ML19224C767

First Round Document Request Submitted by Environ Coalition on Nuclear Power to Nrc,Util & Commonwealth of Pa.Requests Info Re Contentions of Intervenors.Certificate of Svc Encl

ML19224C767
Person / Time
Site:	Susquehanna
Issue date:	05/28/1979
From:	Johnsrud J, Kepford C Environmental Coalition on Nuclear Power
To:
References
NUDOCS 7907060452
Download: ML19224C767 (8)

Text

.NRC FUBLIC DOCIDW 10@M com_spoxugygg ,,

& s UNITED STATES OF AMERICA Of c:cmo 4

. NUCLEAR REGULATORY CCM.'iISSION ,

B_EFORE THE ATOMIC SAFETY AND LICENSING BOARD 6 JW 8 M > 2 m .n s. w i In the Matter of ) g "N Y

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PENNSYLVANIA POWER & LIGHT COMPANY ) N

• and ) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388 (Susquehanna Steam Electric Station,. )

Units 1 & 2) )

ENVIRONMENTAL COALITION ON NUCLEAR POWER (ECNP) FIRST ROUND DISCOVERY REQUESTS TO NRC STAFF, APPLICANT, AND COMMONWEALTH Pursuant to 10 C.F.R. 2.744 and the Licensing Board's Special Prehearing Conference Order of March 7,1979, the Environmental Coalition on Nuclear Power (ECNP), intervenors in the captioned proceeding, hereby serve upon the Executive Director for Operations, the following list of documents for production to these intervenors:

1. For ECNP Contention 1, 2, 3, 5, which refer to the cost-benefit analysis and to the various aspects of the health effects of the nuclear fuel cycle, the following documents:

ORNL-4903, Vol .1&2 NUREG/CR-0311 o -5315 NUREG/CR-0597 ei -TM-4154 NUREG/CR-Oll4

" -TM-5251 NUREG/CR-0649 NUREG-0456 ORNL/NUREG/TM-102 CONF- 720805-GJ0-100(78) and-100(79) CONF-730907 GJ0-ll(1973) MIT-952-5 a -1540

" -1559-1 GJT-2, -4, -6, -12, -18, -21 NUREG-OlC9 FECU-218-1

-0119 FBDU-224-10

-0322 NUREG/CR-0573 USGS Professional Paper 820 NUREG/CR-0574 o Open File Report 78-1050 29[ b[O _

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ERDA-93 ENWL-2190 NIOSH-75-ll7 UCRL-50163 (1968)

" Reserves and Resources of Uranium", Supplement to Mineral Resources and the Environment Nat. Acad. Sci .,1975

" President's Repcrt on Occupational Safety and Health",1972 Bureau of Mines Publ.'RI 8254 Draft Recort of Task Force on Uranium Mill Tailings, Argonne National Labs.,1976 "Monticello Mill Tailings Erosion Control Project: Monticello, Utah," Report and Supplemental Report, USAEC,1966 USPHS Tech. Report W62-19 (1962)

Jan.,1979, Draf t Report of NCRP Sci . Conn. 40 Copy of the NRC Translation of a report by Dieter Teutel of the University of Heidelberg And also supply:

1. All assumptions, references, and calculations used in arriving at the radon-daughter air-concentration to . dose to the bronchial epithelium of 0.625 mrem /pci m3 in NUREG-0511, Vol. II, p. G-44. Cite all references.

2. All calculations, assumptions, with references cited, used in cost-benefit analysis for Susq.1&2, with emphasis on compliance with 10 CFR 51.20(c) .

3. All references in which particular values used in a cost-benefit are singled out for comparison with some parameter not used in the analysis, so as to create the illusion that the singled out parameter is insignificant and need not be included in the cost-benefit analysis. The comparison; here refers to"the comparison of radon-222 emissions to natural releases of radon-222 so as to obscure the health effects caused by the operation of Susquehanna 1&2.

This should also include the references to justifications for, in detail, tampering with one side of the analysis balance and not the other.

4. Transcripts of each and every meeting of the NRC Commissioners, with all attachments and discussicn papers, in which the quantity of radon-222 in Table S-3 is discussed, and all Staff position papers and recommendations pertaining to radon-222.

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2. For ECNP Contention 6 on Evacuation, supply the following information:

1. All presently (as of May 25, 1979) applicable and proposed revisions of NRC detailed requirements for emergency response and evacuation plans to be met by Applicant, agencies of the Commonwealth, local govern-mental agencies, and federal agencies, including full specification of the legal responsibilities of all institutions (agencies) and personnel for

a. reporting of accidents ~ ,

b. recommendations for' evacuation,

c. decisions to implement energency and/or evacuation plans, and

d. the actual conduct of these plans.

2. All correspondence and requests for information, documentation and data pertaining to emergency prepar_edness and evacuation planning submitted by NRC to the Applicant, Commonweal th, and any other agencies of government or private organizations in consequence of and/or subsequent to the March' 28,1979, accident at Three Mile Island, Unit 2,

3. All correspondence and requests for information, data, and docmnentation pertaining to radiation monitoring submitted by NP.C to the Applicant, Commonwealth, and any other agencies of government or private organizations in consequence of and/or subsequent to the March 28, 1979, accident atiThree Mile Island, Unit 2.

4. All federal radiation monitoring data from Three Mile Island, Unit 2, in possession of the NRC, subsequent to March 28, 1979, in order to establish whether the NRC, or other involved federal agency, has monitored'to a distance and extent to be able to establish radiation doses to the public with a reasonable degree of accuracy and tineliness, in the event of a serious radiological emergency at Susquehanna.

3. For Contention 7, referring to unresolved safety problems, supply copies of the following:

PTR-815 BNL-17608 PTR-738 WASH-1246 SAND 77-1371 NUREG/CR-0649 NUREG-140 Any reports on ATWS published subsequent to WASH-1270.

" Meteorology and Atomic Energy-1978", USAEC, TID-24190.

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The rest recant report to Congress describing unresolved generic safety problems.

Those portions of the transcripts of the hear-ings in the Black Fox proceeding in which unresolved safety problems were discussed.

In addition, supply a description of each design basis accident, indicating in the resulting analysis, which engineered safeguards upon which reliance for safety is placed, have been tested under realistic accident conditions (temper-ature, pressure, full-scale test) and which are calculated to be effect through analytical technique.

4. For Contention 9, concerning decommissioning of nuclear power plants, supply copies of:

(a) the report of the Atomic Industrial Foru:a on deccomissioning; and (b) any NRC reports on reactor deconnissioning.

To Acolicant The following infomation and documents, data, and reports are requested from the Applicant:

1. For Intervenors' Contentions 1-18, supply all reports, calculations, revised information, and other responses to any requests from NRC, the Co:r.onwealth of Pennsylvania, or any other agency of government arising out of, anc/or subsequent to the March 28, 1979, accident at Three Mile Island, Unit 2.

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2. Fcr ECNP Cor.tention 4, Need for Power, all data and calculations of Applicant's estimated electricity demand, use, and supply projections for the operating life of the reactor. Supply all bases for assumptions of all growth rates and all forecast parameters, as well as all assumptions in Appendix B1 and Appendiy B2, Environmental Report, and ali updated infonnation subsequent to those reports.

3. For ECNP Contention 6, on Evacuation, supply:

a. Applicant's complete emergency preparedness and evacuation plans (which were not provided with the FSAR) and all subsequent rnodification of these documents by the Applicant, including any resulting from the TMI-2 accident of March 28, 1979.

b. Any calculatiens and the detailed bases of all assumptions used to prepare Applicant's emergency response and evacuation plans, including not readily available studies, and citations to readily availat>1e references, used in the develop.nent of

, those portions of the plans pertaining to:

1. traffic studies in Luzerne and adjoining counties and elsewhere;

2. evacuee destination planning;

3. emergency fuel supply plans; and

4. plans for special handling of the infinn and institutionalized persons- which together ensure conformity with Protective Action Guides and any other applicable governmental regulations.

c. Emergency preparedness and evacuation plans for Class 9 accidents, or any accident more serious than the Applicant's Design Basis accident.

d. All data and information on radiation monitoring in the vicinity.of the plant requested or required by NRC, Commonwealth, cr any other.

agency of govermlent in consequence of and/or subsequent to the March 28,1979, accident at Three Mile Island, Unit 2.

4. For ECN? Contention 7, supply following documents listed in the FSAR, Chap.1.6:

AFID a9S6 NED0-10174 NED0-10958-A AFED-5458 NEDO 10299 NEDO-10959 AFED-54E0 NEDO-10320 NED0-20231 APED-5652 NEDO-10329 NEDO-20340 APED-E750 NEDO-103a9 NECO-20360

- APED-5755 NEDO-10527 NED0-20360-IP 55AF-13112 NEDO-10739 NEDO-20566 NEDE-10313 NEDO-10801 NEDO-20626 NEJE-21175-p NED0-10802 NEDO-20626-1 NE.M-10735 NEDG-10846 NED0-20626-2 N00-10173 NED0-10958 NEDO-20631 9 n

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NED0-20913 ID0-ITR-105 NE00-20922 WACP-6065 NEDO-20939 WAPD-TM-283 NED0-20944 WAPD-TM-416 NEDE-20944-P BN-TOP-1, Rev.1 (11-72)

NED0-20948-P BN-TOP-2, Rev. 2 (5-74)

NE00-21142 BQ-TOP-1, Rev. 2 (1977)

NED0-21143 NEDO-21159 NEDO-26453 (all parts) and The report authored by Dr. Charles Reed of General Electric, concerning tre present and future status of BWRs with regard to, among other thir:gs, safety.

The bases for the assumptions in the " assessment of likelihood" of " rare" and " extremely rare" used in the Environmental Report (ER) Rable 7.1-17 with specifi-cation as to whether these bases are factual, estimated, or speculative.

5. For ECNP Contention 9, on Decomissioning, supply all data, cost estimates, and worker exposure estimates now associated with decommissioning which have been developed by the Applicant since filing of the FSAR or subsequent to and/or in consequence of the TMI-2 accident of March 28, 1979.

6. For ECNP Contention 18, on Herbicides, supply a detailed description of Applicant's plans to maintain clearance of transmission line rights-of-way, including full infonnation on:

a. Any chemical herbicides proposed to be used and a full environmental analysis thereof;

b. Physical or mechanical means of maintenance and their full environmental impacts; and

c. Detailed provisicns and identification of anu subcontracts and subcontractors and their plans for rights-of-way maintenance, on.',

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To Commonwealth of Pennsvivania The Ccmmonwealth is asked to provide Intervenors with the following information, data, documents and reports:

1. For Irtervenors' Contentions 1-18, provide all correspondence and requests for information, data or documents from the Commonwealth to the Applicant subsequent to and/or in consequence of the March 28, 1979 accident at Three Mile Isla'nd, Unit 2.

2. For ECNP Contention 6, on Evacuation, supply

a. The most recent version of the Coroonwealth's energency preparedness and evacuation plans;

b. All correspondence from, and to, the Bureau of Radiological Protection, the Pennsylvania Emergency Management Agency, the Commonwealth Justice Department, the Applicant, and NRC pertaining to the adequacy and any proposed thanges in emergency preparedness and evacuation plans in consequence of and subsequent to the March 28,1979, THI-2 accident.

c. All records, documents, and other information detailing the legal. responsibilities and obligations of employees of the Commonwealth with respect to their ability to respond fully, adequately, and timely to a radiological emergency at a nuclear power facility in order to protect the health and safety of the citizens of Pennsylvania.

d. All radiation monitoring data from Three Mile IsTand, Unit 2, in the possession of the Commonwealth Bureau of Radiological Protection subsequent to March 28, 1979, in order to establish whether the Commonwealth or any other involved institution or agency has monitored to a distance and extent to be able to establish radiaticn doses to the public with a reasonable degree of accuracy and timeliness in the event of a radiological emergency.

e. Emergency preparedness and evacuation plans of the Pennsylvania Emergency Management Agency and local agencies of government to provide adequately for the protection of the healtn and safety of the citizens of Pennsylvania i; the event cf a radiological accident worse than the Applicant's calculated " design basis accident," or a Class 9 accident.

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RELKIM CORRESPONDENCE CERTIFICATE OF SERVICE I hereby certify that copies of Environmental Coalition on Nuclear Power (ECNP) First Round Discovery Recuests to NRC Staff, Acolicant, and Commonwealth have been served on the following by deposit in the United States mail, first class, this 15 day of May,1979:

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Decketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Ce-inion

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Washington, D. C. 20555 Charles Sechhoefer, Esquire Chair =an, ASL3 Panel Jay Silberg, Escuizo U.S. Nuclear Regulatory C W ssion Shaw, rittman, '/otts, and Trowbridge Vashington, D.C. 20555 1800 M Street W -

Waship;; ton, D .C. 20036 Mr. Glenn O. Bright ASL3 Panel Gerald Schultz, isquire U.S. Nuclear Regulatory Cc==ission Susquehanna ::nviron= ental Advocates .

Washingten, D.C. 20555 , SCO South River Street .

Wilkes-Barre, ta. 18/04 Dr. Usear H. Paris ASL3 /anel Ers. Irene >=novics, Chainerson U.S. Nuclear Regulatory C d ssion Citi:: ens Agai:nst Ncclear ikc2ger Washington, D. C. 20555 P 0. Ecr 377 -

R.D. 1 Atc=:ic Safety and Licensing Berwick, Pa. 18603 Board Panel U.S. Nuclear Regulatory CM ssien Ms. Colleen }".arsh Vasnington, D.C. 20555 5$8 A, R.D. 6 Xountain Top, Pa., 18707 Ate d.c Safety and Licensing Appeal Ecard Panel Mr. *h::ac M. Gera@, Direct =

U.S. Nuclear Regulatory Cc-4 ssion Preau of Radiatim Protectics Washington, D. C. 20553 Deprtment of Envi.w.-a9tal Reso=9. :es

. Cc=:uwealth of Yennsylvania Janes M. Cutchin,17, Isquire P.O. Ecx 2063 Office of the Enecutive Legal F.arrisburg, Pa. 17120 Director U.S. Nuclear Regulate:y CGssion Washington, D.C. 20555 ,

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