ML19257C342

First Set of Interrogatories Directed to Environ Coalition on Nuclear Power.Contains Request for Description & Identification of Measures Which Intervenor Contends Should Be Taken to Minimize Operator Errors.W/Certificate of Svc

ML19257C342
Person / Time
Site:	Three Mile Island
Issue date:	01/18/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Environmental Coalition on Nuclear Power
References
NUDOCS 8001280459
Download: ML19257C342 (45)

Text

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Dated: January 18, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LTCENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR ENVIRONMENTAL COALITION ON NUCLEAR POWER These interrogatories are filed pursuant to 10 C.F.R.

S2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation.

Licensee requests that Intervenor Environmental Coalition on Nuclear Power ("ECNP") answer each of these interrogatories within the time specified in S2.740b to the extent that responsive information is presently available to ECNP. With respect to those interrogatories for which complete and responsive information is not now available to ECNP, Licensee requests that revised answers be provided prior to the close of the discovery period established in the Licensing Board's December 18, 1979 First Special Prehearing Conference Order.

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Any reference to Intervenor Environmental Coalition on Nuclear Power ("ECNP") shall be deemed to include all members of ECNP. When knowledge or information of ECSP is requested, such request includes knowledge or information of ECNP's members and, unless privileged, its attorneys iif any).

The following definitions apply to each of the inter-rogatories below:

A. " Document" means all writings and records of every type including, but not limited to memoranda, tapes, correspon-dence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, ct'.letins, minutes, notes, diaries, logs, testimony, speeches, articles, transcripts and all other records, written, electrical, mechanical or otherwise.

B. " Identify" means:

(1) With respect to a natural person, name, present or last known home or business address, present or last known job title or position, and the dates of tenure in that posi-tion. A request for the identification of "the source of each and every fact" is not limited (where the " source" of a fact is .

a person) to sources who are ECNP members, but rather includes all persons (whether or not ECNP members) who were sources of the fact. Similarly, a request for the identification of "all persons having any information . . . is not limited to ECNP members, but rather includes all persons whom ECNP knows to have "any information or knowledge."

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(2) With respect to a document, the type of document (e.g., letter, record, list, memorandum, memorandum of tele-phone or face-to-face conversation, etc.), date of the docu-ment, title of the document, subject of the document, name of person who prepared the document, and name of person for whom the document was prepared or to whom it was delivered.

Interrogatories on Contention No. 1 1(b)-1 Describe each measure which ECNP contends should be taken to minimize operator error.

1(b)-2 Describe each measure which ECNP contends should be taken to minimize mechanical, electrical, or electronic failure.

1(c)-1 Identify each pertinent component of the control system to which this contention refers. Confine your response to components involved in sending signals to the control room which are related to the core cooling and containment isolation systems. -

1(d)-1 Identify each monitoring instrument referred to in the first paragraph of this contention and each radiation monitor referred to in the second paragraph of this contention.

Confine your answer to important safety related monitoring instruments and to important safety related radiation monitoring equipment which are related to core cooling and containment isolation systems.

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e 3 1(d)-2 Specify the indicating ranges which you contend should be provided for each of the instruments and monitors identified in answer to interrogatory 1(d)-1 and the basis therefor.

1(d)-3 Does ECNP contend that the ranges specified in answer to interrogatory 1(d)-2 should be designed to measure in-plant accident conditions more severe than conditions associated with the design basis accidents for TMI-1? If so, describe each accident scenario for which ECNP contends that the ranges should be designed. In answering this interrogatory bear in mind that the references in Contention No. 1(d) to the worst case and worst possible accidents were not accepted by the Licensing Board.

l(f)-1 Does ECNP intend to adopt UCS Contention No. 12?

If so, answer interrogatories 1(f)-2 through 1(f)-5 below.

1(f)-2 Identify each item of failed equipment in the containment and auxiliary buildings which is covered by UCS Contention No. 12. -

1(f)-3 State as to each item of equipment identified in _

answer to interrogatory 1(f)-2 whether ECNP contends that the equipment failed because of the TMI-2 accident environment and, if so, the technical basis for such contention.

1(f)-4 Provide as to each item of equipment identified in answer to interrogatory 1(f)-2 the basis for ECNP's conten-tion that such equipment was previously deemed to be environmentally qualified.

1825 $16 1(f)-5 Identify each item of " safety-related equipment" in the TMI-l containment and auxiliary buildings which ECNP contends must be demonstrated to be environmentally qualified.

l(f)-6 Does ECNP intend to adopt UCF Contention No. 14?

If so, answer interrogatories 1(f)-7 thrucgh 1(f)-10 below.

1(f)-7 Define " adverse effect on the integrity of the core."

1(f)-8 Identify each system or component relating to the core cooling system presently classified as non-safety-related which ECNP contends must be identified and classified as components important to safety and required to meet all safety-grade design criteria.

1(f)-9 Explain how each system or component identified in answer to interrogatory 1(f)-8 can directly or indirectly affect temperature, pressure, flow and/or reactivity.

1(f)-10 Explain how each effect identified in answer to interrogatory 1(f)-9 can have an adverse effect on the integ-rity of the core. ~

1(g)-1 Describe the instrumentation proposed by ECNP for measurement of the water level in the reactor pressure vessel. Explain whether.- and if so how, such instrumentation would provide reliable and unambiguous indication of adequate core cooling under all accident conditions.

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1(h)-1 Refer to section 2.1.1.5 (Containment Isolation Modifications) of the Restart Report. Do the modifications described in that section satisf actoril; respond to this contention? If not, explain fully any dissatisf action by ECNP with the modifications.

1(i)-1 Specify and explain each inadequacy w: . ECNP contends exists between the operator and the control room panel.

1(i)-2 Describe each alteration in the control room and control panel design proposed by ECNP.

Interrogatories on Contention No. 3 3-1 Define the term " serious mechanical malfunction" as that term is used in Contention No. 3.

3-2 Identify all of the " repeated serious mechanical malfunctions" which ECNP contends existed at Unit 2 prior to the commercial operation of that unit.

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a. For each alleged malfunction listed, set forth each and every fact relating to or bearing upon the allegation, -

including a brief description of the alleged malfunction, and the date the alleged malfunction occurred or otherwise became known.

b. For each alleged malfunction listed, identify all documents, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.

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c. For each a:leged malfunction listed, identify all persons having any information or knowledge supporting or relatlag to the allegation.

3-3 Identify all of the " repeated serious mechanical malfunctions" which ECNP contends existed, but were not corrected prior to the commercial operation of Unit 2.

a. For each alleged malfunction listed, set forth each and every fact relating to or bearing upon the allegation, including a brief description of the alleged malfunction, and the date of the alleged malfunction.

b. For each alleged malfunction listed, identify all documents, and the particular parts thereof, containing any evidence er information relating to or bearing upon the allegation.

c. For each alleged malfunction listed, identify all persons having any information or knowledge supporting or relating to the allegation.

3-4 In referring to an incident involving the Unit 2 -

" auxiliary feedwater pumps", does ECNP intend to refer more _

specifically to the Unit 2 " emergency feedwater valves", also known as the " auxiliary feedwater valves"? If not:

a. Set forth each and every fact relating to or bearing upon the allegation, including the date of the alleged incident.

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b. Identify all documents, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

3-5 Identify the " lax conditions" which ECNP alleges to have existed in the Unit 2 control room.

3-6 Is the term " safety and safeguards violations", as that term is used in the allegation, synonymous with those Licensee actions and omissions which have resulted in Notices of Violation?

If so, answer only "a":

a. Identify, by reference to specific NRC docu-ments, the specific Notices of Violation to which ECNP is referring in Contention No. 3.

If not, answer "b", "c", "d", and "e":

b. Define the terms " safety violation" and

" safeguards violation" as those terms are used in the allega- -

tion.

c. Identify all " safety and safeguards violations" which ECNP contends have occurred in the operation of Unit 1 since 1974. Identify all such viciations for which Licensee has received Notices of Violation by reference to specific NRC documents. For each alleged violation listed for which Licensee received no Notice of Violation, set forth each and 1826 $20

every fact relating to or bearing upon the allegation, includ-ing a brief description of the alleged violation, and the date of the alleged violation,

d. For each alleged violation listed, identify all documents, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.

e. For each alleged violation listed, identify all persons having any information or knowledge supporting or relating to the allegation.

Interrogatories on Contention No. 5 5-1 In alleging the " cumulative impact" of " radiation exposure . . . received from the TMI site during the pre-March 28, 1979 operations of Units 1 and 2, plus the exposures . . .

received during . . . the TMI-2 accident, plus future doses, from either normal or unanticipated emissions from a reopened TMI-l or additional planned or unplanned releases of radioac- -

tive gases, water, or solid materials from TMI-2," does ECNP contend that the combination of the radiation associated with those sources will have a greater total effect (i.e., a synergistic effect) on the health and safety of ECNP members and residents of the Susquehanna Valley and Southeastern Pennsylvania than will the simple sum of the radiation from those sources? If not, set forth with precision and i825 321

particularity the relationship among the listed sources which ECNP describes as the " cumulative impact" of radiation from those sources.

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

5-2 Describe in detail the health and safety effects on ECNP members and residents of the Susquehanna Valley and Southeastern Pennsylvania which ECNP contends will result from

" radiation exposure . . . received from the TMI site during the pre-March 28, 1979, operations of Units 1 and 2, plus the exposures . . . received during . . . the TMI-2 accident, plus fucure doses, from either normal or unanticipated emissions from a reopened TMI-l or additional planned or unplanned ~

releases of radioactive gases, water, or solid materials from .

TMI-2."

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

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c. Identify all persons having any information or knowledge supporting or relating to the allegation.

5-3 Identify all estimates by Dr. Chauncey Kepford, Dr.

Judith Johnsrud, and/or other members cf ECNP, as to the release of radioactive " gases, water or solid materials" as a result of the Unit 2 accident - whether expressed as individual or population doses or otherwise. For each estimate listed, specify the element and isotope allegedly released, the form of the alleged release, the date or period of the alleged release, the name of the individual who made the estimate, the date of the estimate (the approximate date if the exact date is not known), and the form of the statement in which the estimate was given - oral and/or written, including but not limited to speeches, testimony, newsletters, newspaper articles, period-icals, books, pamphlets, leaflets and texts of speeches and testimony. If a statement in which an estimate was made orally has been reported or recorded in written form, please identify the report or record with specificity, including the type of record or report, the title of the record or report, the name of the document (if any) in which the record or report is included, and the date of publication.

5-4 State the date on which ECNP will serve its revised Contention No. 5 upon the other parties to this proceeding, in accordance with the instructions of the Board on page 41 of the "First Special Prehearing Conference Order" (December 18, 1979).

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Interrogatories on Contention No. 7 7-1 Does ECNP intend to adopt UCS Contention No. 10? If so, answer interrogatories 7-2 through 7-4 below.

7-2 Identify each safety function related to the core cooling and containment isolation systems as to which ECNP contends that the design of a safety system must be modified so that no operator action can prevent the completion of such safety function once initiated.

7-3 Explain as to each safety function identified in answer to interrogatory 7-2 the criteria proposed by ECNP for determining completion of the safety function.

7-4 Describe as to each safety function identified in answer to interrogatory 7-2 the design modification (s) proposed by ECNP so that no operator action can prevent the completion of such safety function once initiated.

Interrogatories on Contention No. 14 14-1 Does ECNP intend to adopt UCS Contention No. 13? If so, answer interrogatories 14-2 through 14-5 below.

14-2 Describe the accidents which ECNP contends are credible and not bounded by the TMI-l design basis accidents.

14-3 Explain as to each accident identified in answer to interrogatory 14-2 the nexus between such accident and the TMI-2 accident.

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14-4 Explain what ECNP means when it contends that an accident is not " bounded" by the design basis accidents for TMI. Indicate in particular as to each accident identified in answer to interrogatory 14-2 whether the term " bounded" refers to accident events or accident consequences or both.

14-5 Describe the cr_ ceria proposed by ECNP to be used for selecting credible accidents to be considered.

Interrogatories on Contention No. 16 16-1 Does ECNP intend to adopt TMIA Contention No. 1, as allowed by the Board in its discussion of ECNP Contention No.

16, at page 43 of the "First Special Prehearing Conference Order" (December 18, 1979)? If so, answer the following interrogatories, 16-2 through 16-19, with respect to TMIA Contention No. 1.

16-2 Identify all dates on which ECNP contends that, as a result of the accident at Unit 2, I-133 was released into the atmosphere "in excess of permissible limits." -

a. Identify the 34 day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the 26.84 Ci measurement specified in the allegation.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation, including the 26.84 Ci measurement specified in the allegation.

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d. Identify all persons having any information or knowledge supporting or relating to the allegation, including the 26.84 Ci measurement specified in the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to I-133.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to I-133.

16-3 Identify all dates on which ECNP contends that, as a result of the accident at Unit 2, Krypton-88 was released into the atmosphere "in excess of permissible limits."

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the 6.lE+4 Curies measurement specified in the allegation,

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation, including the 6.1E+4 Curies measurement specified in the allegation. .

c. Identify all persons having any information or knowledge supporting or relating to the allegation, including the 6.lE+4 Curies measurement specified in the allegation.

d. Define " permissible limits" as that term is used in the allegation with respect to Krypton-88.

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e. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term ic used in the allegation with respect to Krypton-88.

16-4 Identify all dates on which ECNP contends that, as a result of the accident at Unit 2, Xenon 133M was released into the atmosphere "in excess of permissible limits."

a. Identify the ten day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the measurement of 170,000 Curies specified in the allegation.

c. Identify all documents, and the particu) parts thereof, containing any evidence or information bearing upon or relating to the allegation, including the measurement of 170,000 Curies specified in the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation, including the measurement of 170,000 Curies specified in the allegation. -

e. Define " permissible limits" as that term is used in the allegation with respect to Xenon 133M.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Xenon 133M.

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16-5 Identify all dates on which ECNP contends that, as a result of the accident at Unit 2, Xenon 135 was released into the atmosphere "in excess of permissible lir.its."

a. Identify the seven day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the measurement of 1.5 million Curies specified in the allegation.

c. Identify all documents, and the particular parts thereof, containing any evidence or information relating to the allegation, including the measurement of 1.5 million Curies specified in the allegation.

d. Identify all persons having any information or knowledge supporting or relating to the allegation, including the measurement of 1.5 million Curies specified in the allega-tion.

c. Define " permissible limits" as that term is used in the allegation with respect to Xenon 135. -

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Xenon 135.

16-6 Identify all dates on which ECNP contends that, as a result of the accident at Unit 2, Xenon 135M was released into the atmosphere "in excess of permissible limits."

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a. Identify the three day period specified in the allegation.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based, including the measurement of 140,000 Curies specified in the allegation.

c. Identify all documents, and the particular parts thereof, containing any evidence or information relating to the allegation, including the measurement of 140,000 Curies specified in the allegation.

d. Identify all persons having any information or knowledge rupporting or relating to the allegation, including the measc.rement of 140,000 Curies specified in the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Xenon 135M.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that

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term is used in the allegation with respect to Xenon 135M.

16-7 Identify all isotopes of Xenon, other than Xenon 133M, Xenon 135, and Xenon 135M, which ECNP contends were released into the atmosphere "in excess of permissible limits" as a result of the accident at Unit 2.

a. For each isotope listed, identify the dates on which ECNP contends that releases "in excess of permissible limits" occurred as a result of the accident at Unit 2.

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b. For each isotope listed, identify the total quantity which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

c. For each isotope listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

d. For each isotope listed, identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

e. For each isotope listed, identify all persons having any knowledge supporting or relating to the allegation.

f. Define " permissible limits" as that term is used in the allegation with recpect to each of the isotopes of Xenon listed, other than Xenon 133M, Xenon 135, and Xenon 135M.

g. Identify all NRC and other agency regulations upon which ECNP relies ir defining " permissible limits" as that term is used in the allegation with respect to each of the isotopes of Xenon listed, other than Xenon 133M, Xenon 135, and -

Xenon 135M.

16-8 Identify all dates on which ECNP contends that Ruthenium-103 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Ruthenium-103 which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

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b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Ruthenium-103.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Ruthenium-103.

16-9 Identify all dates on which ECNP contends that Ruthenium-106 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Ruthenium-106 which ECNP contends was released into the atmosphere as a result of the accident at Unit 2. ~

b. Set forth each and every fact and the source of .

each and every fact upon which the allegation is based.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

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e. Define " permissible limits" as that term is used in the allegation with respect to Ruthenium-106.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Ruthenium-106.

16-10 Identify all dates on which ECNP contends that Tritium was released into the atmosphere "in excess of per-missible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Tritium which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation. -

e. Define " permissible limits" as that term is used .

in the allegation with respect to Tritium.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Tritium.

16-11 Identify all dates on which ECNP contends that Bromine-82 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

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a. Identify the total quantity of Bromine-82 which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Bromine-82.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-82.

16-12 Identify all dates on which ECNP contends that Bromine-83 was released into the atmosphere "in excess of

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permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Bromine-83 which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

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d. Identify all persons having any knowledge supporting or relating to the allegation,

e. Define " permissible limits"~as that term is used in the allegation with respect to Bromine-83.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-83.

16-13 Identify all dates on which ECNP contends that Bromine-84 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Bromine-84 which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation. -

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Bromine-84.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-84.

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1C -14 Identify all dates on which ECNP contends that Bromine-85 was released into the atmosphere "in excess of permissible limits," as a result of the accident at Unit 2.

a. Identify the total quantity of Bromine-85 which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

b. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

c. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

d. Identify all persons having any knowledge supporting or relating to the allegation.

e. Define " permissible limits" as that term is used in the allegation with respect to Bromine-85.

f. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to Bromine-85.

16-15 Identify all radioactive gases--other than I-133, -

Krypton-88, Xenon 133M, Xenon 135, Xenon 135M, isotopes of Xenon identified in response to 16-7, Ruthenium-103, Ruthenium-106, Tritium, Bromine-82, Bromine-83, Bromine-84 and Bromine-85--which ECNP contends were released into the atmo-sphere "in excess of permissible limits" as a result of the accident at Unit 2.

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a. For each gas listed, identify the dates on which ECNP contends that releases "in excess of permissible timits" occurred as a result of the accident at Unit 2.

b. For each gas listed, identify the total quantity which ECNP contends was released into the atmosphere as a result of the accident at Unit 2.

c. For each gas listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

d. For each gas listed, identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

e. For each gas listed, identify all persons having any knowledge supporting or relating to the allegation.

f. Define " permissible limits" as that term is used in the allegation with respect to each gas listed.

g. Identify all NRC and other agency regulations upon which ECNP relies in defining " permissible limits" as that term is used in the allegation with respect to each of the -

gases listed.

16-16 Define "long term health effects" as that term is used in the allegation.

16-17 Describe in detail the "long term health effects" which ECNP contends that persons residing within 20 miles of the site will suffer as a result of the release into the atmosphere, at levels allegedly "in excess of permissible limits," of the following gases:

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a. I-133.

b. Krypton-88.

c. Xenon 133M.

d. Xenon 135.

e. Xenon 135M.

f. Each of the isotopes of Xenon identified in response to 16-7, above.

g. Ruthenium-103.

h. Ruthenium-106.

i. Tritium.

j. Bromine-82.

k. Bromine-83.

1. Bromine-84.

m. Bromine-85.

n. Each of the gases identified in response to 16-15, above.

16-18 In alleging that " radiation affects the body in a cumulative manner," does ECNP contend that the radiation associated with the normal operation of Unit 1 and the radia- -

tion associated with the Unit 2 accident will have a greater total effect (i.e., a synergistic effect) on human health than the simple sum of the radiation associated with the normal operation of Unie 1 and the radiation associated with the Unit 2 accident? If not, set forth with precision and particularity the relationship ECNP describes in its allegation that

" radiation affects the body in a cumulative manner."

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a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

16-19 Describe with precision and particularity the inter-relationship which ECNP alleges among (1) the radiation associated with the normal operation of Unit 1, (2) the radiation associated with the accident at Unit 2, and (3) the

" planned and unplanned discharges of radiation" which ECNP contends will occur during the cleanup of Unit 2, including all combinations of these three sources of radiation, with respect to human health.

a. Are the terms " cumulative effect" and

" cumulative manner" (as that term is defined in response to 16-18, above) synonymous? If not, define " cumulative effect" as the term is used in the contention and distinguish it from -

" cumulative manner," as that term is used in the contention.

b. As to each interrelationship which ECNP alleges between and among the three numbered sources of radiation identified in 16-19, set forth each and every fact and the source of each and every fact upon which the allegation is based.

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c. As to each interrelationship which ECNP alleges between and among the three numbered sources of radiation identified in 16-19, identify all documents containing any

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evidence or information bearing upon or relating to the allegation.

d. As to each interrelationship which ECNP alleges between and among the three numbered sources of radiation identified in 16-19, identify all persons having any informa-tion or knowledge supporting or relating to the allegation.

16-20 Does ECNP intend to adopt TMIA Contention No. 2, as allowed by the Board in its discussion of ECNP Contention No.

16, at page 43 of the "First Special Prehearing Conference Order" (December 18, 1979)? If so, answer the following interrogatories, 16-21 through 16-35, with respect to TMIA Contention No. 2.

16-21 Describe the nature and source of the " additional low-level radiological discharges from Unit #1" to which ECNP refers in the contention. ~

a. Define " low-level radiological discharge" as that term is used in the allegation.

b. Identify all NRC and other agency regulations upon which ECNP relies in defining " low-level radiological discharge" as that term is used in the allegation.

16-22 Describe in detail any and all "significant adverse effect[s] on the water quality in the Susquehanna" which ECNP 1825 33SL

contends will result solely from the " low-level radiological discharges from Unit #1."

a. For each effect listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each effect listed, identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. For each effect listed, identify all persons having any information or knowledge supporting or relating to the allegation.

16-23 Identify the "high-level discharges" (including the source of each discharge, an analysis of the discharge, and the date of discharge) which ECNP contends have been discharged in the Susquehanna "as a result of the TMI accident."

a. For each diccharge listed, set forth each and every fact and the source of each and every fact upon which the allegation is based. -

b. For each discharge listed, identify all docu- _

ments, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. For each discharge listed, identify all persons having any information or knowledge supporting or relating to the allegation.

l825 340

d. Define "high-level discharge" as that term is used in the allegation.

e. Identify all NRC and other agency regulations upon which ECNP relies in defining "high-level discharge" as that term is used in the allcgation.

16-24 Identify the "high level discharges" (including the source of each discharge and an analysis of the discharge) which ECNP contends will be discharged in the Susquehanna "as a result of the TMI accident."

a. For each discharge listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each discharge listed, identify all docu-ments, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. For each discharge listed, identify all persons having any information or knowledge supporting or relating to ~

the allegation.

16-25 Describe in detail any and all "significant adverse effect[s] on the water quality in the Susquehanna" which ECNP contends have resulted and will result from the "high level discharges" identified in response to 16-23, above.

a.

For each effect listed, set forth each and every fact and the source of each and every fact upon which the allegation ir based.

)@2$ j4}

b. For each effect listed, identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. For each effect listed, identify all persons having any information or knowledge supporting or relating to the allegation.

16-26 Describe in detail any and all "significa7t adverse effect[s] on the water quality in the Susquehanna" which ECNP contends will result from the "high-level discharges" identi-fied in response to 16-24, above.

a. For each effect listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each effect listed, identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. For each effect listed, identify all persons having any information or knowledge supporting or relating to -

the allegation.

16-27 Describe in detail any and all "significant adverse effect[s] on the water quality in the Susquehanna" which ECNP alleges will result from the combination of the " low-level radiological discharges from Unit #1, in addition to those high-level discharges that have [been] and will be discharged as a result of the TMI accident."

1825 342

a. For each effect listed, set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. For each effect listed, identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. For each effect listed, identify all persons having any information or knowledge supporting or relating to the allegation.

16-28 In alleging that the " low-level radiological dis-charges from Unit #1, in addition to ... high-level discharges

... as a result of the TMI accident, will have a significant adverse effect on the water quality in the Susquehanna," does ECNP contend that the low-level discharges associated with the normal operation of Unit 1 and the alleged high-level dis-charges resulting from the Unit 2 accident will have a greater total effect (i.e., a synergistic effect) on the water quality of the Susquehanna than the simple addition of the low-level -

discharges associated with the normal operation of Unit 1 to the alleged high-level discharges resulting from the Unit 2 accident? If not, set forth with precision and particularity the relationship which ECNP contends exists between the " low level radiological discharges from Unit #1" and the alleged "high level discharges that have [been] and will be discharged as a result of the TMI accident."

1825 343

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledge supporting or relating to the allegation.

16-29 Describe in detail the interrelationship which ECNP alleges between " low-level radiological discharges from Unit

1. 1" and the alleged "high-level discharges that have [been] and will be discharged as a result of the TMI accident," as they affect the water quality of the Susquehanna.

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based,

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or -

knowledge supporting or relating to the allegation.

16-30 Describe the nature and source of the " additional discharges of radiation into the Susquehanna" which ECNP alleges would occur "[i] f Unit #1 were to reopen while decon-tamination of Unit #2 was continuing."

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

j82h 34k

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or knowledgc supporting or relating to the allegation.

d. Does ECNP contend that these " additional discharges of radiation into the Susquehanna" will occur only if Unit 1 reopens before the decontamination of Unit 2 has been completed? If so, explain why the discharges will not occur if Unit 1 is not reopened until the decontamination of Unit 2 has been completed.

e. Are the " additional discharges of radiation into the Susquehanna" referred to in this interrogatory synonymous with the " additional low-level radiological discharges from Unit #1" described in 16-21, above? If not, explain the difference between the two terms as they are used in the respective allegations.

16-31 Describe the nature and source of the " discharges of -

radioactive wastewater into the Susquehanna" which ECNP alleges may occur during decontamination.

16-32 Identify all sequences of events which ECNP contends may result in " discharges of radioactive wastewater into the Susquehanna" during decontamination.

a. For each sequence of events listed, set forth each and every fact and the source of each and every fact upon which the ellegation is based.

1825 545

b. For each sequence of events listed, identify all documents, and the particular parts thereof, containing any evidence or informa tion bearing upcn 0: relating to the allegation.

c. For each sequence of events listed, identify all persons having any information or knowledge supporting or relating to the allegation.

16-33 Define the "present plan" for decontamination to which ECNP refers in the contention.

16-34 Describe in detail any and all " presently ascertain-able damage to the fish and wildlife in and around the river" which ECNP alleges to be a result of the accident at Unit 2.

a. Set forth each and every fact and the source of each and every fact upon which the allegation is based.

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to the allegation.

c. Identify all persons having any information or -

knowledge supporting or relating to the allegation.

16-35 Describe the " pre-March 28, 1979 levels" to which ECNP contends that Unit 2 should be decontaminated prior to consideration of reopening Unit 1.

1825 .S46

Interrogatories on Contention No. 19 19-1 Describe with particularity and explain the basis for ECNP's claim of a "further radiological contamination of the TMI plant site during clean-up and decommissioning of the damaged TMI-2 reactor."

19-2 Identify each risk to the safe operation of TMI-1 which ECNP contends is associated with the possibility of the radiological contamination described in the response to Interrogatory 19-1. For each risk so identified:

a. Set forth each and every fact and the source of each and every fact upon which ECNP bases its conclusion.

b. Identify all documents, and the partionlar parts thereof, containing any evidence or information bearing upon or relating to ECNP's conclusion.

c. Identify all persons having any inform 7 tion or knowledge supporting or relating to ECNP's conclusion.

19-3 Explain the basis for ECNP's claim that "all decon- _

tamination and repair operations at the damaged TMI-2" are

" experimental" in nature.

19-4 Identify each risk to the safe operation of TMI-1 (other than those already identified in response to Interrogatory 19-2) which ECNP contends is associated with the presence of the damaged TMI-2 reactor and the decontamination and repair work taking place at TMI-2. For each risk so identified:

1825 347

a. Set forth each and every fact and the source of each and every fact upon which ECNP bases its conclusion.

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to ECNP's conclusion,

c. Identify all persons having any in ormation or knowledge supporting or relating to ECNP's conclusion.

19-5 Describe with particularity and explain the basis for ECNP's claim of "[u] nforeseen problems, difficulties, and accidents at TMI-2 at unpredictable times in the future."

19-6 For each unforeseen problem, difficulty or accident described in the response to Interrogatory 19-5, identify the TMI-l facility which ECNP contends may be required to be used on an emergency basis "to prevent the release of radioactive materials into the offsite environment."

19-7 Identify each risk to the safe operation of TMI-l (other than those already identified in response to

~

Interrogatories 19-2 and 19-4) which ECNP contends is associated with the use of the TMI-l facilities described in the response to Interrogatory 19-6. For each risk so identi-fied:

a. Set forth each and every fact and the source of each and every fact upon which ECNP bases its conclusion, i825 54B'

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to ECNP's conclusion.

c. Identify all persons having any information or knowledge supporting or relating to ECNP's conclusion.

19-8 Describe with particularity and explain the basis for ECNP's claim of a "present uncertainty concerning the safe operability of the experimental EP:COR II decontamination system."

19-9 Describe with particularity and explain the basis f o, ECNP's claim of a "pending overflow of intermediate and high-level radioactive waste water."

19-10 Describe with particularity and explain the basis for ECNP's claim of a " potential for increased leakage of reactor coolant or other contaminated water in quantities requiring utilization of TMI-l for storage purposes."

19-11 Identify each risk to the safe operation of TMI-l (other than those already identified in response to Interrogatories 19-2, 19-4 and 19-7) which ECNP contends is -

associated with the matters described in the response to Interrogatories 19-8, 19-9 and 19-10. For each risk so identified:

a. Set forth each and every fact and the source of each and every fact upon which ECNP bases its conclusion, i825 349

b. Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to ECNP's conclusion.

c. Identify all persons having any information or knowledge supporting or relating to ECNP's conclusion.

19-12 Does ECNP contend that the physical separation ^'

Units 1 and 2, as described in the TMI-l Restart Report, pages 7-1 through 7-6, and Supplement 1, Part 2, questions 52 and 54, is inadequate to resolve the concerns identified in ECNP Contention No. 19? If so:

a. Describe in detail the inadequacies of the physical separation proposed by Met-Ed.

b. For each inadequacy listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

c. For each inadequacy listed, identify all docu-ments, and the particular parts thereof, containing any evidence or information relating to or bearing upon the -

allegation.

d. For each inadequacy listed, identify all persons having any information or knowledge supporting or relating to the allegation.

19-13 Does ECNP contend that the safety evaluation performed by the NRC Staff with respect to the physical separation of Units 1 and 2, as described in the January 11, 1825 550

1980 Status Report on the Evaluation of Licensee's Compliance with the NRC Order dated August 9, 1979 (" Status Report"),

pages C4-1 through C4-16, is inadequate to resolve the concerns identified in ECNP Contention No. 19? If so:

a. Describe in detail the inadequacies of the physical separation safety evaluation performed by the NRC Staff.

b. For each inadequacy listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

c. For each inadequacy listed, identify all docu-ments, and the particular parts thereof, containing any evidence or information relating to or Daaring upon the allegation.

d. For each inadequacy listed, identify all persons having any information or knowledge supporting or relating to the allegation.

19-14 Does ECNP contend that the storage capacities end -

capabilities of Units 1 and 2, as described in the TMI-l Restart Report, pages 7-6 through 7-llc, and Supplement 1, Part 2, questions 53 and 54, are inadequate to resolve the concerns identified in ECNP Contention No. 19? If so:

a. Describe in detail the inadequacies of the storage capacities and capabilities proposed by Met-Ed.

'l82S 551

b. For each inadequacy listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.

c. For each inadequacy listed, identify all docu-ments, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.

d. For each inadequacy listed, identify all persons having any information or knowledge supporting or relating to the allegation.

19-15 Does ECNP contend that the safety evaluation performed by the NRC Staff with respect to Unit 1 and 2 storage capacities, as described in the Status Report, pages C5-1 through C5-14, is inadequate to resolve the concerns identified in ECNP Contention No. 19? If so:

a. Describe in detail the inadequacies of the storage capacity safety evaluation performed by the NRC Staff.

b. For each inadequacy listed, set forth each and every fact and the source of each and every fact relating to or -

bearing upon the allegation.

c. For each inadequacy listed, identify all documents, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.

1825 552

d. For each inadequacy listed, identify all persons having any information or knowledge supporting or relating to the allegation.

Interrogatory 23 23-1 With respect to each individual whom ECNP intends to call as a witness in this proceeding:

a. Identify by name, address and affiliation each such individual;

b. State the educational and professional back-ground of each such individual, including occupation and institutional affiliations, publications and papers;

c. Identify the contention as to which each such individual will testify;

d. Describe the nature of the testimony which will be presented by each such individual, including an identifica-tion of all documents which the individual will rely upon in the testimony. ~

e. Identify by court, agency or other body, proceeding, date and subject matter of all prior testimony by each such individual.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: ,bj i k) /-f ggeorp4 F. Trowbrid'ge /

Counsel for Licensee 1800 M Street, N.W.

Washington, D.C. 20036 (202) 331-4100 e

1825 354 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Interrogatories To Intervenor Environmental Coalition on Nuclear Power", dated January 18, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 18th day of January, 1980.

b '

_ /$4%V /

• _ ' N/ Gpdrge F.'Trowbridg6 Dated: January 18, 1980 182f5 355 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Board Panel Commission U.S. Nuclear Regulatory P. O. Box 3265 Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing Commonwealth of Pennsylvania Board Panel 505 Executive House 881 West Outer Drive P. O. Box 2357 Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17120 Dr. Linda W. Little Robert L. Knupp, Esquire Atomic Safety and Licensing Assistant Solicitor -

Board Panel County of Dauphin P. O. Box P 5000 Hermitage Drive ,

Raleigh, North Carolina 27612 407 Iorth Front Street Harr(isburg, Pennsylvania 17108 James R. Tourtellote, Escuire (4) . .

Off ce of the Executive Legal h r n D uphin County Board U.S. Nuclear Reaulatorv of Commissioners Commission Dauphin County Courthouse Washington, D.C. 20555 ng and Market Streets Harrisburg, Pennsylvania 17101 Docketing and Service Section (21)

Office of the Secretary Walter W. Cohen, Esquire U.S. Nuclear Regulatory Consumer Advocate Commission Department of Justice Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 1825'356

Jordan D. Cunningham, Esquire Karen Sheldon, Esquire Attorney for Newberry Township Sheldon, Harmon & Weiss T.M.I. Steering Committee Suite 506 2320 North Second Street 1725 Eye Street, N.W.

Harrisburg, Pennsylvania 17110 Washington, D.C. 20006 Theodore A. Adler, Esquire Robert Q. Pollard Widoff Reager Selkowitz & Adler Chesapeake Energy Alliance P. O. Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn Weiss, Esquire Chauncey Kepford Sheldon, Harmon & Weiss Judith H. Johnsrud Suite 506 Environmental Coalition on 1725 Eye Street, N.W. Nuclear Power Washington, D.C. 20006 433 Orlando Avenue State College, Pennsylvania 16801 Steven C. Sholly 304 South Market Street Marvin I. Lewis Mechanicsburg, Pennsylvania 17055 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 Holly S. Keck Legislation Chairman Marjorie M. Aamodt Anti-Nuclear Group Representing R. D. 5 York Coatesville, Pennsylvania 19320 245 West Philadelphia Street York, Pennsylvania 17404 i825 557