition,.l information and documents.

(h)

Intervenor has begun communications with Ralph Nader, Gregory C. Minor, and the Union of Concerned Scientists.

Intervenor r

has not made a decision as to what experts and others he intendes to have testify with reg,ard to contention 1.

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2. (a)

See answer to Applicant s Interrogatory 1f.

(b)

See answer to Applicant's Interrogator.

1g.

(c)

See answer t;o Applican!,"s Interrog tory 1h.

(d)

Yes.

See answer to Applic nt's ~nterrog;.to y 1a.

(e)

This Interrogatory is really too vague to be answered.

The advantages would'e to help prevent 'future fires which might cause damage resulting in situ::tions ranging from a short outage to a core meltdown in both Units 1

and 2 at the same time.

(a)

See answer to Applicant's Interrogatory 2a.

(b)

See answer to Applicant's Interrogatory 2b.

(c)

See answer to Ap;~licant's Interrogatory 2c.

(d)

Yes, because it would aid. in fighting future fires.

Intervenor's inspection of the cable spreading room reinforces the opinions reached by others.

See answer to Applicant's Interrogatory 1 a

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(e)

The gener'1 criteria are adequate'pace to work with the 5/2.

cables, to put out fires, and for average or above-average human

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-beings to move around in

!;he cable spreading room.

(f)

~ee answer to Applicant's Interrogatory 2e.

{a)

See answer.

to Applicant's Intex'.rogatory 2a.

(b)

See answer to App3ic, nt's Interrog:story 2b, (c)

See answer to Applicant's Interrogatory 2c.

(d)

Yes.

See answer to Applicant's Interrogatory 1a.

(e),(f), and (g)

On i!ay 5, 1976, intervenor objec!;ed to this Interrogatory as fol:!ows "it is'not ~ntervenors role to.do research for Applicant that "pplic"nt should do'tself'- as to what type of cable insulation current3y manuf."ectured does not liberate corrosive

gases, ideqifica tion of

".he "pecific typos of c.;bles 'and their respective manufacturers, and wheth':r such cables are uitable for use in the 3rowns cherry Nuclear Plant, "nits 1 and 2."

(h)

In the event that the fire retardant m'teri'1 does not work personal~ attempting to put out future fires will be safer and can fight the fires 'better.

i'iso the outage would be less since the damage to the plant would be less.

5. {a)

See answer to Applicant's Interrogatory 2a.

(b)

See answer to '"pplicant's lnterrogat;ory 2b.

(c)

"ee answer to Applicant's Interrogatory'c.

(d) and (e)

On ~'lay 3, 1976, Intervenor object,ed to this 1

interrogatory as follows,

" it is not Intervenor s role to expl in the terms "outside the fire areas" and locate the "potential fire area."

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(f)

Intervenor has not reacned a conclusion at this time on thi:.;

matter.

(g)

Intervenor has n::.t rc;ached a conclusion at this time on this matter.

(h)

On 11ay 3, l976, Intexv(.nor 'ob;jcc t;ed to this InterDgatory as follows, "this interrogatory is too pen<'.ra) and g;.rbled to respond to II I

6. (a)

See answer to 'ipplicant s interrogatory 2a.

~b)

See answer to Applicant's Interrogate;ory 2b.

(c)

See answer to i'pplicant s interrogatory 2c.

(d)

On

>>ay 3, 1976 ntervenor object;ed to this interrogatory as follows,

" the definition of "redundan',

Class IE circuits" is equally available to E~pplicsnt."

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(e)

See answer to Applicant's Interrogatory 2e.

(f) Yess, because it would aid. in fighting future fires.

See answer to Applicant's Interrogatory 1a.

7. (a)

See answer to Applicant s interrogatory 2a.

(b)

See answer to Applicant's Interrogatory 2b.

(c)

See answer to Applicant's nterrogatory 2c.

(d) and (e)

Dn "ay 5, 1976 Intervenor objected to this

'Interrogatory as follows, "explanations of the quoted terms are equally available to the Applicant."

(f) See,answer to Applicant s Interrogatory 6f.

(g)

See answer to i~pplicant's Interrogatory 7f.

Given the'robability of human error automatic systems are necessary.

8. (a) Generally, of or related. to a technique and. fitted. for a given purpose. "(ill be further defined..

(b) Capable, having requisite ability. or qualities, fit.

experience shows can do.

Gould have ability but not the qualyies to carry out. ('iill further 6efine and supplement.

(c) Ny analysis of this is not complete at this time.

7or one thing answers to certain interrogatorfhes to NHC staff and Applicant are needed.

(d.)

My analysis of this is riot complete.

Por one, prioi successful experience.

(e)

See answer to (d) above.

9 ~ (a) Safety related'ccurrences are define6 in Append.ix "A" of Intervenor's I'erfected letition for Ieave to Intervene.

They are also defined. in the 1fSIC publications referenced.

therein.

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(b) (Reference; OOE-OS-001 Iday 1974 Summary of Abnormal I.

J'ccurrencesReported to The Atomic Energy Commission During St 1975).

At page 5,

"The number of abnormal occurences reported per operating plant varied.. from a low of 1 for the Zion-2 plant, to a high of 65 for the Brown's Ferry-1 plant." One would say that Broom!'s Ferry -

1 had. an unusually large number.

(c) Xntervenor is in the process of assembling this information.

This process may be delayed by the present refusal of the NRC staff and the Applicant to answer relevant interrogatories of the Xntervenor.

(d)

See answer to Applicant's interrogatory 2a.

See also documents referred to in Appendix A to Perfected Petition.

See also OOE-08-00i referred to in (b) above.

(e)

See answer to Applicant's interrogatory 2b.

See also 9d above.

Xntervenor is also studying Qatar Ridge computer print'outs from NSXC on 1975 and 1976 to date safety related occurences.

(f) See answer to Xpplicant's interrogatory 2c.

10'a) a thing constructed deviating from the common rule, a thing constructed.

deviating in excess of normal usage, a thing I

built contrary to what was approved by the AEC, willbe further defined.

Anomalies is the plural of anomaly.

(b)

See answer to 9c above..~..

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(c) See 9 c above.

(d) See answer to Applicant~s interrogatory 2b.

(e)

See answer to Applicant's interrogatory 2c.

answer to Applicant's interrogatory 2a.See also answer

11. (a)

See answer to (b)

See answer to Applicant's Applicant's interrogatory 2a.

interrogatory 2 b.

(c)

See (d)

See answer to Applicant's interrogatory 2c.

answer to Applicant's interrogatory 7c.

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(e)

See answer to Applicant's interrogatory 7e.

(f) At the present time, no, as,to the Atlanta region.

I would want to reserve an answer as to the other regional offices.

(g) At the present time, it should be modified so as to be effective. Intervenor has not completed his analysis of this problem.

See als answer,8c above.

UNITED STATES Oi" AY&'iiICj NUCLEAR Rhx'iULATOIiX COi44ISSION Before the Atomic Safety and Licensing Beard t~

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Clima oy u<<iaioay 5

$<<a/ca cti In the -htter of TB<ibESS E VALLEY AU'I't!ORITX

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(Browns Ferry huclear Plant

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Units 1 and 2)

)

Docket

!~os. 50-259 50-260 State of Alabama

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County of "ackson

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William E. Garner, being first duly sworn>

deposes and says that he has read the foregoing interrogatories propounded by the Applicant,, that he is informed of the matters stated in the answers thereto and that the answers are true to the best of his knowledge, information, and belief.

'='.Subscr'::ed and sworn to before we., thhsf~i ~iay of a'iay, 1976.

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Nota,yc>biic, Jackson

County, Alabama Yy Commission expires (2 8

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In the i4~tter of TEi!iESSrEE VAIT "'Y AU"iiORITY Browns Ferry Nuclear Plant (Units 1 and 2)

UNITED STATES OF AiffZ(ICA NUCLE::.R iUQULiTORY CCi"EMISSION

docket, Nos. 50-259 50-260 mrs e g$ ~

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$srt Serene Sect)on CE:;TI". ICATE GF SERVICE I hereby certify that I have serveJ copies of the following document on the following by depositing them in th. United States mail, first,class, postage repaid:

I tnerve nro' nmtresto 1nterrocet cries or the t<nt~lc,".nt Genera'ounsel Tennessee Valley Authority 629 New Sprankle Building Knoxvi"le, Tennessee 37919 Qr. i!ugh C. Paxton Los Alamos Scient'fic "aboratory P.

G.

Box 1663 Los Al mos, New l!cxico 87544 Executive Legal Direct,or U. S. Nuclear Regulatory Commission

'thshington, C. 20555 Atomic Safety and 'icensing BoarJ Pa,.el U. S. Nuclear Regu" atory ~otmmission

':,'ashington, D.

Cs 2C555 Thomas h. Reilty, Esq.,

Chairman Atomic SafeRy and Licensing SoarJ Panel U. S. Nuclea Regulat.ory Commission washington, D. C. 20555 Dr. FreJerick P.

Cowan 22 Browns Lane

Heliport, New York 11713 Atomic Safety and Licensing Appea

~ Board V. S. Nuclear Regulatory <ommission

'tlashington, D ~

C ~ 20555 Secretary U. S. Nuclear Regulatory Commission'ashington,

0. C. 20555 ht,tn: acket,ing and,-:Service Station

'ihis 14th day of ifay, 1976.

Billiard> E. Garner Route 4, Box 354 Scot t sboro, Alabama 35768 (205: 574-5770)

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