ML19270H424

Outline of Util cross-examination of R Webb & Gulbransen Testimony on Behalf of Intervenor Lower Alloways Creek Township.Matl Will Be Used to Extent 790630 Objections to Testimony Are Overruled.Certificate of Svc Encl

ML19270H424
Person / Time
Site:	Salem
Issue date:	06/30/1979
From:	Wetterhahn M CONNER, MOORE & CORBER
To:
Shared Package
ML19270H421	List: ML19270H420 ML19270H423 ML19270H424
References
NUDOCS 7907240291
Download: ML19270H424 (6)

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'f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 Objections to Lower Alloways Creek Township's Profferred Testimony," dated June 30, 1979, are not sustained, the follcwing represents Licensee's outline of intended cross-examination:

I. Testimony of Dr. Earl A. Gulbransen

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

a. The design and operation of the Salem Generating Station

b. The design, construction and operation of the fuel pool and racks for Salem Unit 1

c. The cause and effects of hypothesized reactor accidents on the spent fuel pcol

d. The TMI-Event

e. NRC ECCS Acceptance Criteria

2. Bias and Prejudice g q

3. Basis for Testimony Regarding the Three Mile Island event

a. Course of the event

b. Basis for conclusions regarding cladding effecrs

c. Basis for recommended " procedures," including hydrogen embrittlement, hydrogen in the cooling water and necessity for hydrogen gauges. 2.[h h0N

4. Knowledge of the NRC's ECCS Acceptance Criteria and

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Ccmparison with Testimony.

5. Basis for testimony regarding cladding behavior in reactors, particularly Salem Generating Station, Unit 1.

6. Basis for conclusions r.egarding the safety of the spent fuel pool and the consequences of nuclear accidents.

II. Testimony of Dr. Richard Webb

1. Qualifications of the Witness to Testify Regarding:

a. Plans to store fuel in the spent fuel i pool in the Salem Generating Station

b. Accident evaluation and probability

c. The design, construction and operation of Salem Generating Station, including the spent fuel pool

d. The " loss of water accident"

e. A permanent fuel repository at Salem

2. Bias and prejudice of the Witness

3. Basis for evaluation of a " Loss of Water Accident," including its hypothesi::ed consequences.

4. Basis for evaluation of conceivable possibilities for causing a " Loss of Water Accident"

5. Basis for evaluation regarding criticality accidents

6. Basis for evaluation regarding reactor accidents that could cause " Lass of Water Accidents," including effect on and actions by the operating crew.

1/ Counsel for LACT should a.;sure that a ccpy of the NRC's ECCS Acceptance Criteria .tre supplied to the Witness in advance of the hearing to facilitate cross-examination.

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7. Basis for evaluation of consequences of reactor accidents and " Loss of Water Accidents"

8. Basis for statements regarding probablistic risk assessment and need for future studies

9. Basis for statements regarding a permanent spent fuel repository at Salem

10. Basis for statements regarding impracticality of theoretical analysis and experiment verification III. Testimony of the NRC Staff

1. Qualifications of the Witnesses to Testify

2. Basis for statements related to the effect of the TMI accident on the TMI spent fuel pool

3. Basis for statements regarding causes of the TMI incident and the chronology of events

4. Basis for statements regarding design and operational differences between TMI and Salem Unit 1

5. Basis for statements regarding hypothesized series of events at Salem Unit 1 in partial response to Scard Question 3

6. Basis for statements regarding effect of hypothesized releases to the Auxiliary Building at Salem Unit 1 on the operation of the spent fuel pcol

7. Basis for statements regarding effect of hypothesized releases into the Auxiliary Building on systems in the Fuel Handling Building at Salem Unit 1

8. Basis for conclusions regarding the Staff's evaluation resulting from the Scard's questiens on the proposed amendment to increase the spent fuel capacity

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9. Basis for statements, evaluations and analysis contained in NUREG-0560 as they apply to the Board's questions Respectfully submitted, CONNER, MOORE & CORBER Mark J. Wetterhahn Counsel for the Licer.see June 30, 1979 2 77 087 I

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UNITED STATES OF 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 (Salen Nuclear Generating ) Operating License Station, Unit 1) ) No . DPR-7 0 )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Objections to Lower Alloways Creek Township's Proffered Testimony" and

" Licensee's Outline of Cross-Examination," dated June 30, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail this 30th day of June, 1979:

Gary L. Milhollin, Esq. Chairman, Atcmic Safety and Chairman, Atomic Safety Licensing Board Panel and Licensing Board U.S. Nuclear Regulatory 1815 Jefferson Street Commission Madison, Wisconsin 53711 Washington, D.C. 20555 Mr. Lester Kornblith, Jr. Barry Smith, Esq.

Member, Atomic Safety and Office of the Executive Licensing Board Panel Legal Director U.S. ' Nuclear Regulatory U.S. Nuclear Regulatory Ccmmission Ccmmission Washington, D.C. 20555 Washington, D.C. 20555 Dr. James C. Lamb, III Richard Eluchan, Esq.

Mamber, Atomic Safety and Deputy Attorney General Licensing Board Panel Department of Law and 313 Woodhaven Road Public Safety Chapel Hill, N.C. 27514 Environmental Protection Section Chairman, Atomic Safety and 36 West State Street Licensing Appeal Board Panel Trenten, N.J. 09625 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 237? 088

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.

Depaty 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

// Q [t-Mark J(.,Wetternahn

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