ML19320C544
| ML19320C544 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/15/1980 |
| From: | Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | BIER, MILLS, CHRISTA-MARIA, ET AL |
| Shared Package | |
| ML19320C545 | List: |
| References | |
| NUDOCS 8007170354 | |
| Download: ML19320C544 (18) | |
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UNITED STATES OF AMERICA 7/15/80 NUCLEAR REGULATORY COMMISSION BEF_0RE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER C0ftPANY
)
Docket No. 50-155
)
(Big Ro'ck Point Nuclear Power
)
(Spent Fuel Pool Modification)
Station)
)
(
NRC STAFF RESPONSE TO CHRISTA-MARIA, ET AL.,
INTERROGATORIES TO THE NRC STAFF In accordance with 10 C.F.R. 66 2.720 and 2.744, the Staff of the Naclear Regulatory Conmission (Staff) hereby responds to Christa-ilaria, et al.
Interrogatories to the NRC Staff dated June 26, 1980.
Each of Christa-Maria's interrogatories is restated and a response is provided.
Following the responses are affidavits identifying the individuals who prepared the responses and verifying them.
TH)S DOCUMENT CONTAlNS I
P00R QUAUTY PAGES j
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JnterroSatory 1 With regard to each contention and Board Question admitted for litigation in this proceeding by the Atomic Safety and Licensing Board in its " Order Following Special Prehearing Conference" dated January 17, 1980, or its
" Memorandum and Order Regarding Two Additional Board Questions" dated March 27,1980:
(a)
Identify each person whom the Staff expects to call as an expert witness in. respect of such contention or Board question; (b) State the subject matter on which the expert witness is expected to testify; t
(c) State the substance of the facts and opinions to which the expert
- witness is expected to testify and summarize the grounds for each opinion; (d)
Identify all documents relied upon or examined by the expert witness in answering subparagraph (c) above; (e)
Identify all documents not identified in subparagraph (d) above which the expert witness expects to put into evidence or to rely upon in support of his or her testimony in this proceeding.
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Response
i Listed below are those contentions admitted in this proceeding concerning which the Staff has identified the persons expected to present testinony.
The Staff is unable at this time to provide the names of persons who will testify concerning the contentions and Board questions not so listed. The persons expected to testify concerning the listed contention are identified below, However, the designation of witnesses could change. Attached are i
statements of professional qualifications for these witnesses.
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. Ceritentions Witness (es)
Christa-Maria
~2 Jack N. Donohew, Jr.
3 John R. Weeks 1
Christa-Maria Contention 8 and Edward Lantz John O'Neill, II, Contention IIE-2 4
John O'Neill, II I
j IB-5 Weeks a
{
IIA Donohew/Jacques S. Boegli i
IIB Donohew IIE-3 Lantz IIE-4 Donchew IIF Donohew/Boegli IIG Donohew In addition the Staff may call Mr. Walter A. Paulson, who is serving as i
project manager for this project, as an additional witness on any of the contentions or Board questions.
1 The Staff testimony has not been prepared, and, therefore, the substance of that testimony cannot be provided. When the preparation of the testimony is completed, that testimony will.be served upon the parties in accordance with the schedule adopted by the Licensing Board by Order dated January 17, 1980.
This response was prepared by Janice E. Moore.
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I nter roga to ry_2, Answer Interrogatory 1 above with respect to each contention identified as being withdrawn subject to reassertion in the Atomic Safety and Licensing Board's " Order Following Special Prehearing Conference" dated January 17, 1980.
Rysponse Since the contentions mentioned in this interrogatory have not been admitted as matters in controversy in this proceeding, the Staff has not designated expert witnesses to testify concerning them.
This response was prepared by Janice E. Moore.
O
]niperogatory 3 With respect to each contention and Board question admitted in litigation in this proceeding:
(a)
Identify any person having knowledge of.he facts relating to such contention or Board Question (other than the expert witnesses identified in response to Interrogatory 1).
This question is limited to those persons whom the Staff expects to call as witnesses other than expert witnesses in this proceeding, or with whom the Staff has consulted or expects to consult in connection with this proceeding.
(b) For each person who has been consulted, state when he or she was consulted and summarize the substance of any facts or opinions communicated by such person to the Staff relating to the subject matter of any contention or Board Question.
(c)
If the Staff expects to call any person identified in response to Interrogatory 3(a) above to testify, state the substance of his or her testinony, summarize the basis for any opinions contained in such testimony, and identify all documents which will be introduced as evidence er relied upon by such person in support of such testimony.
Response
(a) The Staff does not intend to call anyone.is a witness in this proceeding who is not an expert witness.
Dr. Weeks will be an expert witness for the Staff.
See Interrogatory 1.
(b) Dr. John R. Weeks of Brookhaven National Laboratory was consulted on November 20, 1979 in connection with this proceeding.
(c) Not applicable.
This response was prepared by Janice E. Moore.
'2L'a tog A Ann.er Interrogatory 3 above with respect to each contention identified as being sithdrawn subject to reassertion in the Licensing Board's
" Order Following Special.Prehearing Conference" dated January 17, 1980.
Eqspanse See Interrogatory 2 above.
This response was prepared by Janice E. Moore.
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Interrapiorv 5 Identify all documents which the Staff expects to introduce in evidence or use for impeachment or other cross-examination purposes in this proceeding, other than those identified in the responses to the previous Interroga tories.
Resp _onse The Staff intends to introduce into evidence those documents prepared by it upon completion of the review of the license amendment application.
The Staff also intends to provide the testimony of various expert witnesses concerning the contentions and Board questions admitted as matters in controversy in this proceeding. See Interrogatory 1.
Every document i
f introduced into evidence by any party to the proceeding, documents obtained 1
as a result of discovery, general treatises on pertinent technical subjects, and any other documents obtained during the course of this proceeding by Staff Counsel, may be used for impeachment or other cross-examination purposes in this proceeding.
A more specific response identifying the documents to be used for such purposes would require disclosure of Staff 1
Counsel's work product in the form of mental processes, impressions, or legal theories.
The discovery of such matters is prohibited by 10 C.F.R.
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52.740(b)(2) of the Commission's regulations.
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This response was prepared by Janice E. Moore.
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Inte rroca to ry_6 Please identify and provide copies of all NRC Staff memoranda, reports or other Jocuments or memoranda discussing the progress of the Systematic i
Evaluation Program at the. Big Rock Plant.
Please include any reports c
or other documents or memoranda that discuss the progress of the SEP in general, without specific reference to Big Rock.
R_e.spons e_
The following documents discuss the progress of the Systematic Evaluation l
l Program (SEP) in general, the progress of said program with respect to the Big Rock Point Plant, and provide definitions of the topics involved in the SEP to aid in interpretation of the enclosed status reports:
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Briefing on Systenatic Evaluation Program, meeting held on May 6,1980.
2.
Topic Status Listing 3.
Definitions of Topics in Systematic Evaluation Program r
The documents provided in response to this Interrogatory were identifed by Walter A. Paulson'.
Respectfully submitted, W dA IDt- /VLMQ-.
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Janice E. Moore Counsel for NRC Staff 1
Dated at Bethesda, Maryland 1
this =15th day of July,1980.
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VI;liLD.'ll.TES CF /?: ERICA fiUCLEAR iuGULATORY CO.".AISSIO i BEFOR_E THE ATOMIC SAFETY AND LICENSING BOARD _
In the Matter of
)
)
CONSUMERS POWER COMPANY
)
Docket No. 50-155
)
(Big Rock Point Nuclear Power
)
(Spent Fuel Pool Modification)
Station)
)
AFFIDAVIT OF JANICE E. MOORE I, Janice E. Moore, being first duly sworn, do depose and state:
l 1.
I am an attorney in good standing admitted to practice before the court of the District of Columbia.
I hold the position of Staff Attorney in the Office of the Executive Legal Director of the Nuclear Regulatory Commission and serve as.itaff Counsel in this proceeding.
2.
The answers to Christa-Maria, et al., Interrogatories 1 through 5 were prepared by me.
I hereby certify that the answers given by me are true and accurate to the best of my knowledge, infonnation, and belief.
T 2/ufDL E fTlf2@o Janice E. Moore Subscribed and sworn to before me this 14th day of July,1980.
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U' Notary Public
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My Commission expires:
July 1, 1982
- _ = _ _ _ - - _ _ _. _ - - _
UttITED STATES OF /"EN CA flVCLEAR f:EGUL ATORY CC". *IE10:1 BEFORE THE ATOMIC SAFETY A!lD LICEr5II;G L0ARD In the Matter of C0flSUltERS POWER COMPAflY
)
Docket No. 50-155
)
(Big Rock Point Nuclear Power
)
(Spent Fuel Pool Modification)
Station)
)
AFFIDAVIT OF WALTER A. PAULSON I, Walter A. Paulson, being first duly sworn, do depose and state:
1.
I am the Nuclear Regulatory Commission Project Manager for the Big j
Rock Point Plant, Division of Licensing, Office of Nuclear Reactor Regulation, fluclear Regulatory Commission, Washington, D. C.
20555.
2.
I identified the documents listed in response to Christa-11 aria, et al.,
Interrogatory 6.
l-I hereby certify that the information given by me is true and accurate to the best of my knowledge and belief,
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u Walter A. Paulson Subscribed and sworn to before me this 14th day of July, 1980.
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~p' Notary Public
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My Commission expires:
July 1,- 1982
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PROFESSIONAL QUALIFICATi0"S 0F WALTER A. PAULS0" I am the Nuclear Regulatory Commission _ Project Manager for the Big Rcck Point Plant as well as one other nuclear power plant.
As a Project Manager I manage and participate in the review and evaluation of safety and environmental considerations associated with the design and operation of nuclear power facilities, especially those licensed for operation.
I also currently manage and participate in the Systematic Evaluation Program which involves a comprehensive review and evaluation of older operating facilities to determine and document the acceptability of departures from current licensing requirements.
I received a' Bachelor of Chemical Engineering Degree from Pratt Institute in 1957.
In 1959, I received a Master of Science Degree in Nuclear Science and Engineering from Rensselaer Polytechnic Institute, Frcc 1958 to 1962 I was employed by E. I. duPont de Nemours at the Savannah River Plant and held the position of Chemical Engineer with responsibilities in the areas of heat transfer., fluid flow, instrumentation, and fuel element operational performance.
From 1962 to 1973 I was employed by the National Aeronautics and Space Administration at the Lewis Research Center in Ohio.
I held positions as nuclear engineer in heat transfer, fluid flow and shielding design, and supervisory nuclear engineer in these areas.
In May 1973, I joined the Nuclear Regulatory Commission (formerly AEC) as a Licensing Project Manager.
I have also held the positions of Research Analyst, Technical Assistant, and Operating Reactors Project Manager.
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E Ej..fd D_,L A'il Z DIVIS10'i 0F OPE'% TING REALTORS U_.S. NUCLEAR REGU_LATORY COMMISSION PROFESSIONAL QUALIFICATIONS _ '
As an Engineering Systems Analyst in the Plant Systems Branch I am responsible for technical reviews and evaluations of component and system designs and operating characteristics of licensed nuclear power rea cto rs.
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I have a Bachelor of Science degree in Engineering Physics from the Case Institute of Technology and a Masters of Science degree in Physics from Union College and a total of 'A years of professional experience, with over 20 years in the nuclear i. eld.
My experience includes work on i'
reactor transients and safeguards analysis, nuclear reactor analysis and design,' research and development on nuclear reactor and reactor control concepts and investigations of their operational and safety :spects.
I have held my present position with the Commission since December 1975.
t My previous position, which I held for about two and one half years, was Project Manager in the Gas Cooled Reactors Branch, Division of Reactor Licensing, U. S. Nuclear Regulatory Commission, where I was responsible for the technical review, analysis, and evaluation of the nuclear safety aspects.of-applications for construction and operation of nuclear power plants.
For about ten years prior to that I was Head of the Nuclear Reactor Section in NASA.
My section was responsible for the development and -verification of nuclear reactor analysis computer programs, conceptual design engineering, and development engineering contracting.
Prior to my employment with NASA, I was a nuclear engineer at the Knolls Atomic Power Laboratory for about six years, where I worked on the safeguards and
- nuclear design of the 53G reactors and the initial development of the nuclear design of the S5G reactors.
Previous experience includes system engineering and electrical engineering with the General Electric Company and electronic development engineering with the Victoreen Instrument Company.
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Jacques S. Boegli Professicnal Qualifications Effluent Treatrent Systens Branch Office of Nuclear Reactor Regulation My name is Jacques S. Boegli.
I am a Senit-Nuclear Engineer in the Effluent Treatment Systems Branch in the Office of Nuclear Reactor Regulation. I attended Case Institute of Technology and received a Bachelor of Science Degree in Chemical Engineering from Indiana Techni-cal College in 1951. In 1952, I received a Master of Science Degree in Chemical Engineering from Kansas State College. From 1955 to 1956 I completed advanced courses in chemical and nuclear engineering at the University of Michigan and applied Health Physics 2 raining at the Oak Ridge National Laboratory.
From 1953 to 1973 I was employed by the National Aeronautics and Space Administration and held positions as research engineer in heat and cass transfer, design engineer in nuclear reactor coolant, utilities, ventila-tion and radwaste systens, process systems supervisor, and technical consultant at the NASA Plum Brook Reactor in Ohio.
In July 1973, I joined the Nuclear Regulatory Commission (formerly AEC) as a Senior Nuclear Engineer in the Effluent Treatment Systems Branch, Division of Technical Review.
In this position I am responsible for 1
the review and evaluation of radwaste treatment systems and for the calculation of releases of radioactivity from nuclear power reactors.
The duties involve developing analytical codels and performing calcula-tions on ~ the effectiveness of proposed radwaste systems, studying technicalogical improvements and developing criteria governing radwaste processing, monitoring, shielding and handling.
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I EDTE 5510'1AL OU;L 1 FJ CGI dis E
JOHN R. WEEKS i
I am currently a metallumist at Brookhaven National Laboratory, (BNL), where I have been anployed since 1953.
My present title is Leader, Corrosion Science Group, in the Departz.ent of Nuclear Energy. My current responsibilities include experimantal investigations on the mechanisms of stress corrosion cracking and pitting corrosion of stainless steels and Inconel, and providing technical assistance to the U.S. Nuclear Regulatory Comnission (NRC) in the area of corrosion and coolant chemistry in light water reactors.
I am a partidipating consultant on the NRC Pipe Crack Study Group.
I also am Chaiman of the BNL Reactor and Critical Experiments Safety Conmittee, and represent the Department of Nuclear Energy on the BNL Council.
Since joining Brookhaven I have performed and supervised research on materials behavior in both liquid metal and water cooled reactors.
From'1970 to 1972 I headed Brookhaven's program dn liquid sodium technology.
I have been materials advisor to the Reactor Division 6t BNL since 1959.
I was keynote lecturer in 1966 at the Inter-national Atomic Energy Agency Symposium on Alkali Metal Coolants, and served in 1967-1969 as a U.S. delegate at the US-UK information exchanges on corrosion of reactor ma terial s.
I was a consultant to Aerojet General on the SNAP-8 project.
I was an adjunct associate professor of materials science at SUNY - Stony Brook in 1962-1963, and am currently an adjunct professor of Metallurgy and Nuclear Engineering at the Polytechnic Institute of New York.
From 1972 to 1974 I was on assignment to the U.S. Atomic Energy Conmission as a senior metallurgist in the Materials Engineering Branch, Directorate of Licensing.
In 1974-1975, I served on the AEC (later NRC) Task Force investigating the causes of the stress corrosion problems in BWR piping.
My academic qualifications include a Met. E. degree from the Colorado School of Mines in 1949, a M.S. in 1950, and a Ph.D. in 1n53 in Metallurgy from the University of Utah.
I am a member of the American Society for Metals, for which I have been Chairman of the Long Island chapter, the Metallurgical Society of AIME, for which I have served as Chairman of the Nuclear Metallurgy Cocmittee, and the American Nuclear Society.
I am the author or co-author of approximately sixty-five publications in the areas of my research.
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!!M l.55!L3L (;AL:.- 1CAI JCCS OF JACK ff. 00:10!1EW, JR.
- y name-is Jack fi. Donohew, Jr6 I am a Senior fluclear Engineer in the Enviroruental Evaluation Branch in the Division of Operating Reactors, U.S. fluclear Regulatory Comnission (f!RC).
1!y duties include the review l;
of rad-waste treatment systems and engineered safety feature ventilation i
systems for operating reactors.
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j I received a Bachelor of Engineering Physics Degree from Cornell University
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in 1965, a Masters of Science Degree in fluclear Engineering from Massachusetts s.
Institute of Technology in 1968, and a Doctor of Science Degree in liuclear i
1
'1 Engineering from Massachusetts Institute of Technology in 1970.
I received my Professional Engineers License in t!uclear Engineering from the Coamomsealth of Pennsylvania in 1974.
After graduation, I worked for Stone and Webster Engineering Corporation as an engineer in the Radiation ~ Protection Group.
I was responsible for l
esti..ating source terms, release rates and resulting doses for the Safety Analysis Report, Environmental Report and response to !!RC questions for boiling water nuclear reactors.
I was also responsible for shielding design for the reactor water cleanup system.
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I was Icad engincer
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for the St.orcham Project and the equip:nent specialist for all nuclear plants
. for the containment iodine spray removal system, ventilation filter a,se:tblies, and Boiling 1.'ater Reactor and Pressurized 1.'ater Reactor gaseous 1.iste tn atnent system.
In June,1975, I joined-the T'uclear Regulatory Co:renission as a senior nuclcar engineer in the Efflu'ent Treatraent Systems Branch, Directorate of Licensing.
I was involved in rad-waste system licensing revied of nuclcar power plants.
I have conducted generic studies of the degradation of charcoal adsorbers in ventilation filter assemblies.
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In Dece.;,ber,1975, I joined the Environmental Evaluation Branch in the Division of Operating Reactors.
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. :: D 5,. I S OF .;;: :.A t AR i:LGULA;0hY CG:.415 S10N i;.
-.::E A10MIC SAf ETY AND L]CENSJf G LLARD In the Matter of
)
)
4 CONSUMERS P0;!ER C0"PANY
)
Docket tio. 50-155
)
(Sig Rock Point Nuclear Power
)
(Spent Fuel Pool Modification)
Station)
)
CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF RESPONSE TO CHRISTA-MARIA, ET AL.,
INTERROGATORIES TO THE NRC STAFF, in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulttory j
Conmission's internal mail system, this 15th day,of July,1980.
- Herbert Grossman, Esq., Chairman Joseph Gallo, Esq.
Atomic Safety and Licensing Isham, Lincoln & Beale Board Panel 1120 Connecticut Ave, N.W., #325 U.S. Nuclear Regulatory Commission l!ashington, D. C.
20036 Washington, D. C.
20555 John A. Leithauser i
Dr. Oscar H. Paris Leithauser and Leithauser, P.C.
Atomic Safety and Licensing Opal Plaza, Suite 212 Board Panel 18301 Eight Mile Road U.S. Nuclear Regulatory Commission East Detroit, MI 48021 Washington, D. C.
20555 John O'Neill, II Mr. Frederick J. Shon Route 2, Box 44 Atomic Safety and Licensing
.. Maple City, Michigan 49664 Board Panel U.S. Nuclear Regulatory Commission Christa-Maria
.l!ashington,'D. C.
20555' Route 2, Box 108c Charlevoix, MI 49720 Philip'P. Steptoe, Esq-Michael I. Miller, Esq.
Ms. JoAnne Bier Isham, Lincoln & Beale 204 Clinton Ont. First National Plaza Charlevoix, MI 49720 Suite 4200 Chicago, Illinois 60603 Barbara J. Godwin 306 Clinton Charlevoix, MI 49720
' Ai' ic Safety and Licensing Ms. Marcy Crown A, peal Board Panel 401 Alice Street U.S. Iluclear Regulatory Cornission Charlevoix, liichigan 49720
!lashington, D. C.
20555
- Alvaic Safety and Licensing Karin P. Sheldon, Esq.
hard Panel Sheldon, Harmon & Weiss U.S. i;uclear Regulatory Co:anission 1725 I Street, N.W.
1lashington, D. C.
20555 Suite 506 Washington, D. C.
20006
- DocLeting and Service Section U.S. Nuclear Regula tory Commission Mr. Gordon Howie Washington, D. C.
20555 411 Pine
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Boyne City, MI 49712 Mr. Thomas Damann Route 3, Box 241 Charlevoix, MI 49720 Judd L. Bacon, Esq.
Consumers Power Co.
212 West Michigan Ave.
Jackson, [1I 49201 d'W_)WW WY Janice E. Moore Counsel for NRC Staff
.