ML19225C839
| ML19225C839 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/21/1979 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19225C840 | List: |
| References | |
| NUDOCS 7908020574 | |
| Download: ML19225C839 (11) | |
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05/21/79 UtlITED STATES OF A?' ERICA NUCLEAR REGULATORY CCPMISSICil BEFORE THE ATCMIC SAFETY AND LICENSI"r ECARD i
In the Matter of PENNSYLVAtlIA PCUER AND LIGHT CO.
)
Docket Nos. 50-387 ALLEGHENY ELECTRIC CC0FERATIVE, INC.
)
50-388
)
(Susquehanna Steam Electric Station.
)
Units 1 and 2)
)
NRC STAFF'S FIRST RCUND DISCOVERY RECUESTS OF THE CITIZE'IS AGAINST NUCLEAR CANGERS (CAND' As allowed by 10 CFR 2.74Cb of the Comissions regulations ard the Licensing Board's Scecial Prehearino Conference Order dated March 6, 1979, th'e NRC'. Staff requests that'CAND answer the interrogatories set forth below.S As required by 10 CFR 2.740c(b), each interrogatory shall be answered separately and fully, in writing and under oath or affirmation, and the answers shall be signed by the person (s) ma ing them.
In addition, as allowed by 'O CFR 2.741, the NRC Staff requests that CAND make available for Staff inspection ar! cocying (or provide copies of), those' documents designated by CAND in its answer s.1 S The answers are to be ;;rovided by June 20, 1979, as required by the Licensing Ecard's Scecial Drehearine Ccnference Order data'd March 6, 1979 (at p. 79).
/ Of course, if the document was cr2 cared by the NRC Staff or its consultants, or was submittcc by the 4clicant in cc. nec-ion with the captioned matter, it need not be made available by CAND.
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-2 General InterrocatoriesS G-1.
State whether you intend to present ar.y excert witnesses c7 the subject matter at issue in:
a) Contention 2 f) Contention 11 b) Contention 4 g) Contention 16 c) Contention 6 h) Contention 17 d) Contention 9 e) Contention TO If so, provide the names, addresses (residence and business), and pro-fessional quali'f rations of those persens you expect to call as excer t witnesses, sute the subject matter on which the expert is expected to testify, state the substance of the facts and opinions to which the expert is expected to testify and provide a sumary o' the grounds for each opinion.
G-2.
Identify by title, author, cate of iswance or publication, and issuer or publisher, all documents that you intend to use (refer :o or offer in evidence) in presentir.g ycur direct case on the contentions listed in Interrogatory G-! and all docur:ents that you intend to refer to in conducting your cross-examination of witnesses for other parties who may testify in connection with any admitted contention, and make available those dccuments for Staff inspecticn and cocying (or provide copias of.nem!.
M These interragatodes shculd be answered secarately with resi.ct to each contentien, 423 6
. Soccific Interroca tories Contention 2 S-2.1.
Specify with particularity all of the errors that you believe to exist in the estimates of the health effects of cesium-137, ccbalt-60 and chlorine releases frca the Susquehanna facility, the magnitude of such errors and the causes of such errors.
S-2.2.
Specify the amount of cesium-137, cobalt-60 and chlorine that you believe will be released and set forth in detail each calculaticn made and specify, and state your bases for, all assumptions made by you in estima'ing the rele::ses.
S-2.3.
Specify with particularity each health effect of cesium-137, cobalt-60 and chlorine that you believe will occur and state in detail how that health effect is caused.
5-2.4.
Set forth in detail all calculations made and specify, and state ycur bases for, all assumptions made in reaching ycur conclusions about the health effects of cesium-137, qcbalt-60 and enlorine.
S-2.5.
Specify with particularity the effect that ycu believe correct inclusien in the cost-benefit analysis of these allegedly new inadequately assessed health effects of cc.fium-137, cabalt-60 and chlorine will have en the outccme of that analysis, and state in detail the basis for your conclusion.
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4-Contention 4 S-4.1.
Specify the growth rate c? peak electric icad that you believe will occur in the Applicants' service areas over the life of the Susquehanna facil i ty.
S-4.2.
Provide your projections of peak loao and available capacity in the Applicants' service areas cver the life of the Susquehanna f.acility.
S-4.3.
Specify the models used in making your calculations of peak load and available capacity, and state why.you believe those models should be -
used.
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,-4.4.
Se' forth in detail each ca.l.,culation made and specify, and state your t
basis for, all assumptions made in reaching your conclusions about peak load projections and available capacity.
Contention 6 S-6.1.
Identify (if necessary for clarity provide a ma.p marked to show) the area in which (in the event of a design basis accident at the Susquehanna facility and withcut prcmpt notificcticn and evacuation) you believe persons may be exposed to radiaticn doses in excess of those pennitted by existing radiation exposure standards for the general public and pro-tective action guides.
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. S-6.2.
Specify the nwnerical values (in appropriate units) of the exposure standards and guides which you believe will be exceeded and state why you believe they will be exceeded.
S-6.3.
Speci*r the models used :n making your dose-distance calculations and state why you believe those models should be used.
S-6.4.
Set forth in detail each calculation made and specify, and state your bases for, ali assumptions made in reaching your conclusions about the adequacy.nf the emergency plan.
5-6.S.
Specify in detail how you believe the Applicants' emergency plan fails to satisfy the Commission's regulations.
Cite each regulatory require-ment that you believe is not satisfied. State the basis for your con-clusion that the requirement is not satisfied by the Applicants' proposed plan.
Contention 9 S-9.1.
Specify with particularity why you believe that the monetary costs of decommissioning the Susquehanna facility will at least be equal to the cost of its construction and provide an estimate of those menetary costs.
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-- S-9.2.
Provide an itemized list showing what you believe the monetary costs of decommissionir.g the facility will be.
S-9.3.
Set forth in detail each calculation made and specify, and provide your bases for, all assumptions made in reaching your conc'usions about the monetary costs of decccmissioning the Susquehanna facility.
S-9.4.
Specify with particularity wny you believe that dec.ommissioning the Susquehanna facility will result in serious radiation hazards, particular-ly for workers.
S-9.5.
Identify and provide esti nates of these "new" occupational hazards to rorkers.
S-9.6.
Specify with particularity e "new" envircnmental hazards that you believe will result from decomissioning the Susquehanna facility.
5-9.7.
Specify with particularity why..
.cVe that the decc=issioning costs, when added.to cther monetary and health costs of the facility and the nuci:-ar fuel cycle, tilt the cost-benefit balance against authorizing operaticn of the facility.
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. Centention 10 S-10.1.
Describe in detail the "significant" rail accident that you allege has already occurred at the Susquehanna facility.
S-10.2.
Define with particalarity the term "significant" as it is used in the context of contention 10 and state clearly why you believe that the accident described in answer to interrogatory S-10.1 was significant.
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S-10.3.
State clearly whether the accident, referred to as Saving occurred, occurredon-di,te.
S-10.4.
Describe in detail the actual damage that occurred to safety structures, systems or components of the.Susquehanna facility.
S-10.5.
Specify with pcrticularity your reason (s) for believing that the rail line is not adequately designed to assure that on-site accidents, that will damage safety systems, structures or components (to the extent that they wili not be able to perform their intended safety functions) will not occur in the future.
S-10.6.
Identify with specificity the safety structures, systems or ccmponents that you believe will be damaged should a rail accident occur on-site, and state in detail the basis for your conclusiens.
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. S-10.7.
Describe in c tai' the extent and consecuences of t,he damage that you believe would occur.
S-10.8.
Identify with particularity the standards (criteria) with which you believa the on-site portion of the rail line should be designed to comply.
S-10.9.
Set forth in cetail all calculations made and specify, and state your bases for, all assumptions made in reaching your conc'usions about rail accidents at the Susquehanna facility.
Contention 11 9
S-11.1.
Specify with particularity your reasons for believing that the Applicants' alleged failure to provide. adequately for safe on-site storage, for periods of up to 10 to 15 years, of spant fuel and low-level radioacti've wastes creates an unreasonable risk of harn. to the health and safety of the public.
5-11.2.
Define the terms " adequately," " safe" and "unreascnable risk of harm" as they are used in the context of contention 11.
5-11.3.
State wnether, and if so why, you believe that the methou of cn-site storage of spent fuel and Icw-leve! radioactive wastes to be used at the Suscuehanna facility will be unsafe.
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9-S-11.4.
How many spent fuel elements and whct volume of low-level radioactive wastes do you believe can be stored at the facility as proposed?
S-ll.5.
How many spent fuel elements and what volume of Icw-level radioactive wastes (that must be stored on the site) do you believe will be produced in the first 10-15 years of nornal operation of the Susquehanna facility?
S-ll.6.
Stz te in detail how you believe the conditions, that you alleged, con-stitute a violation of 10 CFR 20.1 or 10 CFR 20.105(a) of the Commission's regula tions.
S-11.7.
Set forth in detail all calculations made and specify, and state your bases for, all assumptions made in reaching your ccnclusions about sper.t fuct and low-level waste storage.
Contention 16 S-16 1.
Soecify with particularity ycur basis for the statement that menty million gallons of radioactive evaporated water are to be vented daily froc. the Susquehanna facility's ccolirg towers.
5-16.2.
Set forth in detail each ca? ulation made and specify, and bases for, all asst =ptions made in reaching your conclusion.
at the amount, radioactive content, and environmental impact of water evapo atec in the cooling towers.
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a 5-16.3.
Specify the effect that you believe inclusion in the cost-benet it analysis of this allegedly now improperly eva'uated econcmic threat will have on the outcomn of that analysis and state in detail the basis for your conclusion.
Contention 17 S-17.1.
Specify with particularity whether, and if so why, you believe that environmental impacts of the 500 kV transmissi n lines for the Susqt. un ta ficility are such as to tip the cost-benefit bElance against authorizing operation' of kbe facility.
5-17.2.
Specify with particularity whether, and if so why, you believe the results of " mini" cost-benefit balances would support requiring either:
a) use of transmission lines of voltages no greater than 230 kV, or b) placing the 500 kV lines (using compressed gas as an insulator) undergrcund.
5-17.3.
Set forth in detail each calculation made and specify, and state your bases for, all-assumpticns made in reaching your conclusions a' out the a
environmental impacts of SCO kV transmissica lines and the costs and benefits of 230 kV and underg aund transmission lines.
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.. 10 CFR 2.740(e) of the Commission's regulations states that a party is undcr a duty seasonably to supplement his response with respect to questions directly addressed to the identity of each person excected to
.; called as an expert witness at the hearing, the suoject matter on which the witness is expected to testi'y and the substance of the witnesses' tes t'. mony.
Section 2.740(e) also states that a party is under a duty seasonably to amend a prior response if he obtains information uoan the basis of which (i) he knows that the response was incorrect when made, or (ii) he knows that the response though correct when made is no longer true and the'dircumstances are such that a failure to amend the response is in substance a knowing etacealment.
Respectfully submitted, s
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f James M. Cutchin, IV Counsel for NRC Staff Datad at Sethesda, Maryland this 21st day of May,1979 3
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UNT'ED STATES OF AMERIi.A NUCLEAR REGULATORY CCMMI.';SION BEFORE THE ATOMIC SAFETY AND LICE.' SING BOARD In the Matter of PENNSYLVANIA POWER AND LIGHT CO.
)
Doc':at Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.
)
50-388
)
(SJsquehanna Steam Electric Station.
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I cereby certify that copies of "NRC STAFF'S MOTION FOR AN ORDER COMPELLING CITIZENS AGAINST NUCLEAR DANGERS TO RESPOND TO THE STAFF'S DISCOVERY REQUESTS" and " PROPOSED FORM OF ORDER COMPELLING DISCOVERY OF CITIZEL AGAINST NUCLEAR DANGER 5" in the above-cactioned proceeding have been served on the following by deoosit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system,. this 28th day of June,1979:
Charles Bechhoefer, P;q., Chairman
- Dr. Judith H. Johnsrud Atomic Safety and Lic::nsirig Co-Director Board Panel Environmental Coalition on U.S. N Jclear Regulatory Commission Nuclear Power Washington, D.C.
20555 433 Orlando Avenue State College, PA 1680i Mr. Glenn 0. Bright" Atomic Safety and Licensf,:3 M. Thomas M. Gerusky, Director Board Par.21 Bureau of Radiation Protection U.S. Nuclear Regulatory Commission Department of Environmen al Washington, D.C.
20555 Resources Commonwealth of Pennsylvania Dr. Oscar H. Paris
- P.O. Box 2063 Atomic Safety and Licensing Harrisburg, PA 17120 Board Panel' U.S. Nuclear Regulatory Commissio1 Ms. C311een Marsh Washington, D.C.
20555 Box S S, RDi4 Mounta:n Top, PA 18707 Jay Sillerg, Esq.
Shaw, Pittman, Pctts and Mrs. Irene Lemanowicz, Chairperson Trowbridge The Citizens Against Nuclear 1800 M Street, N.W.
Dangers Washington, D.C.
20036
_P.O. Box 377 RD#1 Berwick, PA 18503 3 6 pa a
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Susquehanna Environmertal Atomic Saie.j and Licensing Advocates card Panel
- c/o Gerald Schultz, Esq.
U.S. Nuclear Regulatory Comaission 500 South River Street Washington, D.C.
20555 Wilkes-Barre, PA 18702 Docketing and Service Section*
Atomic Safety and Licensing Office of the Secretary Appeal Board Panel
- U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C.
2N55 Washington, D.C.
20555 Bryan A. Snapp, Esq.
Pennsylvania Power & Light Company Two North flinth Street Allentown, PA 18101 James fl. Cutchin, IV Counsel for NRC Staff e
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