ML19263F422

First Set of Interrogatories Directed to Intervenor Sc Sholly.Questions Alleged Inadequacy of Offsite Radiation Teams,Described in Health Physics Procedure 1670.6,to Properly Monitor Offsite Radiation Releases

ML19263F422
Person / Time
Site:	Three Mile Island
Issue date:	01/18/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S AFFILIATION NOT ASSIGNED
Shared Package
ML19263F423	List: ML19263F422 ML19263F424
References
NUDOCS 8001280217
Download: ML19263F422 (14)

Text

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January 18, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION n? g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) ] g gg 9 METROPOLITAN EDISON COMPANY ) Docket No. 50-289 3, g

) (Restart) c>

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR STEVEN C. SHOLLY These interrogatories are filed pursuant to 10 C.F.R.

S 2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation.

Licensee recognizes that you may not now be able to completely answer all interrogatories propounded below, since some areas are the subject of discovery by you to Licensee. Licensee there-fore requests that each of these interrogatories be answered within the time specified in S 2.740b to the extent that re-sponsive information is presently available to you. With re-spect to those interrogatories for which complete and responsive information is not now available to you, Licensee requests that revised answers be provided prior to the close of the discovery priod established in the Licensing Board's December 18, 1979 First Special Prehearing Conference Order.

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

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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 who prepared the document, and name of person for whom the docu-ment was prepared or to whom it was delivered.

Interrogatories on Contention No. 1 1-1. Refer to section 2.1.1.5 (Containment Isolation Modifications) of the TMI-l Restart Report. Do the modifications described in that section satisfactorily respond to this conten-tion? If not, explain fully any. dissatisfaction with the modifi-cations. ,

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Interrogatories on Contention No. 4 4-1. Identify all bases for the claim that Licensee's ability to provide offsite radiation exposure and dose data is significantly impaired due to the lack of onsite TLD processing facilities, other than the referenced pages of NUREG-0600.

4-2. Explain why the use of offsite radiation monitor-ing teams, as described in Health Physics Procedure 1670.6 (copy attached), is not adequate to properly monitor offsite releases of radiation.

4-3. Explain the basis for the claim that protection of public health and safety under accident conditions requires that Licensee have onsite TLD processing capability.

4-4. Identify that part of Health Physics Procedure 1670.6 which rou contend " limits the Licensee's environmental TLD data to five offsite stations beyond five miles from the site."

4-5. Do you contend that the number and placement of TLD's in Licensee's revised Radiological Environmental Monitor-ing Program ("REMP"), as described in the TMI-l Restart Report, pages 7-13 through 7-14, is inadequate? If so:

(a) Describe in detail the inadequacies of the TLD 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, and the particular parts thereof, contain-ing any evidence or information relating to or bear-1817 325

ing 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. 5 -

5-1. Specify the number, location and indicating range which you contend should be provided for radiation monitoring instruments in the " containment, spaces which could contain LOCA fluids, effluent discharge paths, and the plant environs."

5-2 Do you contend that the ranges specified in answer to Interrogatory 5-1 should be designed to measure in-plant accident conditions more severe than conditions asso-ciated with the design basis accidents for TMI-l? If so, de-scribe each accident scenario for which you contend that the ranges should be designed.

Interrogatories on Contention No. 10 10-1. Identify those possible accidents at Unit 1 which you contend will affect activities at Unit 2 so as to pose a significant risk to public health and safety. With re-spect to each such accident so identified:

(a) Describe with particularity the risk posed by that accident to activities at Unit 2.

(b) Describe the steps to be taken which you contend are necessary to protect against the speci-fied risks.

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10-2. Do you contend that Unit 1 waste handling and stcrage capacity will be used to assist in the Unit 2 decon-tamination and clean-up activities? If your response is other than an unqualified "no", explain the basis for the response and specify the portion of the Unit 1 waste handling and storage capacity which you contend may be used to assist in Unit 2 activities.

10-3. Identify those possible accidents at Unit 1 which you contend may possibly result in an uncontrolled release of liquid wastes if Unit 1 waste handling and storage capacity is being used to assist in Unit 2 activities. With respect to each such accident so identified:

(a) Estimate the quantity of radioactive waste-water requiring storage which you contend will be generated.

(b) Describe the mechanism by which you contend the accident will generate the quantity of radioac-tive wastewater estimated above.

(c) Explain why the wastewater could not be stored temporarily in the Unit 1 containment.

10-4. Do you 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 comply with GDC 5 or to otherwise resolve the concerns identified in your Contention No. 107 If so:

(a) Describe in detail the inadequacies of the physical separation proposed by Met-Ed. 1b17 )2[

(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.

10-5. Do you 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, is inadequate to establish compliance with GDC 5 or to otherwise resolve the concerns identified in your Contention No. 10? 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.

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(d) For each inadequacy listed, identify all persons having any information or knowledge support-ing or relating to the allegation.

10-6. Do you contend that the storage capacities and capabilities of Units 1 and 2, as described in the TMI-l Restart Report, pages 7-6 through 7-11c, and Supplement 1, Part 2, questions 53 and 54, are inadequate to resolve the concerns identified in your Contention No. 10? If so:

(a) Describe in detail the inadequacies of the storage capacities and capabilities 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.

10 7. Do you 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 your Contention No. 10? If so:

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(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.

(d) For each inadequacy listed, identify all persons having any information or knowledge support-ing or relating to the allegation.

Interrogatories on Contention No. 14 14-1. Identify by date of each alleged violation and citation to applicable regulation (s) and/or technical specifi-cation (s) all violations of NRC regulations and technical specifications which you contend have occurred, other than those specifically included in items a through k which are listed as a

" Basis for Contention #14."

(a) For each alleged violation listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allega-tion, including a brief description of each alleged violation and an identification of the unit at which the violation allegedly occurred.

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(b) For each alleged violation 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 alleged violation listed, identify all persons having any information or knowledge support-ing or relating to the allegation.

14-2. Identify all " safety-related functions" which you contend that Licensee did not " timely" execute during the Unit 2 accident.

(a) Define " safety-related functions" as that term is used in the allegation.

(b) For each " safety-related function" listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allega-tion, including a description of the function, and the date of the alleged untimely execution.

(c) For each " safety-related function" listed, specify the day and time at which you contend that function should have been executed to have been " timely" executed.

(d) For each " safety-related function" listed, identify all documents, and the particular parts thereof, containing any evidence or information re-lating to or bearing upon the allegation.

(e) For each " safety-related function" listed, identify all persons having cny information or know-ledgesupportingorrelatingtotheallegation! l'O } .

14-3, Describe all Licensee actions (other than those specific items referenced in a through k which are listed as a

" Basis for Contention #14"), especially with respect to plant operating procedures, which you allege collectively demonstrate a lack of managerial and administrative control, although they do not constitute violations of NRC regulations.

(a) For each action listed, set forth each and every fact and the source of each and every fact re-lating to or bearing upon the allegation, including the date of the alleged action, the name(s) of the specific person (s) who took the alleged action (if known), and an identification of the unit to which the alleged action relates.

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

(c) For each action listed, identify all per-sons having any .tformation or knowledge supporting or relating to the allegation.

14-4. Describe all Licensee staff actions (other than the specific items referenced in a through k which are listed as a " basis for Contention #14") which allegedly demon trate inadequate knowledge of operating procedures and basic radia-tion safety concepts.

(a) For each action listed, set forth each and every fact and the source of each and every fact 1817 332

relating to or bearing upon the allegation, including the date of each alleged action, the name (s) of the specific person (s) who took the alleged acticn (if known), and an identification of the unit to which the alleged action relates.

(b) For each action listed, identify the NRC regulation, technical specification or operating procedure (if any) which the action allegedly vio-lated.

(c) For each action 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 action listed, identify all per-sons having any information or knowledge supporting or relating to the allegation.

14-5. Identify all " crucial records" which you allege that Licensee or Licensee's staff lost, except those specific items referenced in a through k which are listed as a " basis for Contention #14."

(a) For each record listed, set forth each and every fact and the source of each and every fact re-lating to or bearing upon the allegation, including the approximate date of the alleged loss (if known),

the approximate date of the discovery of the alleged loss (if known), and the unit to which the allegedly ,

lost record relates.

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(b) For each record listed, identify the NRC regulation (if any) which you allege to mandate main-tenance of the record. (c) For each record 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 record listed, identify all per-sons having any information or knowledge supporting or relating to the allegation. 14-6. Identify all records which you allege that Li-censee failed to maintain, in violation of NRC regulations, ex-cept those specific items referenced in a through k which are listed as a " Basis Fer Contention #14." (a) For each record listed, set forth each and every fact and the source of each and every fact re-lating to or bearing upon the allegation, including a brief description of the record and entry or entries on that record which you allege were not made (in violation of NRC regulations), the date of each such alleged omission, and an identification of the unit to which the alleged omission relates. (b) For each record listed, identify the NRC regulation which you allege to mandate maintenance of the record. (c) For each record listed, identify all docu-ments, and the particular parts thereof, containing any evidence or information relating to or bearin$ 1 i 73 3 4

upon the allegation. (d) For each record listed, identify all per-sons having any information or knowledge supporting or relating to the allegation. Interrogatories on Contention No. 15 15-1. Specify and explain each inadequacy which you contend exists in the current operator-instrumentation interface. 15-2. Describe each alteration to the control room and control panel design that you propose be implemented at TMI-1. Interrogatory No. 18 18-1. With respect to each individual whom you intend to call as a witness in this proceeding: (a) Identify by name, address and affiliation each such individual; (b) State the educational and professional background of each such individual, including occupa-tion 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 identification of all documents uhich the indi-vidual will rely upon in the testimony; 1B17.535

(e) Identify by court, agency or other body, proceeding, date and subject matter all 1.rior testi-many by each such individual. Respectfully submitted, SHAM, PITTMAN, POTTS & TROWBRIDGE By: / /'ksj blu l /J

                                      ' s/ Ge,orge'F. Trowbridge' 1800 M Street, N.W.

Washington, D.C. 20036 Tel: (202) 331-4100 Counsel for Licensee Dated January 18, 1980 1817 $36}}