ML19247A753
| ML19247A753 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/24/1979 |
| From: | Black R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19247A746 | List: |
| References | |
| NUDOCS 7908020264 | |
| Download: ML19247A753 (5) | |
Text
05/24/79 NRC PUBLIC DOCIDfENT ROOM UNITED STATES.0F AMERICA NUCLEAR REGULATORY COMMISSION
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cp BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
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In the Matter of
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Ol-DETROIT EDISON COMPANY
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Docket No. 50-341 m 301979 > q
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Enrico Fermi Atomic Power Plant,
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- 'g" Unit 2)
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N NRC STAFF'S WRITTEN INTERROGATORIES TO CITIZENS FOR EMPLOYMENT AND ENERGY (CEE)
Pursuant to 10 CFR 2.740b of the Com'ission's regulations and the Licensing Board's Order dated March 21, 1979,.:he NRC Staff requests that CEE answer the interrogatories set forth below.1 As required by 10 CFR 2.
- 0(b), each interrogatory shall ae answered separately and fully, in wrir! g and under oath or affirmation, and the answers shall be signed by the person (s) making them.
In addition, pursuant to 10 CFR 2.741, the NRC Staff requests th.t CEE make available for Staff inspection and copying (or provide copies of), those documents referred to by CEE in its answers. /
2 Contention 6 C6-1.
With respect to Contention 6(a), identify in detail:
a) how and under what conditions the reactor coolant piping will be susceptible to stress corrc sion cracking; and b) what procedures, if any, for the inspection and
/! [; }} maintenance of reactor coolant piping by the Appli-cant are considered inadequate by CEE. 1! The answers are.to be provided by June 29, 1979, as required by the Licensing Board's Order. 2/ - Of course, if the docu=ent was prepared by the NRC Staff or its con-sultant, or was submitted by the Applicant in connection with the captioned matter, it need not be made available by CEE. 7908ogggz,y C6-2. With respect to Contention 6(b), identify in detail: a) the sources of heat, radiation, and oxidation and how these conditions will cause a deterioration of elec-trical cables; and b) what assumptions or calculations were made by CEE to determine the cause or effect of such deterioration, Contention 14 C14.1. State specifically and in detail: a) what recent NRC publicaticns and cases referred to in Contention 14(1) indicate that the mining, milling, enrichment, and fabrication of the uranium used at Fermi 2 will present a very serious health hazard; b) what evidence indicates that the long-term effects of cndon gas from mining and milling tailings may cause hundreds of thousands of deaths due to cancer and genetic effects; c) the assumptions that CEE believes should be made in estimating radon releases; d) the effect that CEE believes each assumption listed above has on the estimate of radon releases; e) the amcunt of radon-222 that CEE alleges will be released and set forth in detail each calculation made and specify, and state your bases for, all assumptions made by you in estimating the releases; f) the errors CEE believes to exist in the estimates of the health effects of radon-222, the magnitude of such errors and the causes of such errors; g) each health effect of radon-222 that CEE believes will occur and state in detail how that health effect is caused; h) all calculations made by CEE and specify, and state your bases for, all assumptions made in reaching conclusions about t'.e heal *5 effects of radon-222; i) what isotopes, other than radon-222, that will cause a very serious health hazard in mining, milling, enrichment, and fabrication of uranium activisies; j) all errors that CEE believes to exist in the estimates of the health effects of isotopes other than radon-222, the magnitude of such errors and the causes of such errors; k) what health effects will be caused by isotopes other than radon-222 and state in detail how that health effect is caused; 1) all calculations made by CEE and specify, and state your bases for, all assumptions made in reaching your conclusions about the health effects of isotopes other than radon-222; m) any other health hazard from mining, milling, enrich-ment, and fabricatien operations that CEE contends to have been documented in recent NRC publications and cases other than radon-222 and the isotopes identified in the responses to the previous interrogatories; and n) the effect that CEE alleges that all of the above identified health hazards will have on the outcome of the cost-benefit an 1ysis for Fermi 2, and state in detail the basis for your conclusion. Respectfully subm *ted, // IS RkchardL. lack Counsel for NRC Starf Dated at Bethesda, Maryland this 24th day of May, 1979 446 237
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.'.1.\\tISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) Detroit Edison Company ) Docket No. 50-341 ) (Enrico Fermi Atomic Power Plant, ) Unit 2) ) CERTIFICATE ~ OF SERVICE I hereby certify that copies of "NRC STAFF'S WRITTEN INTERROGATORIES TO CITIZENS FOR EMPLOYMENT AND ENERGY (CEE)" in the above-captioned proceed-ing have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, htis 24th day of May, 1979: Charles Bechhoefer, Esq., Chairman
- Mr. Jeff Alson Atomic Safety and Licensing Board 772 Green Street Panel Ypsilanti, Michigan 48197 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. David Hiller University of Michigan Law School Dr. David R. Schink Hutchins Hall Department of Oceanography Ann Arbor, Michigan 48109 Texas A & M University College Station, Texas 77340 Atomic Safety and Licensing Board Panel
- Mr. Frederick J. Shon*
U.S. Nuclear Regulatory Commission Atomic Safyty and Licensing Board Washington, D. C. 20555 Panel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D. C. 20555 Appeal Panel (5)* U.S. Nuclear Regulatory Commission Washington, D. C. 20555 446 238
~ , Eugene B. Thomas, Jr., Esq. Docketing and Service Section (3)* LeBoeuf Lamb, Leiby & MacRae Office of the Secretary 1757 N Street, N. W. U.S. Nuclear Regulatory Commission Washing ton, D. C. 20036 Washington, D. C. 20555 Peter A. Marquardt, Esq. The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Gil R4 chard L. lack Counsel for NRC Staff '/50 (J/ .}}