ML19269D415

Outline of Intended cross-examination by Util,Contingent Upon Denial of Util 790423 Objections to Intervenor'S Profferred Testimony.Certificate of Svc Encl

ML19269D415
Person / Time
Site:	Salem
Issue date:	04/25/1979
From:	Wetterhahn M CONNER, MOORE & CORBER
To:
References
NUDOCS 7906020252
Download: ML19269D415 (10)

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• d' NUCLEAR REGULATORY COMMISSION b, os tav \ y In the Matter of )

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PUBLIC SERVICE ELECTRIC & GAS ) Docket No. 50-272 COMPANY, et al. ) (Proposed Issuance

) of Amendment to (Salem Nuclear Generating ) Facility Operating Station, Unit 1) ) License No. DPR-70)

LICENSEE'S OUTLINE OF CROSS-EXAMINATION If and to the extent that " Licensee's Obj ections to Intervenor's Profferred Testimony" dated April 23, 1979, is not granted, the following represents Licensee's outline of intended cross-examination:

I. Testimony of George Luchak, Ph.D.

1. Qualifications of the Witness to testify with regard to:

a. The design of commercial nuclear power plants

b. The design of the Salem Generating Station, Unit 1

c. The design of fuel pools and racks, particularly the fuel pool and racks for Salem Generating Station Unit 1

d. The siting, design, and construction of an ISFSI

e. Costs associated with the siting, design, construction and operation of an ISFSI 2259 006 79060209 Q

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f. Costs associated with operation of a nuclear power plant and spent fuel pool at that plant, particularly the Salem Generating Station, Unit 1

g. Safe and permanent disposal of spent fuel, including technology and costs

h. Accident evaluation at nuclear power plants and spent fuel pools, particularly Salem Generating Station, Unit 1

2. Bias and prejudice of the Witness

3. Basis for Testimony Regarding Availability of an ISFSI as an alternative.

a. Status, design, construction or operation of all 79FSI's

b. Capacity of proposed ISFSI's

c. Lead time associated with siting, design and construction of an ISFSI

d. Costs associated with siting, design, and construction of various ISFSI's and basis for calculation of such costs

e. Changes in ISFSI costs v. time

f. Operating costs of an ISFSI

. g. Operating costs associated with the Salem spent fuel pool

h. Differential operating costs at the Salem Generating Station, Unit 1 resulting from changing the racks

i. Factors regarding need for an ISFSI, including national policy considerations 2259 007

4. Basis for statements regarding Regulatory Guide 3.24 and ISFSI regarding:

a. Siting requirements for an ISFSI

b. Comparison to the requirements of proposed Regulatory Guide 3.44 and proposed 10 C.F.R. Part 72

c. An ISFSI as a permanent storage facility

d. Purported U.S. policy regarding directed away-from-reactor storage

e. Changes in U.S. position after President Carter's

- position on reprocessing

f. Subsequent bias of NRC towards at-reactor storage

5. Basis for knowledge of Browns Ferry incident, including:

a. Nature of sources utilized

b. Type of and time spent on research

c. Detailed chronology of events at Browns Ferry

d. Offsite consequences

e. Knowledge of investigators performed

f. Differences in type of reactor between Browns Ferry and Salem Generating Station Unit 1

g. Relationship of Browns Ferry accident to the design changes of the spent fuel pool

6. Basis for knowledge of the Three Mile Island Incident, including

a. Nature of sources of information

b. Type of and time spent on research

c. Detailed chronology of events

d. Offsite consequences

e. Effect on the spent fuel pool at Three Mile Island Unit 2 2259 008

f. Differences in design between Three Mile Island Unit 2 and Salem Unit 1

7. Basis for predicting impact of Three Mile Island Unit 2 type event on Salem Fuel Pool, including

a. Knowledge of predicted radiation levels and conenmination at various locations at Salem Unit 1 as result of Three Mile Island Unit 2 type event

b. Knowledge of details of design and location of equipment at Salem as related to the spent fuel pool c .. Knowledge of redundant and backup fuel pool systems at Salem Unit 1

8. Basis for predicted risk of accident at Artificial Island, including

a. Methodology and assumptions utilized

b. Data utilized

c. Accuracy of results and uncertainty

9. Basis of prediction of type of spent fuel pool accident, including

a. Assumptions utilized

b. Failure mode analysis utilized

c. Type of contamination assumed or calculated

d. Type and extent of instrument failures assumed or predicted

e. Assumptions or predictions as to age of fuel in spent fuel pool by region 2259 009

f. Assumptions or prediction as to radioactive decay of spent fuel

g. Assumptions or predictions as to. heat rejected by spent fuel pool

h. Type and extent of hydrogen explosion predicted and mechanisms involved

i. Type and extent of " scattering" of nuclear debris assumed or predicted

j. Type and extent of maintenance required post accident k.' Mechanism for water boiling off due to a break in the cooling system

1. Assumptions regarding radioactive transport modes and predicted effects

10. Basis for statements regarding asserted criteria for determining location for storage of spent fuel:

a. Assumptions regarding dispersion of radioactive material

b. Sitine criteria for ISFSI

c. Basis for and completeness of asserted necessarr infor.Tation needed to site an ISFSI

11. Basis for'ulH mate conclusions regarding availability of an ISFSI as an alternative IJ. Crockett Letter

1. Basis for Crockett letter, including

a. Identification of DOE letter and determinatior.

of basis, purpose and extent of inquiry from LOE 2259 010

b. Conditions or programs existing at time which caused inquiry from DOE

c. Changes since Crockett letter which may have changed responses if requested today or changed PSE&G position

d. Status of DOE programs

2. Basis for response to Question 1, including

a. Assumptions and methodology used to determhe number of spent fuel assemblies discharged by calender year

b. Nature of changes which could affect the dis-charge rate

3. Basis for response to Question 2, including

a. Assumption and. methodology used to predict cumulative total of spent fuel cooled for five years

4. Basis for response to Question 3, including

a. Basis for PSE&G position with regard to shorter period of time for shipment of spent fuel

b. Assumptions and type of economic evaluations used to determine when transfer to the government should take place

c. Advantages and incentives for a utility to wait for a geologic repository to be in service ...

d. Basis for statements regarding spent fuel pool capacity for Hope Creek

e. Basis for saturation of the spent fuel facility with and without full core dump 2259 011

5. Basis for response to Question 4, including

a. Basis for PSE&G position with regard to DOE design criteria of five year fuel cooling

b. Basis of position on advance notice for transfer of spent fuel

c. PSE&G position on situations which might neces-sitate shorter notice and earlier transfer

6. Basis for response to Question 5, including

a. PSE&G position on reprocessing as preferable to disposal

b. PSE&G position on schedule for geologic repository

c. PSE&G position with regard to advance notice of transfer of spent fuel, including contract conditions

d. PSE&G position on fee structure for away-from-reactor storage including transportation and separate fee for geologic disposal

e. PSE&G position on technical design bases for repository

7. Basis for response to Question 6, including

a. PSE&G position with regard to determination of fee for interim offsite storage and geological repository storage

8. Bases for response to Question 7, including

a. PSE&G position with regard to change in title associated with disposal of fuel and subsequent liability 59 012

b. PSE&G position regarding disposal fee reflecting the right of a utility to recover its spent fuel Respectfully submitted, CONNER, MOORE & CORBER Mark J. Wetterhahn Counsel for the Licensee April 25, 1979 2259 013 O

UNITED STATES 05' AMERICA NUCLEAR REGULATORY COMMISSION Before the' Atomic Safety and Licensing Board In the Matter of )

)

PUBLIC SERVICE ELECTRIC AND GAS ) Docket No. 50-272 COMPANY, et al. ) (Proposed Issuance of

- ) Amendment to Facility (Salem Nuclear Generating . ) Operating License Station, Unit 1) ) No. DPR-70)

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's outline of Cross-rvamdnation," dated April 25, 1979, in the captioned matter, have been served upon the following by deposit in the United States m il this 25th day of April, 1979:

Gary L. Milhnllin, Esch. chai man, Atomic Safety and ch=4 man _, Atomic Safety Licensing Board Panel and Licensing Board U.S. Nuclear Regulatory 1815 Jefferson Street Ccmmission

. . . . , _ Madison, Wisconsin 53711 Washington, D.C. 20555 - .

Mr Lester Kornblith, Jr. Barry Smith, Esq.

Ma har, Atomic Safety and Office of the Executive Licensing Board Panel. Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Ccamission Washington, D.C. 20555 Washington, D.C. 20555 Dr. James C. Lamb, III Richard Hluchan, Esq.

Member, Atomic Safety and Deputy Attorney General Licensing Board Panel Department of Law and 313 Woodhaven Road Public Safety Chapel Hill, N.C. 27514 Envireamental Protection Section Chair: nan, At:omic Safety and 36 West State Street Licensing Appeal Board Panel Trenton, N.J. 08625 U.S. Nuclear Regulatory

'o.umission Washington, D.C. 20555 2259 014

Richard Fryling, Jr., Esq. Carl Valore, Jr., Esq.

Assistant General Solicitor. Valore, McAllister, Aron Public Service Electric & Westmoreland

& Gas Company Mainland Professional Plaza 80 Park Place P. O. Box 175

. Newark, N. J. 07101 Northfield, N. J. 08225 Keith Onsdorff, Esq. Office of the Secretary Assistant Deputy Public Advocate Docketing and Service Section Department of the Public Advocate U.S. Nuclear Regulatory Division of Public Interest Commission Advocacy. Washington, D. C. 20555 Post Office Box 141 Trenton, N. J. 08601 June D. MacArtor, Esq. -

Deputy Attorney General Sandra T. Ayres, Esq. Tatnall Building, P. O. Box 1401 Department of the Public Advocate Dover, Delaware 19901 520 East State Street Trenton, N. J. 08625 Mr. Alfred C. Coleman, Jr.

Mrs. Eleanor G. Coleman 35 "K" Drive Pennsville, New Jersey 08070 1

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Marx J. @ tterbahn 2259 015