ML19257A364
| ML19257A364 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/27/1979 |
| From: | Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Sholly S AFFILIATION NOT ASSIGNED, Environmental Coalition on Nuclear Power, UNION OF CONCERNED SCIENTISTS |
| References | |
| NUDOCS 8001030840 | |
| Download: ML19257A364 (9) | |
Text
4 UNITED STATES OF AMERICA 12/27/79 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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METROPOLITAN EDIS0N COMPANY, _et _al.
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Docket No. 50-289 (Three Mile Island, Unit 1)
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FIRST SET OF NRC STAFF INTERROGATORIES TO INTERVENORS Pursuant to 10 C.F.R. 52.740b, the following general interrogatories are directed to each party admitted in the above-captioned proceeding.~1/
In addition, other specific interrogatories are directed to the Environmental Coalition on Nuclear Power (ECNP), Steven C. Snolly, and the Union of Con-cerned Scientists (UCS). Only the party to who:. the questions are addressed are required to answer.
Each interrogatory not objected to is to be answered separately and fully in writing under oath or affirmation by the individuals having personal knowledge of the answers. The answers should be supplemented as required by 52.740(e). Please do not hesitate to supplement your responses to questions 1668 245 If The Atomic Safety and Licensing Board in its First Special Prehearing Conference Order dated December 18, 1979 admitted as parties to the pro-ceeding the following: Union of Concerned Scientists (UCS); Three Mile Island Alert (TMIA); Mrs. Aamodt; Mr. Sholly; Anti-Nuclear Group Repre-senting York (ANGRY); Environmental Coalition on Nuclear Power (ECNP);
Chesapeake Energy Alliance (CEA); and Newberry Township TMI Steering Committee. The Board deferred ruling on the status of the People Against Nuclear Power (PANE), and admitted Mr. Lewis as a matter of discretion.
In addition, the Commonwealth of Pennsylvania, the Pennsylvania Public Utility Comission, and the Pennsylvania Consumer Advocate are partici-pating as interested state agencies under 10 C.F.R. 82.715(c). Memo-randum and Order dated September 21,1979 at 1.
Special Prehearing Conference transcript at 45. The NRC Staff requests that all the above-named intervenors answer the general interrogatories submitted.
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as more complete answers become available to you. Section 2.740b requires interrogatories to be answered within 14 days of service.
Five days are y
added to this time under 52.710 when service is by mail.
General Interroaatories to be Answered by All Intervenors With regard to each of your admitted issues, provide the following informa-tion:
1.
Identify the individual (s), if any, that you intend to present as witnesses in this proceeding on the sub. ject matter of each of your issues. The identification should include the individual's name, affiliation, and a summary of the educational and professional back-ground of that individual.
2.
Provide a reasonable description of the substance of the testimony of any witness (es) that you intend to have testify with regard to each of your issues, including an identification of all documents that will be relied upon in that testimony.
3.
Following the substantive response to each of the subsequent inter-rogatories posed by the Staff, identify all documents and studies relied upon by you in providing the answers to that interrogatory.
The identification should be specific to the portion of the document or study relied upon. Studies shall include observations, calcula-tions, literature and other types of work, whether recorded i.n writing or not, which consist of an examination or analysis of a pheonomenon.
1668 246
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4.
Following the substantive response to each of the subsequent inter-rogatories posed by the Staff, identify by name and affiliation
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each individual who has knowledge which served as the basis for the answer to that interrogatory.
1668 247
UCS Contention 9 9-1 Identify the specific systems within the core cooling and contain-ment isolation systems as to which it is alleged that there is inadequate provision to inform the operator that such a system has been deliberately disabled.
9-2 With respect to the specific systems identified in response to Question No. 9-1, explain the bases for believing that deliberate disabling is feasible and credible.
9-3 With respect to the specific systems identified in response to Question No. 9-1, explain the deficiencies in the present informa-tion provided to the operator with respect to that system.
UCS Contention 10 10-1 Identify the specific systems within the core cooling and contain-mentisolationsystemastowhichitisaliegedthattheoperator can prevent the completion of a safety function.
UCS Contention 12 12-1 Provide the definition used by UCS for " equipment important to safety."
UCS Contention 13 13-1 Identify the particular element (s) of the staff's method of deter-mining which accidents fall within the design basis accidents which UCS alleges are faulty.
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13-2 Identify any modifications or additions to the Staff's method of determining design basis accidents which UCS would recommend.
13-3 Describe any method or methods for determining design basis acci-dents which UCS would support.
UCS Contention 14 14-1 Identify those systems or components within the core cooling system which UCS believes can either cause or aggravcte an accident or can be called upon to mitigate an accident.
If you can provide only a partial answer, please do so.
14-2 If UCS feels it cannot identify all of the systems or components described in question 14-1 above, describe the method (s) acceptable to UCS for identification of such syst ms or components.
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Sholly Contention 14 14-1 What criteria would be acceptable to you to evaluate licensee's demonstration that it possesses the necessary managerial and ad-ministrative capabilities required to operate Unit 1 in compliance with all applicable rules and regulations while, at the same time, properly and safely decontaminate and restore Unit 27 14-2 Why do you feel licensee must demonstrate its capability to operate Unit I while, at the same time, restorina Unit 27 What do you mean by " restore"?
14-3 Identify any violations of NRC regulations and technical specifi-cations mentioned in the first sentence of Contention No. 14 which are not directly involved in the March 28, 1979 accident.
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ECNP Contention 1(c) 1(c)-1 Identify the cases in which ECNP alleges that the electronic signals sent to the control room record the wrong parameters.
1(c)-2 Describe what ECNP regards as sufficient information on the per-formance capability of components to reasonably ensure that electronic signals will record, accurately and in a timely manner, all neces-sary and correct parameters. Specifically, what type of information is envisioned by ECNP?
Respectfully submitted, b
N Lucinda Low Swartz Counsel for NRC Staff Dated at Bethesda, Maryland this 27th day of December, 1979.
1668 251
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.R In the Matter of METROPOLITAN EDISON COMPANY,
)
(ThreeMileIsland, Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "FIRST SET OF NRC STAFF INTERR0GATORIES TO INTERVEN0RS" in the above-captioned proceeding 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 in-ternal mail system, this 27th day of December,1979.
- Ivan W. Smith, Esq.
Ellyn Weiss, Esq.
Atomic Safety & Licensing Board Panel Sheldon Harmon, Roisman & Weiss U.S. Nuclear Regulatory Commission he50 Washington, D. C.
20555 Washington, D.C.
20006 Dr. Walter H. Jordan Mr. Steven C. Sholly 881 W. Outer Drive 304 South Market Street Oak Ridge, Tennessee 37830 Mechanicsburg, Pennsylvania 17055 Dr. Linda W. Little 5000 Hermitage Drive Mr. Thomas Gerusky Raleigh, North Carolina 27612 Bureau of Radiation Protection Department of Environmental Resources George F. Trowbridge, Esq.
P.O. Box 2063 Shaw, Pittman, Potts & Trowbridge Harrisburg, Pennsylvania 17120 1800 M Street, N.W.
Washington, D. C.
20006 Mr. Marvin I. Lewis 6504 Bradford Terrace Karin W. Carter, Esq.
Philadelphia, Pennsylvania 19149 505 Executive House P. O. Box 2357 Metropolitan Edison Company Harrisburg, Pennsylvania 17120 Attn:
J. G. Herbein, Vice President P.O. Box 542 Reading, Pennsylvania 19603 Honorable Mark Cohen 512 E-3 Main Capital Building Ms. Jane Lee Harrisburg, Pennsylvania 17120 R.D. 3; Box 3521 Etters, Pennsylvania 17319 1668 252
. Walter W. Cohen, Consumer Advocate Holly S. Keck Department of Justice Anti-Nuclear Group RepresenFing Strawberry Square,14th Floor York Harrisburg, Pennsylvania 17127 245 W. Philadelphia Street York, Pennsylvania 17404 Robert L. Knupp, Esq.
Assistant Solicitor John Levin, Esq.
Knupp and Andrews Pennsylvania Public Utilities Comm.
P.O. Box P Box 3265 407 N. Front Street Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17108 Jordan D. Cunningham, Esq.
John E. Minnich, Chairman Fox, Farr and Cunningham Dauphin Co. Board of Commissioners 2320 North 2nd Street Dauphin County Courthouse Harrisburg, Pennsylvania 17110 Front and Market Sts.
Harrisburg, Pennsylvania.17101 Theodore A. Adler, esq.
Widoff Reager Selkowitz & Adler
- Atomic Safety and Licensing Appeal Board Post Office Box 1547
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U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17105 Washington, D. C.
20555 I$ M jorie M. Aamodt Atomic Safety and Licensing Board Panel RD U.S. Nuclear Regulatory Commission Coate$;ville, Pennsylvania 19320 Washington, D. C.
20555 Docketing and Service Section U.S. Nuclear Regulator.v Commission Ms. Karen Sheldon Washington, D. C.
20555 Sheldon, Harmon, Roisman & Weiss 1725 I Street, N. W.
Robert Q. Pollard Suite 506 Chesapeak Energy Alliance Washington, D. C.
20006
'609 Montpelier Street Baltimore, Maryland 21218 Chauncey Kepford Judith H. Johnsrud Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant Postponement 2610 Grendon Drive Wilmington, Delaware 19808 Q'u(AA]/1hO IXW '
}fy L cinda Low Swartz' Counsel for NRC Staff 1668 253