ML19210B740
| ML19210B740 | |
| Person / Time | |
|---|---|
| Issue date: | 03/04/1976 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19210B722 | List: |
| References | |
| FOIA-79-414 NUDOCS 7911120218 | |
| Download: ML19210B740 (10) | |
Text
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INVESTIGATION OF CHARGES RELATING Q "ir I,.,
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FEllitUARY IN, :.3. AND : 4,.MAltCII 2 AND 4,10M l
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a- 'y 1. hamn. p i. APPENDIX 14 6 ou"a' NUCLEAn RD:UI.ATottY Co.st.itiSSloN STArr REI'onT ON OTiiEn u te. Issues RAlseD BY MEssns. POLLARD, BnIDENBAUGil, et al.
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i-f FE81llARY 29. 1976 F e e r u.. i s b f the tsn. (tw o .s R.
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'e."'.' . p s. + . V.Q...e m n 3 3 I 7 emm f,I),p7-f- yn 4 > 9, ,,.w f.f ;1a.e { l 't s "1. Has the Nuclear Regulatory Comission been presented wath l[g.[. a review of the findings of Dr. Charles Reed of Cencral Electric concerning the technical adequacy of tne B'4R? If (! so. Is Ccneral Electric's progress being evaluated? Et t programs have been implemented by the NRC as a result of their evaluatLon of the Reed study?" 1
Response
!.s '.* - i During 1975, a General Electric Company task f orce made a detasted crit te il i
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review of their Boilina Water Beactor design to determine what trprovements
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could be made in the way their reactors were desagned. constructed, and operated. Although the task force only intended to revtew how improve-t ments could affect General Electric'n commercial po3Ltion, the possi511ttv that questions of safety might be ratsed was recognized. Therefore, the a 6 findings of the task force were reviewed by the General Electric licenstn% [ group. This review identified some twenty-seven safety related items and concluded that the hKC had been aware of all of them. As a result of the February 18 testimony, members of the NRC staff reviewed the findings Jf the General Electric task force and also came to the conclusion that the NRC staff was previously aware of all of the safety related items contatred e I -w in the General Electric task group findings.and that no tuttact staff action was required. 1 The staff report of the NRC review that was performed, dated February M. F 5
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1976, is attached. hh i a 5 ."u $.~, ; i e I k. O\\' [ L.*;.3 -.e I2 c c.. 9-g' I a a g \\ l f i w ~5. ;- a i p $,M ^(- Q i.... ,e
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.g February P',, ly/6 re cor t' i. L' C. f - 4k previn 4 revir$< that r-specif, wherc6* 1, Ben C. Ruscir, Director revic.* 'I Of fice of NucicAr IIcaClor RegWIation E mi g l r did ne' 1 i On February 23-24, 1916, a revicis vos made of the GE ::nt u
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' l V2shington, D.C. The review of this report was made for c..o .iscific purposes: (1) to detteriine if any in forr'a t ion in sas'ety concerns by CE had not previously been kn%nthe rc, net espressirg dof C Regulatory Cc, niission (:AC) t arid (2) to icte,rnin: if % tio '06 of d to t he t:uclear l 055" " al the Energy Acm c inization Act of 1974 hed been sw. 1.y th; repinting of instan
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In oJr revics* of the t e pur' t, did not PN' identify any Instances of ncw areas of safety rt.oct rn; h's/ e C*' ins tances Identified wherc significant safcty ct.ut e a os L:re not ror, were any D3!, previously reported to the fiAC. The CE Nc lear Ite..c tor S t oily consi s t s f of the main report plus ten (10) appendices as (nliu.4: '55" B. Fuel {'. t A. fluclear Systems j N I"' C. Electrical Control and it.str n ntation O' ' 5' O. -{ l Mechanical Systems and Equip ent 355 J,. E. itatcr ials, Proces ses ard Chc nistry hl F. Production, Procurennt.,nd Constr ctica G. Quality Centrol Systens Ovu sitar a H. ' Manaqci ent/Informatice Systems r . i s ~~ Reg datory Consideration 1.
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Scope and Standardization IN, O' ( in our revices of time GE t:ve tcce tractor Stua, si study has trJinly directed at r' ark ting ratb:r ti.. n .1, . ;i;,r cni t h.s t the f report does contain items tehich had implication on .:f et f ps r sc. The 'r and opera t ien of It'ifts, houcver, the ema ples usi, th; *afe ca.ntruction t point that id6 o' rt Jo h,we on e f fee r r,n 'A e ;.i 'i ified problems bcnc of s.hich b.n. tc, ille..trate the 4 4l f i ...fety significance) Ili., of 7"a,- 1. ',4t ) and markting g4 <nii I vi t.u
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} { ;- having safety signific.or.ct tere cited tN.r rep < sit of the significancs c t.n. <. a.... !,, i *- in the CE phenuinenon. (roa a safety st: rid;.nini .f
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%;y ... s M 'v " * :...*' M 1407 11 r]y4., m.- Ben C. P.u cN.. 1',4g g In our review of the repor t, we did not cit. ,,t to provide a ts m record of ho'.* thc pa r t icu la r issue wJs FC;.c,r tad or fiadu !.10un to the 'h IAC, rather wt: Interested in deterraining.AcDer or not Lt.: 4 was were previously usade avare of the particular issue 4s discussed. Fro.n our review of tha safety related items cited in it.e report it was c e view 3 that many of ti.e issdas were raised by the FJtt itself in its revicu of J I specific ap.')ications as sub,itted by L.E. L's diel not finJ any comptr I I wherein th. IIE was not cognirant of the particular concern. In our l review there were also Issues raised as a coise acnce of o; crating ( prob 1 cms in D'.l36 4*a, cnj again wa did not atte-pt to trace '.a., a reparted i problem was co municatcJ to the NRC. In sc.a instances trable,s could here 3 l h.y., been repos ted by the operator of the plant nr by C* it>.-IT, but ,. J. i M since m. did not i<fentify any Instance where the f.% u,5 rot tully aware of the event, wi mavle no attempt to track the re. es of reprting. y; 3, There was ora category of information which.c did not have suf ficient i documentation (> deterriine if the events identified in the CC t;uc trar "1 Reactor *,cuuy para thcatsolves report 3ble. 1his w 5 in t t.c area of quality assurance khur:' the report indicated that the CE tan forru identified Instances based on their revltw of audit repos is U rc htailc:1 procedurcs rel1ted to quality assurance scre r.cl fol!c.4J. TN s,wi fic
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examples were nat provided in the report. The CE repres-ita tive dated 'that tho'r.E lic.cnsing group he. aver; had r ev is..cJ t h^ s*,;.:c i fic i tem; reviewe.1 by the rask force itscif and had decer. sic.cd that the e,ustity ) M' assurance bree.1down did. not have the sis-ificenec iedicatcJ in tectio, ?O6 p g., m for report 4*lity. Ve are 'awarc that thfs a"Ji t reports centioned in t he-I h. 'g y 5 CE Nuclear ftcJc tor study are also availabir. to the vendors as 6. ell as thc MC inspec tion,ta f f. Since the r rcports are available erid.,re revie rd \\f' on a selectcd b3 sit by the HitC inspectors, 6:e did not delve into this lssue at any greater depth. l h u. vow .sL 7 h +<N L t VJfrcn HInrects, 5:CtIon leader OotalJ F. Keuth. Directo* n $cctic.: A Re ictor Systems Brar'ch retctor 5.sfety rase.rch, MS hs Divisice: cf Systems safety, im y P b aa :nK &Eh.d ~, +32(d' \\,3 \\ z 1 f,7 ,l_ c Y, & t f g p.. s ~ a O s '{,. ( [ M-m.4 , we -~ .. ~.. u.. . ~.- ~.. - .? - + ~ -
Lling requiring these intervenors to take the proceedmg as ie) uun a ATOMIC SAFETY AND LICENSING APPEAL B precludes any disruption of the established discovery and hearing (The*nearijs currently scheduled to get underway in September.) f, r m, we perceiw..e?her serious delay nor expansion of the issues in the [ Alan S. Rosenthal, Chainnan , ~ v* gs Bowing from the admission of these interveners out of time. We Michael C. Farrar Dr. W. Reed Johnson a do not think it c:n fairly be said that the Licensing Board abused its in ruling that the City and the County's status as "important local In the Matter of Docket Nos. 50-461 ) ntal entities" tipped the balance in favor of their intervention. 504G2 gly,we defer to the Board's judgment in this matter. r ILLINOIS POWER COMPANY (Clinton Power Station, Unit Nos.1 and 2) 1 appeals of the City of Louisville and of Jefferson County, Kentucky, are Upon a; peal by intervenors from the partialinitial decision of the Licensing I without pictudice as premature. Board (LDP 75-59), and upon review sua sponte of uncontested portions of that decision and that Board's initial decision (LDP-7M3), the Appeal Board applicant's appeal is denied. so O RDERED. concludes that, although several determinations of the Licensing Board are of doubtful correctness, there was no error which could have changed significantly FOR T!!E ATOMIC SAFETY AND the result reached in either decision or which affected substantial rights. LICENSING APPEAL BOARD Licensing Board decisions affinned. Romayne M. Skratski RJLES OF PRACTICE: IIEARSAY EVIDENCE Secretary to the Appeal Board An expert may generally rely on scientific treatises and arto.!-s. irrnpective of their hearsay character. RULES OF PRACTICE: REQUESTS DURING llEARING FOR PRO L,r4 OF DOCUMENTS U Requests to obtain background material from a witness, to supply answers j to cross-examination questions which the witness was unable to answer,cannot p u be denied solely because the material was not earlier requested through dis-covery. t RUI.ES OF PRACTICE: REQUESTS DURING llEARING FOR PR s. I l OF DOCUMENTS .A rardy petitmner with no good entuse may be required to ta e the proceeding as it k }. l'or, as stated by the dmentmg member of the Appeal Dnard. *any disadvantage ln considering whether to grant requests for the production of documents t might suffer in terms of the opportunity Inr trial preparation would be entirciv of rn de at the time of cross <xemination, a board must balance the costs of delay making '" West I",IIcy. surra CLI 75 4,1 NRC at 276. 27 7G 1 i i I ~ ] r p =.. g e-q ; g,
a n a tention to the issue to stimulate the board's co ,..,~y , n. a.n ! National Emir'onmental Policy Act re ofit. ' rely of options which might enhance environmental quality or h' red to a d f} y Messrs. Peter V. Fazio. Jr., and Sheldon A. Zabel, Chicago k ure ntal effects than the proposal under consideration Illinois (Mr. Christopher for the applicant, Illinois Power Company. Nelson with th ave less r COST-BENEFIT ANALYSIS t Mr. Robert W. Dodd, Champaign, Illinois, for the inter-h, ,f
- e a need for power has been demonstrated, a board must i venors Salt Creek Association,etal.
$( the need can be best met through the proposal unde, taking into account all relevant env nquire into Mr. Milton J. Grossman (Mr. Charles A. Barth on the n ca for the Nuclear Regulatory Comenission staff. r consideration. SCOPE OF INFORMATION REQUIRED FOR LICENSING d DECISION [ )oard must examine the effects of wi hd . l ion in terms both of society as a whole and of the particular owners or v t rawing land from agricultural such land. July 29,197G k h. Before us for review are two decisions of the Licensing Board g COST. BENEFIT ANALYSIS two units with a net power output of approxima f ed in tenns of how much it would cost to regeacrate if neces societal cost of remo reactors are to be located in liarp Township, DeWitt Couniy Illinois neaj' e each, ~1he confluence of Salt Creek and its North Fmk,approximately six mi (} r the I u e 6 nt amount of production on other land. City of Clinton. In a partial initial decision rendered on Septem ssary, an Board reviewed the environmental and site suitabdity aspects of'he COST.DENEFIT ANALYSIS made the determinations requisite to the issuance of limited work s, v and tions. LDP.75 59, 2 NRC 579. Herca ter, on February r performing a benefit <ost analysis, the placing of a monetary rendered its second decision, which dealt with the remaining radiol 20 1976 the Board h of electricity is inappropriate-value on the LnP.764, NRCI.76/2 135.'and safety questions and authorized }. 3 ealth l, COST-DENEFIT ANALYSIS Participating jointly as intervenors in the proceeding are the Salt Association and a number of individuals who live, work, or own o trds may consider strictly economic differenc l ( the vicinity of the proposed facdity.11efore the Boari below the the extent that the environmentalimpacts of the ttes of project alternatives l' n confined to the disposition of those issues in the se intervenors a ematives vary. y COST.IlENEFIT ANALYSIS a ential tax reve iues are transfer payments resulting in offsetti nitial decision. Nevertheless, as is our custom, we have reviewed 30 1975 partial I and therefore may not be included in the cost benefit anal ng costs and ysis of a 8 1he construction giermits have tven inued. 41 i R 9425 (htsrch 4 f .1974 t.A 28 29 l* I
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Mlk there, fore affirm. uc i a ecte su stantial rights. We
- s. ion an utinty system planmrg, fud cycle costs, capa.u co>ts, and cuvu system evaluation. For its part, the staff primarily urged that eith" hears S
legal conclusions were involved. De hearsay cbjection encompa made by Dr. Rieber to varicus articles in newspapers, maga / I m-periodicals which he had utdued as source materials for portions o The Clinton site extends over some 13,535 acres in a rural area. The facility It was the staffs argument (particularly as to hearsay) which carr and its construction-related activities will utilize approximately 6135 acres. Of g 1592,1642,16G1). Subsequently, in the partial initial decision, the Boar this amount, some 4900 acres are to be inundated for a cooling lake which is to opined that the material which it had extuded not only was hearsay but, comprise a part of the facility's exhaust steam cooling system..In the recent past tionally,was " irrelevant, immaterial and unreliable"(2 NRC at $88L most of th. land has been devoted to crop production or employed as pasture We do not believe that the stricken parts of the Rieber testimony w (Final Environmental Statement (FES), @2.7.1). Here appears to be no dispute either irrelevant or immaterial. Nor does any basis appear in the record f that at least a significant portion ofit is of high agricultural quality 'regarding the sources cited by Dr. Rieber to be inherently unreliab %e thrust of the intervenors' position before the Board below was that a Licensing Board's action can be justified, if at all, only on hearsay need for the power which would Le genciated by the facility had not been the circumstances of this case,however, there is no compelling need to established; that sufficient consideration had not been given to " coal as arfdifficult question of the extent to which an expert witness in an administr economically viable attemative fuel", and that the cmt-benefit analysis of the proceeding may make reference to articles in newspapers and other peri applicant and the staff did not adequately consider the " adverse agricultural without running afoul of the hearsay rule.s Insofar as we can determine. n and/or economic impacts" which the taking of such a large quantity ofiand for the contents of the source material pointed to by Dr. Rieber has be the nuclear plant would have upon the Salt Creek Association members residing by the applicant or staff as either incorrect or inconsistent with other disc in DeWitt County. !n short, the intervenors opposed construction of the fa ilitin the record. Rather, the dispute seems te center on the conclusions whi on exclusively cocioeconomic grounds. c y Rieber drew from the fatts asserted in those sources and c!sewher On the basis of what it found to be reasonable forecasts of future demand-so, we see no impediment to our taking into account the entire Rieber testim the Licensing Board concluded, however, that the power would be requirn! by in evaluating those conclusions-includmg the struck portions, all of which ar the date of the scheduled completion of the facility. De Board further our possession. We accordingly have done so. determined that the alternative of a coal-fired plant was not economically ~ B. %e liceming Board denied the intervenors' rape-st that it req %e b i superior and that, balancing al' benefits and costs (including those associatedmour Jaye, one of the applicant's witnesses,' to bring to the hearing in Illi with the diversion of the land from agricultural use), the construction of the undeilying data on computer modeis which he had used in forecasting facdity at the Clinton site wasjustified. On appeal, the intervenors do not press the need for power issue but d fuel cycle costs for the Clinton station.* ne request was made after the wi was unable to answer certain questions on cross-examination because the v renew their claims on the otherissues raised below. Additionally, they complain necessary data was at his home office in New York City. ne intervenors so vigorously of two procedural rulings of the 1.icensing Board. De arplicant andthe source decks, data decks, computer programs and background docum the NRC staff urge affirmance. i j tion upon which the models were based. At no previous time had they l II ' An esperi nisy of ecurse, renerally rely on scientific treatnes an.1 attides,irresp of their hearsay character. See Rule Rnh1R). Rules of I' valence for United States Courts. We turn (int to the procedn'al questions presenteil to us by the intervenon 'M), Jaye was the Vice-President and General kranares of the titdity th=ismn of S. M A. During the course of the hearing, the I.iccining Board tituck certain. stotter Corp. (SMSC) of New York, a consulting engencer ng firm stucts the arrinan segments of the prepared wntten testimony of Dr. MNhac! Richer, an economist en(a ed pninnn the fue e e co ana s of e nton called as a witness by the intervenors. It did so in response to motions of the alternatives. See further dncusson of tho sut. ject at pp. 4Mt.viPa I ar and ensi _4 bN 30 I 31 I c z I 3 7 y;,ygggy 3 a q y; j l a. ,.v.3
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3 sufficient time to analyre the data once it had been delisend to them (Tr. anything else-by way of discovery. Discovery is avadable to assist a parth a 1427-29). "obtain adequate factual data in support of his claim or defe/ {.'. nyLicensing Board based the denial upon both the delay factor and the y learn the substantial basis of the positions asserted by his a " 4 Noore failure c. the intervenors to have asked earlier for the material. It referred to the Tcderalfractice 2d ed., par. 26.02[4]. Failure of a party to take advantage fact that, during the discovery process, the intervenors' expert witness, Dr. discovery can in no way preclude its exercise of other rights it may possess. [ Rieber, had been given a copy of a letter from hlr. Jaye to 3e appbcant which In this connection, we have previously noted the parallel between o had rnade explicit reference to the model used by him to estimate costs; and that discovery rules and those contained in the Federal Rules of Cini Procedur the intervenors had "at least a week's time [before the close of the discovery Commonwealth Edison Co. (Zion Station, Units I and 2) ALAC496. 7 AE v ,i., period] following re:eipt of that letter" to request additional discovery and did 457,460 61 (1974). The parties have not called our attention to any instance i 4 not do so. Further, the Board noted that the intervenors had been given Mr. which a court has declined te allow. subpoena for the production of a doc Jaye's prepared written testimony on June 9,1975, and had not asked for the ment at trial under either Rule.54 or Rule 45(b) for the reason that the reques underlying data during the intercening 17-day period between that date and the ing party had not earlier sought the same document through discovery. time the request was made. It concluded that
- 2. Bus, the correctness of the Licensing Board's action hinges upon th
'[. .,, nifomtation revealing the existence ar.d significance of the models was validity of the other reason it assigned-the avoidance of delay. available to the Intervenors during the discovery process and their failure to Licensing boards have extensive authonty to control the course of a hearic follow up and request the detailed backup data at that time required us in 10 CFR 2.718. And they are under a mandate to insure that proceedmgs ar c i k? fairness to the other parties and to the public's right to a prompt disposithn conducted "as expeditiously as possible, consistent with the development of i h of this proceeding, to deny their request. adcquate decisional record." 10 CFR Part 2. Appendix A.Section V.Morcou {. delay in the hearing is a well recognized basis for hmiting or denying requests f 2 NRC at 585.8 the production of docume_nts3Eaorci.Erderal thctict2d ed., par. 34.06
- 1. It i, clear that Mr. Jaye was unable to answer certain questions on Scran rah Dreatre Co. v. Lucas & Jen Ains, 8 F.R. Serv. 34.12, Case 2 (S.D.G 3
cross +xanJnation because of the absence of some underlying data. The 1944); cf Commonwcalth Edrson Co. (Zion Station, Units I and 2), ALAB 19 h intervenors.laim that the accuracy of the modeis employed by !Lfr. Jaye-and supra, 7 AEC at 467; Bernstein v. N. V. Nederlandsche-Amentaansche Stoom hence of a substantial portio:t of his testimony-cannot be evaluated withnut raart-Maatschappij,15 F.R.D. 32 (S.D.N.Y.1953). ,4 such data and that their questions were of a type that an expert should have In considering whether,in a particular case, deiay shouki i e countenme [. been able to answer from memory (App. Tr. 47). Accordingly, they reason,it to allow a party to obtain additional information, a board must balance th should not have been necessary to ask Mr. Jaye *o bring the information to the effects of such delay againyt_such countervailing factors as the afaerity witt (,. hearing, since he should have been familiar with it. Similarly,it is argued, they w*iicithe.infermation_was requested 3 hen.ns.materiahty became_spparenith f should not have been required to seek the information through discovery in particMar_ relationship _qf_thacquestedjafogmation to unresolved _quejtions order to be provided with answers to relevant questions on cross-examination. the proceeding, and the overall importance of the information to a soun< %heti er or not an expert witness such as Mr. Jaye should have anticipated decision. In this instance, it is not clear whether the intervenors asked for th material at the earliest practicable time;we will assume that they did so. But w-are satisfied both that the additional data sought wa. far more extensive tha: j 'The intervennrs advised the Licensing Board that they had esilier inquired about such necessary to provide answers to the questions to which Mr. Jaye was unable tr material and been informed that "Stoll r materiats were secret and not available" (Tr. respond and, further, that the particular information bearing upon such answer 1414). The applicant denied this to be so (Tr.1417). 'The staff would have v' bct the intervenors' esception on the ground that they had wouhl have been of too little potential worth to justify holdmg up the eviden submitted a propowd find ntially parallehng the reasons adopted by the Doard. But liary hearing to await its receipt and analysis. ~"" the proposed finding mere cribed uhat the Board had previously done and cannot be We have earher noted (p. 32, supra), that the hearing delay incident to th U taken as a waiver of any., sections to the rutmg. ktoreover, tte proposed finding atto document request would have resulted primarily from the tune needed by th
- included a statement as to the deficienrics of F.tr. Jaye's testimony and the resulting tack of intervenors to analyze the material once it had been dehvered to them.% hat wa U weight which should be given thereto; the Doard did not adopt that portion of the finding.
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f,, *8 material would have provided specific detads on the entire program utilized by used m nuclear power contracting and (2) the gross national product dellatti. o' Mi. Jaye a developing his fuel cycle cost forecasts. As we shall see,it was far Mr. Jaye's associates developed estimates of long-term escalation in the general ,, M'i. mere eMensive than was needed to provide answers to those relatively few g, economy and thus projected the future course of the GNT deflator.'1he analyses questions to which the witness had been unable to espond. in this connection, involved the utilization of the historic conelation mentioned abose to predict, i Professor Moore has observed that "[a] blanket request for production of all from the prejected changes in the GS P deflator, the projected changes in the f ' books, documents, papers and records which are relevant and relate to the indices. subject matter of [anj examin.+ ion
- is obviously without merit." 4 A Mr. Jaye was able to furnish the projected changes in the GNT deRator j.
Moore's Federal fractice, 2d ed., par. 34.07.1hus,in all events, the Board need (Jaye, p. 8. fol. Tr.1255; Tr.1288). And he discussed the historic correlations not have requ red the production of everything that was sought by the inter-which had been developed between the movement of that deflator and the particular indices? But, when the intervenors questioned him conceming the I. venors. f it is significant that the intervenors never modified their request to reduce strength of these historic correlations. Mr. Jaye was unable to furnnh from its scope. The question remains.however,whether the Board nevertheless should memory certain correlation coefficients or standard errors of es:imate. Either have insisted-in the interest of achieving a complete record on the points would have indicated for each index,in mathematical terms. precisely how good addressed by Mr Jaye-that at least some of the recrested data be nroduced the correlation was. Ile pointed out.however, that those values were not part of (either in tpe fomi sought or in a different form). We conclude not. Given the the models as such (Tr.1338) and that they could be calculated on the bass of other_eridence availat/.m.to_the. Board, none of the material _was_sufGciently public infonnation (Tr. 1325,1338) because the intenenors knew which mdwes significant to the issue of fuel cycle costs to warrant a hearing delay of.even were involved (Tr.1330). modest proportions whih: it was being obtained and scrutinized. In any event, the answers which Mr. Jaye was unable to provide would have Mr. Jay's testimony on projected fuel cycle costs was both clear and com-done no mo.e than refine the desenption of the error ranges of the models. prehensive. IIis direct testimony (fol. Tr.1255) included a qualitative descrip-. These ranges had been touched upon by him in another fashion. Spec:fically.be tion of a series of analy'.al models used to make cost predictions in each of the had desciibed a number of cantingencies or changes in circunntances ufach phases of the cycle, a series of life-of-the-plant cost projections for each fuel might occur in various phases of the fuel cycle and the particular cost dif ferences cycle phase, and estimates of t pper levels of cost risk both far individual phases for each phase likely to eventuate from those contingencies or changed of the cycle and for the phases in combination. On cross-examination he was circumstances (Jaye, pp.1315). And,in addition he testified to the cumulame able to answer in substantial detail the vast m-jority of the questionshe was asked increase in fuel cycle costs which would hkely resuit if.ill ut the pmcma. a a regarding the fuel cycle, his assumptions, and specinc aspects of his models(Tr. he had mentioned were to occur (id., pp.15,17). lie also evaluated the hieh-j 1261 1346, 1367 1407). At one point, he presented verbally what amounted to hood of occurrence of the totahty of the cumulative increases DJ., pp.15-1 D. a flow diagrc.n of that portion of the analysis dealing with fuel reprocessing While Mr. Jaye's inabdity to have provided the mathemat cal quantities formativ costs, stating his assumptions and the numerical imput values that were used (Tr. related to error might have taken on more than minimal signincance in the 134146). Ile later offered to deal similarly with each :.." 9.e other separate absence of such analysis, it does not do so here, where the subject of posuble phases of the entire progiam,but was not asked to do so. error in the modelv projections and numerical estimates thereof had been Our review of the cross +xamination of Mr. Jaye has revealed that, except specifically addressed by the witness throurh another mechanism. with respect to o"e minor matter,' there was only one general area in which the Moreover, in addition to that specific consideratmn of error. the record witness could not provide answers to the intervenors' questions.This concemed provides yet another and quite independent measure of the accuracy of the the range of error that might be inherent in the models he used? l apphcant's fuel cycle cost predictions.Specifically, the range nf values advanced by the apphcant encompaved the fuel cycle cent value.. prepared by the L 'The witness wa unable to say what fir'ne he had factored into his rnodel to represent the percent. ige of u aniurn in a partitut.n year corning frorn open pit and underground ~ sources (Tr. 12?h lic Iurnished nrher inforrnatmn in this regard, however, and the See
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