ML19263F405
| ML19263F405 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/18/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Chesapeake Energy Alliance |
| References | |
| NUDOCS 8001280114 | |
| Download: ML19263F405 (13) | |
Text
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January 18, 1980 e
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 m
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR CHESAPEAKE ENERGY ALLIANCE, INC.
These interrogatories are filed pursuant to 10 C.F.R.
S 2.740b, which requires that the interrogatories be answered s,e arately and fully in writing and under oath or affirmation.
Licensee recognizes that Intervenor Chesapeake Energy Alliance, Inc. ("CEA") may not now be able to completely answer all inter-rogatories propounded below.
Licensee therefore requests that each of these interrogatories be answered within the time speci-fied in S 2.740b to the extent that responsive information is presently available to CEA.
With respect to those interroga-tories for which complete and responsive information is not now available to CEA, 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 Pre-hearing Conference Order.
Any reference to CEA shall be deemed to include all members of CEA.
When knowledge or information of CEA is re-quested, such request includes knowledge or information of 1817.147 8001280\\\\ d.
. CEA's members.
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, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, logs, 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 position; (2)
With respect to a document, the type of document (e.g.,
letter, record, list, memorandum, memorandum of telephone or face-to-face conversation, etc.), date of the document, title of the document, subject of the document, name of person -#"
prepared the document, and name of person for whom the docu-ment was prepared or to whom it was delivered.
Interrogatories on Contention No. 5 5-1. Describe with particularity the "possible inter-ference from [ Unit 2] vantaminated water with storage space that might be required in the event of a TMI-1 accident."
(a)
Identify the potential Unit 1 accidents assumed in the contention, remembering that the 1817 148
. Licensing Board already has ruled that the scenario postulated in CEA Contention No. 2 (a) is to be ex-cluded.
(b)
Estimate the quantity of radioactive waste-water requiring storage at Unit 1 which CEA contends will be generated by each of the accident scenarios identified above.
(c)
Describe the mechanism by which CEA contends that each of the identified accidents will generate the quantity of radioactive wastewater requiring storage as estimated above.
5-2. Describe the potential accidents during decontami-nation and clean-up at Unit 2 which CEA contends might impact on the operation of Unit 1.
5-3. Identify each risk to the safe operation of Unit 1 which CEA contends is associated with the Unit 2 accidents de-scribed in the response to Interrogatory 5-2.
For each risk so identified:
(a)
Set forth each and every fact and the source of each and every fact upon which CEA bases its con-clusion.
(b)
Identify all documents, and the particular parts thereof, containing any evidence or information bearing upon or relating to CEA's conclusion.
(c)
Identify all persons having any informa-tion or knowledge suppcrting or relating to CEA's conclusion.
1817 149'
4-5-4.
Identify any evidence based on actual operation of EPICOR-II of which CEA is aware indicating that the effective-ness, reliability and/or safety of EPICOR-II is not as antici-pated prior to actual operation.
5-5. Describe the basis for,CEA's claim that a delay in the ultimate disposal of processed TMI-2 wastewater may inter-fere with emergency storage facilities that may be needed in the event of an accident at Unit 1.
Interrogatories on Contention No. 6 6-1. Explain the basis for CEA's claim that "TMI-2 con-tinues to ' leak' contaminated water."
(a)
Define what CEA means by the word " leak".
(b)
Identify the source of each alleged " leak".
(c)
Identify where the contaminated water is allegedly " leaking" to.
(d)
Quantify (if known) in gallons per minute the rate of each " leak".
6-2. Explain with particularity the risk to safe opera-tion of Unit 1 from the " leaks" identified in the response to Interrogatory 6-1.
6-3. Explain the basis for CEA's claim that "as long as TMI-2 continues to generate surplus radioactive water that TMI-2 continues to pose the threat of returning to an active emergency status."
(a)
Define what CEA means by the phrase " return-ing to an active emergency status."
1817L150
. (b)
Explain with particularity the risk to safe operation of Unit 1 posed by such " emergency status."
(c)
Is this risk the same as the "potentially severe conflict with operation of TMI-1" referred to in the last sentence of Contention No. 6?
Explain what CEA means by " severe conflict with cperation of TMI-1."
Interrogatories on Contention No. 7 7-1. Does CEA contend that the physical separation of 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 CEA Conten-tion No. 7?
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 documents, and the particular parts thereof, contain-ing any evidence or information relating to or bear-ing upon the allegation.
(d)
For each inadequacy listed, identify all persons having any information or knowledge support-ing or relating to the allegation.
1817 151
. 7-2. Does CEA 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, 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, with particular reference to the sec-tion on " Process and Effluent Radiological Monitoring System (p. C4-10), is inadequate to resolve the concerns identified in CEA Contention No. 7?
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 documents, and 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 support-ing or relating to the allegation.
Interrogatories on Contention No. 8 8-1.
Identify all alleged " evidence of the inadequacy of licensee's management capability", other than the specific items referenced in a through k which are set forth as a " Basis for Contention #14" by Intervenor Steven C.
Sholly.
1817 152
. (a)
For each piece of evidence listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation (including, for example -- where the piece of evidence is a particular Licensee action -- the date of the alleged action, a description of the alleged action, and the name (s) cf the specific person (s) who took the alleged action (if known), etc.].
(b)
For each piece of evidence listed, identify all documents, and the particular parts thereof, con-taining any evidence or information relating to or bearing upon the allegation.
(c)
For each piece of evidence listed, identify all persons having any information or knowledge sup-porting or relating to the allegation.
Interrogatories on Contention No. 12 12-1. Does CEA intend to adopt UCS' Contention No.
13?
If so, answer interrogatories 12-2 through 12-5 below.
12-2. Describe the accidents which CEA contends are credible and not bounded by the TMI-l design basis accidents.
12-3. Explain as to each accident identified in answer to interrogatory 12-2 the nexv:s between such accident and the TMI-2 accident.
12-4. Explain what CEA 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 12-2 whether the term " bounded" refers 1817 153 to accident events or accident consequences or both.
12-5. Describe the criteria proposed by CEA to be used for selecting credible accidents to be considered.
Interrogatories on Contention No. 13 13-1. Describe the "mindset" to which CEA refers in Contention No. 13, referring to the sections of NUREG-0600 upon which CEA relies, describing in particular detail any "mindset" to which CEA re'.ers which differs from that addressed in NUREG-0600.
13-2. Does CEA contend that the operator training program, as described in the TMI-l Restart Report, pages 6-1 through 6-17, is inadequate to resolve the concerns identified in CEA Contention No. 13?
If so:
(a)
Describe in detail the inadequacies of the operator training program 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 documents containing any evidence or information relat-ing 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.
13-3. Does CEA contend that the safety evaluation per-formed by the NRC Staff with respect to the operator training program, as described in the January 11, 1980 Status Report on 1817 154 the Evaluation of Licensee's Compliance With the NRC Order dated August 9, 1979
(" Status Report"), pages C6-4 through C6-5, is inadequate to resolve the concerns identified in CEA Contention No. 13?
If so:
(a)
Describe in detail the inadequacies of the operator training program 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, contain-ing any evidence or information relating to or bearing
~
upon the allegation.
(d)
For each inadequacy listed, identify all persons having any information or knowledge support-ing or relating to the allegation.
Interrogatory No. 14 14-1. With respect to each individual whom CEA intends to call as a witness in this proceeding:
(a)
Identits by name, address and affiliation each such individua'-
(b)
State tia educ;Lional and professional background of each such individual, including occupa-tion and institutional affiliations, publications and papers; 1817 155
. (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 identification of all documents which the indi-vidual will rely upon in the testimony; (e)
Identify by court, agency or other body, Proceeding, date and subject matter all prior testi-mony by each such individual.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By:
Mj jpgVy p.t G6cr@e F. Trowbridge(
1800 M Street, N.W.
Washington, D.C.
20036 Tel:
(202) 331-4100 Counsel for Licensee Dated:
January 18, 1980 1817 156
January 18, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
MZTROPOLITAN 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 Chesapeake Energy Alliance, Inc." 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.
5 c-Rbbert E. J hler Dated: January 18, 1980 1817 157
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)
)
SERVICE LIST Ivan W. Smith, Esquire John A. Ievin, Esquire Chairnun Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Cam'n Board Panel Post Office Box 3265 U.S. Nuclear Pegulatory Camission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 881 West Outer Drive Harrisburg, Pernsylvania 17120 Oak Ridge, '1bnnessee 37830 Robert L. Knupp, Esquire Dr. Linda W. Little Assistant Solicitor Atomic Safety and Licensing County of Dauphin Board Panel Post Office Box P 5000 Hermitage Drive 407 North Front Street Raleigh, North Carolina 27612 Harrisburg, Pernsylvania 17108 James R. 'Iburtellotte, Esquire John E. Miraich Office of the Executive Iagal Director Chairrran, Dauphin County Board U. S. Nuclear Pegulatory Camission of Ccrmissioners Washington, D.C.
20555 Dauphin County Courthouse Front and Market Streets Docketing and Service Section Harrisburg, Pernsylvania 17101 Office of the Secretary U. S. Nuclear Pegulatory Ca mission Walter W. Cohen, Escuire Washington, D.C.
20555 Consumer Advocate Office of Consu:ter Advocate 14th Fkor, Strawberry Scuare Harrisburg, Pennsylvania-17127 1817 158
. Jordan D. Cunningham, Esquire Pelert Q. Pollard Attorney for Newberry Township Chesapeake Energy Alliance T.M.I. Steering Cccmittee 609 Montpelier Street 2320 North Second Street Baltimore, Mal,(land 21218 Harrisburg, Pennsylvania 17110 Chancey Kepford Theodore A. Adler, Esquire Judith H. Johnsrud Widoff Reager Selkowitz & Adler Enviremental Coalition on Nuclear Post Office Box 1547 Power Harrisburg, Pennsylvania 17105 433 Orlando Avenue State College, Pennsylvania 16801 Ellyn R. Weiss, Esquire Attorney for the Union of Concerned Marvin I. Iewis Scientists 6504 Bradford Terrace Sheldon, Harnen & Weiss Philadelphia, Pennsylvania 19149 1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006 Marjorie M. Aamodt R. D. 5 Steven C. Sholly Cbatesville, Pennsylvania 19320 304 South Market Street Mechanicsburg, Pennsylvania 17055 Gail Bradford Holly S. Keck Iagislation Chaiman Anti-Nuclear Group Pepresenting York 245 West Philadelphia Street York, Pennsylvania 17404 Karin P. Sheldon, Esquire Attorney for People Agairst Nuclear Energy Sheldon, Harnen & Weiss 1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006 I817 159
.