ML19269D338
| ML19269D338 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 04/27/1979 |
| From: | Sekuler S ILLINOIS, STATE OF |
| To: | |
| References | |
| NUDOCS 7906010266 | |
| Download: ML19269D338 (6) | |
Text
NRC PUBLIC DOCUEA ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1
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In the Matter of
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Docket Nos. 50-295 d'F fj$[
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50-304
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m STATE OF ILLINOIS ANSWERS TO NRC STAFF INTERROGATORIES On April 9, 1979 the NRC propounded certain inter _ogatories to the State of Illinois. In accord with 10 C.F.R.
SS2.740 (b) and 2.710 the answers to these interrogatories are required to be filed by April 27, 1979. The following partial answers are therefore being filed at this time. Additional information will be filed as it becomes available.
INTERROGATORY 1.
With respect to contentions 2(a), 2(b), 2 (c) and 2(d) set out in the Order of January 19, 1979.
(a) State the name, business and residence address of each person expected to be called as an expert witness at the evidentiary hearing; (b) With respect to each person named in response to interrogatory 1(a), state the subject matter on which that persons is expected to testify; and (c) With respect to each person named in response to interrogatory 1(a), state; (1) which contention (s) 2265 120 7906010
. will be addressed, (2) the substance of that person's testimony, and (3) what you expect the testimony to prove.
ANSWER 1(a):
Peter Cleary Citizens for a Better Environment 59 East Van Buren Chicago, Illinois (residence address inapplicable and unknown)
Gregory C.
Minor MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, California 95125 (residence address inapplicable and unknown)
Additional witnesses, if any, have yet to be identified.
1(b) (c) :
A.
Mr. Cleary will testify on Contention 2(a) and 2 (b).
Cleary will testify to the adequacy of the Environmental Impact Appraisal, including consideration of cost-benefit analyses; impact of the spent fuel modification on resource commitment and the utility of this licensing proceeding vis a vis other Commonwealth Edison licensing actions designed to ameliorate the alleged shortage of spent fuel storage capacity; cumulative environmental impacts of this licensing action and potential harm to the public interest.
Cleary's testimony will challenge the approach of the NRC Staff in its Environmental Impact Appraisal and will demonstrate that the the Appraisal was limited in scope and did not adequately cover all 2265 121
. reasonably postulated effects of this modification on the community.
In particular Cleary will show that there was no consideration of the impact of a credible accident and the incremental damage caused thereby by the additional amounts of stored fuel.
B.
Mr. Minor will testify on Contention 2 (b). He will address the question of NRC policy as it relates to the ability of this Board to resolve all technical problems associated with the proposed modification. His testimony will show that existing generic problems of a technical nature will not be dealt with by this Board and the existence of such problems mediate against granting of a license at this time.
C. Additional witnesses, currently unidentifie4 will testify to Contentions 2(a), 2(b) and 2(c).
Testimony will go to show that a possible shut down of the Zion plant would not be detrimental to the public interest.
INTERROGATORY 2.
Specifically, as to contention 2(a), state:
(a) what environmental effects do you expect to occur as a result of the proposed modification other than those which have been set forth and analyzed in the NRC Staff's Environmental Impact Appraisal, dated March 29, 1979, (b) the time period over which you expect such effects to occur, and 2265
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. (c) the relationship between such impacts resulting from the modification and the impacts which would otherwise occur if the Zion station continued to operate in its present as-built configuration until the spent fuel pool is filled.
ANSWER The specific witness who will address the types of issues referred to above and in Interrogatory Number 2 has not yet been identified. Therefore the information requested in the interrogatory is not available at this time. This answer will be supplemented as soon as the information becomes available. For the interim Intervenor can partially answer interrogatory 2 as follows:
A.
The NRC Staff's Environmental Impact Appraisal dated March 29, 1979 in the section entitled " Impacts on the Community" addresses only the shipping of the new racks. The effect of the increased storage of fuel and the actual installation of the racks as it impacts on the utilization of existing community services is not discussed. For instance, there is no mention of the need for additional community services to deal with the effects of incremental radiation exposure to workers in the plant.
B.
The " Environmental Impact of Postulated Accidents" is asserted to be the same as that reported in the 1972 FES. The environmental effects of accidents postulated in 1972 have not been recalculated to factor in the increased radiation that will necessarily result from an accident in"olving additional numbers of fuel elements.
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5-The EIA does not reevaluate the possibility of accidental occurrences in light of recent developments: e.g.
Three Mile Island.
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SUSAN N.
SEKULER Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 I,
SUSAN N.
SEKULER, being an attorney of record in this cause attest that the answers to the Interrogatories herein are true and correct in all material respects to the best of my knowledge and belief.
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SUSAN N.
SEKULER Assistant Attorney General Environmental Control Division 188 West Randolph, Suite 2315 Chicago, Illinois 60601 (312) 793-2491 DATED: April 27, 1979 2265 124
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-295
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50-304 (Zion Station, Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing State of Illinois ANSWERS TO NRC STAFF INTERROGATORIES in the above captioned matter have been served upon the following by deposit, first vlass mail, in the United States Mail, this 27th day of April, 1979.
Edward Luton, Chairman Atomic Safety & Licensing Board Atomic Safety & Licensing Board Panel Panel U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commissi Washington, D.C.
20555 Washington, D.C.
20555 Dr. Linda W.
Little Atomic Safety & Licensing Research Triangle Institute Appeal Board Panel P.O.
Box 12194 U.S. Nuclear Regulatory Commissi Research Triangle Park, N.
Carolina 27709 Washington, D.C.
20555 Dr. Forrest J. Remick Docketing & Service Section 305 E.
Hamilton Avenue U.S. Nuclear Regulatory Commissi State College, Pennsylvania 16801 Washington, D.C.
20555 Michael Miller, Esq.
Richard Goodard, Esq.
Philip Steptoe, Esq.
Myron Karman, Esq.
Isham, Lincoln & Beale Guy Cunningham, Esq.
One First National Plaza Office of the Executive Legal Chicago, Illinois 60690 Director U.S.
Nuclear Regulatory Commissi Washington, D.C.
20555 SUSAN N.
SEKULER 2265 125