ML19029A861

04/25/1979 Licensee'S Outline of Cross-Examination

ML19029A861
Person / Time
Site:	Salem
Issue date:	04/25/1979
From:	Wetterhahn M Conner, Moore & Corber, Public Service Electric & Gas Co
To:	Office of Nuclear Reactor Regulation
References
Download: ML19029A861 (10)

Text

-- ------

-~

UNITED STATES OF AMERICA  :

NUCLEAR REGULATORY COMMISSION .-

In the Matter of )

)

PUBLIC SERVICE ELECTRIC & GAS ) Docket No;: 50-272 COMPANY, et al. ) (Proposed~Issuance

) of Amendment to (Salem Nuc*lear Generating ) Facility pperating Station; Unit 1) ) License . Np. DPR-7 0)

LICENSEE'S OUTLINE OF CROSS-EXAMINATION If and to the extent that "Licensee's Objections to Intervenor's Profferred. Testimony" dated April 23, 1979, is not_ granted, the following represents Licensee's outline of intended. cros*s-examina tion:

I. Testimony of George Luchak, Ph.D.

1. Qualifications of the Witness to testify with regard to:

a. The design of commercial nuclear power plants

b. The design of the Salem Generating Station, Unit l

c. The design of fuel pools and racks, particularly the fuel pool and racks for Salem Generating Station Unit l

d. The siting, design, an~ construction of an ISFSI

e. Costs associated with the siting, design, construction and operation of an ISFSI

f. Costs associated with oper~tion of a nuclear power plant and spent fuel pool at that plant, particularly the Salem Gene.rating Station, Unit 1

~

g. Safe and. permanent disposaL of spent fuel, including technology and c0sts

h. Accident evaluation at nuc*iear power plants and spent fuel pools, particularly Salem Generating Station, Unit l~

2. Bias and prejudice of the Witness*

3. Basis*for Testimony Regarding Availability of an ISFSI as an alternative.

a. Status, design# construction or operation of all. ISFSI's

b. Capacity of proposed ISFSI's

c. Lead. time associated with siting, design. and construction of an ISFSI

d. Costs -associated with siting, design, and construction of. various* ISFSI' s and basis for calculation of such costs

e. Changes in ISFSI costs v. time

f. Operating costs of an ISFSI

g. Operating costs associated with the Salem spent fuel pool

. h. Differential operating costs at* the Salem Generating*

Station, Unit !.resulting from changing the racks

i. Facto.rs regarding need for an ISFSI, including national policy considerations

4. Basis for statements r~garding Regulatory Guide 3.24 and ISFSI regarding:

a. Siting requiremen;ts. for an ISFSI

. ~

b. Comparison to the; requirements of proposed Regulatory Guide 3.44 and proposed 10 c.F.R. Part 72

c. An ISFSI as a permanent storage facility

d. Purported U.S. poJ.icy regarding directed away-from-reactor .sto~age

e. Changes in u .. s. position after President Carter's

, position on reprocessing f *. Subsequent bias. of NRC towards a t--reactor storage

5. Basis for knowledge o~ Browns Ferry incident, including:

a *. Nature'of sources utilized

b. Type of and* time spent on research c.. Detailed. chronology of events at* Browns Ferry d.. Offsite consequences.

e. Knowledge of investigators performed

f. Differences in type of reactor between Browns Ferry and Salem Generating Station* Unit 1

g. Relationship of Browns Ferry accident to the design changes of the spent fuel pool

6. Basis for knowledge of the Three Mile Island Incident, including

a. Nature of sources of* information

b. Type of and time spent on research

c. Detailed chronology of events

d. Offsite consequences

e. Effect on the spent fuei pool at Three Mile Island Unit 2

f.

e e Differences in design between Three Mile Island Unit 2 and Salem Unit l

7. Basis for pred~cting impact of Three Mile Island Unit 2 type event on Salem Fuel Pool, including

a. Knowledge-of predicted radiation levels and contamin~~ion at various locations. at Salem Unit l as result o.f Three Mile Island Unit 2 type event

b. Knowledge of details of design and location of equipment at Salem as related to the spent fuel pool c.. Knowledge of redundant and backup fuel.. pool '~".

systems at Salem Unit l

8. Basis. for- predic.ted risk of accident. at Artificial.

Island,. including

a. Methodology and C!,Ssumptions utilized .f

b. Data utilized.

c. Accuracy of results and uncertainty  ; I

9. Basis of prediction of type of spent fuel pool accident, including a.* Assumptions utilized

b. Failure mode analysis utilized

c. Type of .contamination assumed or calculated

d. *Type and extent of instrument failures assumed or predicted

e. Assumptions or predictions as to age of fuel in

• spent fuel pool *by region

fr Assumptions or prediction as to radioactive decay of spent fuel Assumptions or predictions as to: .heat rejected by spent fuel pool h ***- Type and extent of hydrogen explosion predicted and mechanisms involved.*

i; Type and extent of "scattering" of nuclear debris- assumed or predicted j.. Type and extent of maintenance required post accident

k. Mechanism for water boil'ing off due to a break in. the cooling system

l. Assumptions regarding radioactive transport modes and predicted effects

10. Basis for statements* regarding asserted criteria for determining location for storage of spent fuel:

a. Assumptions regarding dispersion of radioactive material

b. Siting criteria for ISFSI

c. Basis for and completeness of asserted necessary information needed to site an ISFSI

11. Basis for* ultimate conclusions regarding availability of an ISFSI as* an alternative II *. Crockett Letter

l. Basis for Crockett letter, including

a. Identification of DOE letter and determination

• of basis, purpose and extent of inquiry from DOE

b. Conditions or programs existing at time which caused inquiry from DOE

c. Changes since Crockett letter which may have changed responses if requested today or changed PSE&G position

-* d. Status of DOE programs

2. Basis for response to Question 1, including

a. Assumptions and methodology used to determine number of spent fuel assemblies discharged by calender year

b. Nature of changes which could af*fect the dis-charge rate

3. Basis for. response to Question 2,. including a *. Assumption and.methodology used to predict cumulative total of spent fuel cooled for five years

4. Basis for response to Question 3, including

a. Basis*for PSE&G position with regard to shorter period of time for shipment of. spent fuel

b. Assumptions and type of economic evaluations used to determine when transfer to the government should take place

c. Advantages and incentives for a utility to wait for a geologic repository to* be in service

d. Basis for statements regarding spent fuel pool capacity for Hope Creek e *. Basis for saturation. of the* spent fuel facility with and without full core dump

5. Basis for response to Question 4, including

a. Basis for PSE&G position with regard to DOE d.esi.gn criteria of five year fuel cooling

b. Basis of position on advance notice for transfer of spent fuel

c. PSE&G positio~ on situations which might neces-sitate shorter notice and earlier transfer

6. Basis for response to Question 5, including

a. PSE&G position on reprocess*ing as* preferable to disposal

b. PSE&G position on schedule. for geologic repository

c. PSE&G position with regard to advance notice of~ transfer of spent fueJ_, including contract conditions

d. PSE&G position on fee structure for away-from-reactor storage including transportation and separate fee for geologic disposal e *. PSE&G position on technical design bases for repository

7. Basis for response to Question 6, including

a. PSE&G position with regard to determination of fee for interim o:ffsite storage* and geological

• repository storage

8. Bases for.response to Question 7, including a~* PSE&G position with regard to change in. title associated with disposal of fuel and subsequent liability

b. PSE&G position regarding disposal fee reflecting the right of a utility to recover its spent fuel Respectfully submitted, CONNER, MOORE & CORBER Mark. J *. Wetterhahn Counsel. for the Licensee April. 25, 1979

UNITED. STATES OF AMERICA NUCLEAR REGm:ATORY COMMISSION Before the-Atomic Safety and Licensing Board In the Matter of )

)

PUBLIC' SERVJ:CE ELECTRIC AND GAS ) Docket No. 50-272 COMPANY, et al. ) (Proposed Issuance of

) Amendment to Facility

{Salem Nuc1ear Generating ) Operating License Station, Unit l) * ) No. DPR-70)

CERTIFICATE OF SERVICE I hereby certif:/ that copies of "License7 1 s Outline. .

of Cross-Examination," dated.April 25, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail this 25th day of April, 1979:

-. ChaiJ:man, Atomic Safety and Gary L. Milhollin, Esq.

Chaizm.an., Atomic Safety Licensing Board Panel and Licensing Board U.S. Nuc.lear: Regu.latory 1815 Jefferson. Street Commission

.... _ Madison, Wisconsin 53711 Washington, D.C. 20555 Mr. Lester Kornblith, Jr. Bar:ry Smith, Esq.

Member, Atomic Safety and Office of the Executive Licensing Board Panel. Legal Director u.s. Nuclear Regulatory u.s. Nuc.lear Regulatory Connnission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. James C. Lamb, III Richard Hluchanr Esq.

Member, Atomic Safety and Deputy Attorney Genera.l Licensing Board Panel Department of Law and 313 Woodhaven Road Public Safety

• Chapel. Hil.l, N.C. 27514 Environmental. Protection Section Chairman, Atomic. Safety and 36 West State Street Licensing Appe~l Board Panel Trenton, N.J. 08625 U.S. Nuclear* Regulatory Connnission Washington, D.C. 20555 -

Richard Fryling, Jr., Esq. Carl Valore, Jr., Esq.

Assistant General Solicitor vaJ.ore, McAllister, Aron Public Service Electric & Westmoreland

& Gas Company Mainland Professional Plaza 80 Park Place P. o. Box 175

.Newark, N. J. 07101 Northfield, N. J. 08225 Keith Onsdorff, Esq~ Office of.* the Secretary Assistant Deputy.Public Advocate Docketing and Service Section Department of the Public Advocate u.s. Nuclear* Regulatory Division of Public Interest Commission Advocacy. Washington, D. c. 20555 Post Office Box 141 Trenton, N. J. 08601 June D. MacArtor, Esq.

Deputy Attorney General*

Sandra T. Ayres., Esq. Tatnall Building, P. o. Box 1401 Department of the Pub1ic Advocate Dover, Delaware 19901 520 East State Street Trenton~ N. J *. 08625 Mr. AlfJ:ed.C. Coleman, Jr.

Mrs. Eleanor G. Coleman 35 "K" Drive Pennsville, New Jersey 08070 1-