ML19343D355
| ML19343D355 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 04/23/1981 |
| From: | Eichhorn W EICHHORN, EICHHORN & LINK, LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, NORTHERN INDIANA PUBLIC SERVICE CO. |
| To: | ILLINOIS, STATE OF |
| References | |
| NUDOCS 8105040335 | |
| Download: ML19343D355 (27) | |
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/ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
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\ In the Matter of ) Docket No. 50-367
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NORTHERN INDIANA PUBLIC SERVICE ) (Construction Permit COMPANY ) Extension)
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(Bailly Generating Station, ) April 23, 1981 c
Nuclear-1) gg U:'60 NORTHERN INDIANA PUBLIC SERVICE COMPANY'S SECOND SET OF INTERROGATORIES TO 02 THE STATE OF ILLINOIS 4 SNMb r _.
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Northern Indiana Public Service Company (NIPSCO) hereby serves its Second Set of Interrogatories to the State of Illinois (hereinafter " Illinois"), pursuant to 10 C.F.R. S 2.740b. Each interrogatory is to be answered fully in writing, under oath or affirmation, and include all pertinent information known to Illinois. Each answer should clearly indicate the interrogatory to which it is intended to be responsive.
Under NRC regulations (10 C.F.R. S 2,740(e)) parties are required to supplement responses to interrogatories under certain circumstances when new and/or different information becomes available.
" Illinois" shall include all agents, employees, attorneys, in-vestigators, and all other persons directly or indirectly subject to its control in any way.
" Documents" means all written or recorded material of any kind or character known to Illinois or in its possession, custody, or es 9/
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, - control, including, without limitation, letters, correspondence, telegrams, memoranda, notes, records, minutes, contracts, agree-mer ts, records or notations of telephone or personal conversa-tions or conferences, inter-office communications, microfilm, bulletins, circulars, pamphlets, studies, notices, aummaries, reports, books, articles, treatises, teletype messages, invoices, tape recordings, and work-sbeets.
When used with respect to a document, " identify" means, without limitation, to state its date, the type of document (e .g . , letter, memorandum, telegram, chart, photograph, sound reproduction, etc.), the author and addressees, the present location and the custodian, and a description of its contents.
When used with respect to a person, " identify" means, with-out limitation, to state his or her name, address, occupation, and professional qualifications.
If Illinois cannot answer any portion of any of the Inter-rogatories in full, after exercising due diligence to do so, so state, and answer to the extent possible, specifying the in-ability to answer the remainder and stating when Illinois expects to be able to answer the unanswered portions.
NIPSCO'S INTERROGATORIES 1!
- 8. (a) For what period of time do you contend that the Bailly site will be dewatered during the extended period of construction?
l II Numbering of the following Interrogatories continues from i
NIPSCO's First Set of Interrogatories to Illinois (April 10, l 1981). ,
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(b) For what period of time do you contend that the Bailly site was dewatered between May 1, 1974 and September 1, 1979?
(c) What period of dewatering of the Bailly site was assessed in connection with issuance of Construction Permit No. CPPR-104?
(d) By what incremental period does the sum of your answers to Interrogatories 8(a) and 8(b) exceed your answer to Interrogatory 8(c)?
(e) Please provide the bases for your answers to Interrogatories 8(a), 8(b), and 8 (c) .
- 9. (a) What total volume of water do you contend will be removed from the Bailly site as a result of dewatering during the extended period of construction?
(b) What total volume of water do you contend l was removed from the Bailly site as a result of dewatering between May 1, 1974 and Sep-tember le 1979?
(c) What was the total volume of water removal from the Bailly site which was assessed in connection with issuance of Construchion Permit No. CPPR-1047 l
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. s (d) By what incremental volume does the sum of your answers to Inter'.ogatories 9 (a) and 9(b) exceed your answer to Interrogatory 9 (c) ?
(e) Please provide the bases for your answers to Interrogatories 9(a), 9(b), and 9 (c) .
- 10. (a) The environmental assessment at the construc-tion permit stage contemplated dewatering to what elevation?
(b) For what period of time was dewatering to the elevation specified in.your answer to Interrogatory 10 (a) contemplated?
(c) Please provide the bases for your answer to Interrogatories 10 (a) and 10(b).
- 11. (a) If the Bailly site is continuously dewatered to the elevation specified in your answer to Interrogatory 10 (a) , how long after the onset of such dewatering will the groundwater levels in the Bailly site area reach equi-librium as a result of dewatering (discount-ing variations in the groundwater levels from factors other than dewatering)?
(b) Please specify the depth of drawdown of the groundwater levels which you contend will
result from continuous dewatering to the elevation specified in your answer to Inter-rogatory 10(a) at distances of 700 feet, 1/2 mile, and 1 mile from the excavation.
(c) Please specify the rate of dewatering (vol./
min.) which you contend will occur as a result of continuous dewatering to the elevation specified in your answer to Interrogatory 10(a).
- 12. If the Bailly site is continuously dewatered to the elevation specified in your answer to Interrogatory 10(a), how long after the onset of such dewatering will the environmental impacts as a result of such dewatering reach an equilibrium (discounting varia-tions in environmental impacts from factors other than dewatering)?
- 13. Do your answers to Interrogatories 11(a), 11(b),
11 (c) , and 12 bound the results which would be obtained if the Bailly site were dewatered to an elevation higher than that specified in your answer to Interrogatory _ 10(a)?
- 14. (a) Do you contend that an incremental environ-mental impact during the extended period of construction will result from (1) dewatering during the incremental period specified in your answer to Interrogatory 8 (d) ?
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(2) dewatering of the incremental volume ;
l of water specified in your answer to' Interrogatory 9 (d) ?
(3) other causes? If yes, please specify the cause[s].
(b) Please describe in detail the incremental environmental impact which will result from each of the causes specified in your answer to Interrogatory 14(a).
- 15. Are the incremental environmental impacts described in your answer to Interrogatory 14(b) irreversible in whole or part once dewatering during the extended period of construction is completed?
- 16. If your answer to: Interrogatory 15 is yes, please specify which impacts are irreversible.
- 17. If the incremental environmental impacts described in your answer to Interrogatory 14(b) are reversible
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in whole or part once dewatering during the extended period of construction is completed:
(a) please specify which impacts are reversible i in whole or part; (b) please specify the degree to which those i
impacts are reversible; (c) please specify the time required to complete I the reversal process,'fdr each impact.
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- 18. (a) Are you contending that dewatering of Bailly during the extended period of construction will cause different groundwater levels at distances of 700 feet, 1/2 mile and 1 mile from the excavation than occurred as a result of dewatering prior to September 1, 1979?
(b) Are you contending that dewatering of Bailly during the extended period of construction will cause different direction or rates of groundwater flow at distances of 700 feet, 1/2 mile and 1 mile from the excavation than occurred as a result of dewatering prior to September 1, 1979?
(c) Are you contending that dewatering of Bailly during the extended period of construction will cause the groundwater at distances of 700 feet, 1/2 mile and 1 mile from the ex-cavation to exhibit different chemic.sl character-l 1stics than occurred as a result of dewatering l
l prior to September 1, 1979?
l (d) Are you contending that dewatering of Bailly during the extended period of construction l will cause the groundwater to be different in any other respects than occurred as a result of dewatering prior to September 1, 1979?
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2 (e) If your answer to Interrogatory 18 (a) , 18 (b) ,
18 (c) , or 18 (d) is yes,
- i. please describe each difference, specify-ing, e.g., its' magnitude, geographic ex-tent, and duration; ii. please describe the bases for contending that each difference will occur; iii. please describe the incremental environ-mental impact whicit will be caused-by each difference.
(f) If your answers to Interrogatories 18(a),
18(b), 18(c), and 18 (d) are no, please describe the respects in which the environmental impacts attributable to dewatering during the extended period of construction of Bailly will differ in kind or degree from those impacts, if any, which occurred as a result of dewatering prior to September 1, 1979.
- 19. (a) Are you contending that the extra period of dewatering of Bailly (as distinct from any changes in the parameters of the ground-water which will allegedly occur after Sep-tember 1, 1979, as a result.of dewatering
! during the extended period of construction) l l will cause'an increme.ntal environmental impact?
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(b) If yes,
- i. please describe the impact, and ii. please provide the bases for your con-tention.
- 20. You have contended that the " additional period of construction time (sought] is sufficient ta cause some of the rare species, particularly the
'5og indicator' [ Indicator] plants to disappear from the dunes ecosystem . . . ."II (a) Please identify the " rare species" mentioned above.
(b) Please specify the periods and rates of de-watering of the Bailly site which are required to cause the above plants "to disappear."
(c) Please provide the bases for your contention.
- 21. You have contended that the Indiana Dcnes National Lakeshore would be adversely affected by "a deficiency of water, a surplus in water characteristics, an increase in the rate or change of direction of water
." -j se flow, [or] dilution of the existing water . . .
(a) Please specify the " water" to which you are refer-ring.
/ " Supplemental Petition of the State of Illinois," Contention 3.A., p. 8 (Feb. 26, 1980).
11/- " Supplemental Petition of the State of Illinoig" Contention 3.A., p. 9 (Feb. 26, 1980).
(b) Please specify the numerical values for the parameters of the water which you are using as a reference for determining whether a deficiency, surplus, or a change in the water occurs.
(c) Please describe the adverse effects upon the Indiana Dunes National Lakeshore which will result from i . deficiencies of water;
- 11. surpluses of water; iii. changes in water characteristics; iv. changer in water-flow direction;
- v. changes in water-flow rates; and vi. dilution.
(d) Using the values specified in your answer to Interrogatory 21(b) as a reference, please specify the magnitude of change in the follow-ing parameters of the groundwater of the i Indiana Dunes National Lakeshore which can l
l occur befcre any adverse impact will result in the Indiana Dunes National Lakeshore:
i . groundwater level;
- 11. groundwater flow rate;
! iii. groundwater flow direction; iv. groundwater characteristics.
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. (e) Using the values specified in your answer to Interrogatory 21(b) as a reference, please specify the magnitude of change in the follow-ing parameters of the groundwater in the-Indiana Dunes Nat.onal Lakeshore which you allege will occur as a result of dewatering during the extended period of construction.
- i. groundwater level; i
- t. groundwater flow rate; iii. groundwater flow direction; iv. groundwater characteristics.
(f) Please describe the environmental impact which you allege will result from the change in items specified in your answer to Inter-rogatory 21(e).
(g) Please identify all documents upon which you relied and persons whom you consulted in answering Interrogatories 21(b) through 21(f).
(h) Please provide calculations upon which your answers to Interrogatories 21(b) through I.
i 21(f) are based.
1 22. You have contended that "[d]ewatering can alter subsoil structure in such a way that it can change the reaction to seismic occurrences."I/
(a) What are the bases for this contention?
L/
" Supplemental Petition of the State of Illinois," Conten-tion 3.E., p. 11 (Feb. 26, 1980).
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(b) (1) Are you contending that dewatering of the Bailly site prior to September 1, 1979, has altered the subsoil structure beneath Bailly? If yes, (2) Please describe in detail the manner in which the subsoil structure has been altered.
(3) Please identify any empirical data which supports your contention.
(4) Please specify all other bases for your contention.
(c) (1) If your answer to Interrogatory 22 (b) (1) is yes, are you contending that this alleged alteration in the subsoil structure beneath Bailly N-1 will affect the vibratory ground motion in the event of a seismic occurrence? If yes, (2) Please provide the bases for your contention.
(3) Please specify the effects upon the response parameters (acceleration, velocity, displacement, period, duration) and in the soil stability characteristics for the Safe Shutdown Earthquake.
(4) Please provide the calculations by which your answers to Interrogatory 22(c) (3) were derived.
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', (5) Please specify the effects upon the response parameters (acceleration, ve-locity, displacement, period, duration) and in the soil stability characteristics for the Operating Basis Earthquake.
(6) Please provide the calculations from which your answers to Interrogatory 22 (c) (5) were derived.
(d) (1) Are you contending that the effects specified in your answer to Interrogatory 22 (c) (3) wi_1 render Bailly N-1 unable to withstand the loads induced by the Safe Shutdown Earthquake? If yes, (2) Please specify those structures, systems, or components of Bailly N-1 which, contrary to 10 C.F.R. Part 100 Appendix A, S VI(a) (1) ,
will not remain functional in the event of a Safe Shutdown Earthquake.
(3) Please provide the calculations by which your answer to Interrogatory,22(d) (2) was derived.
(e) (1) Are you contending that the effects specified in your answer to Interrogatory 22 (c) (5) will render Bailly N-1 unable to withstand the loads induced by the Operating Basis Earthquake? If yes, i
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. 4 I' (2) Please specify.those structures, systems, or components of Bailly N-1 which, contrary to 10 C.F.R. Part 100 Appendix A, S VI(a) (2) ,
will not remain functional in the event of an Operating Basis Earthquake.
(3} Please provide the calculations by which your answer to Interrogatory 22(e) (2) was derived.
(f) (1) Are you contending that the alleged alteration in the subsoil structure beneath Bailly identified in your answer to Interrogatory 22(b) will affect the susceptibility of the Bailly site to surface faulting? If yes, l (2) Please provide the bases for your contention.
(3) Please specify the effect upon the magnitude of and probability for surface faulting at the Bailly site.
(4) Please provide the calculations by which your answe- to Interrogatory 22(f) (3) i was derived.
i (g)
(1) Are you contending that the effects specified in your answer to Interrogatory 22 (f) (3) will render Bailly N-1 unable to withstand ~ surf ace ' faulting as required by 10 C.F.R. Part 100, Appendix A 5 VI(b) (3) ?
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(2) Please specify those structures, syste=s, or cc=penents of Dailly N-1 which will be unable to withstand such surface faulting.
(3) Please provide the calculations by which your answer to Interrogatory 22(g) (2) was derived.
(b) (1) Are you contending that the alleged alteration in the subsoil structure beneath Bailly identified ir,your answer to Interrogatory 22(b) wi]~ affect the
=agnitude of seis=ically-induced floods and waves at the Bailly site? If yes, (2) Please provide the bases for your contention.
(3) Please specify the effects upon the =agnitude of such floods and waves.
(4) Please provide the calculations frcz which your answer to Interrogatory _22(h) (3) was derived.
(i) (1) Are you contending that the effects specified in your answer to Interrogatory 22 (h) (3) will render Bailly N-1 unable to withstand, consistently with 10 C.F.R. Part 100, Appendix A, 5 VI(c) , such ficods and waves? If yes, 4
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(2) Pl'3ase specify that part of the design of Bailly N-1 which is defective in response to auch floods and waves.
(3) Please provide the calculations from which your answer to Interrogatory 22(i) (2) was derived.
(j) (1) Are you contending that dewatering of the Bailly site duri.7g the extended period of dewatering will alter the subsoil structure beneath Bailly? If yes, (2) Please describe in detail the manner in which the subsoil structure will be altered.
(3) Please identify any empirical data which supports your contention.
(4) Please specify all other bases for your contention.
l (k) (1) If your answer to Interrogatory 22(j) (1) l l is yes, are you contending that the alleged alteration in the subsoil structure l beneath Bailly N-1 will affect the vibratory l
ground motion in the event of a seismic occurrence? If yes, (2) Please provide the bases for your contention.
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', 17-(3) Please specify the effects upon the response p rameters (acceleration, ve-locity, displacement, period,. duration) and in the soil stability characteristics for the Safe Shutdown Earthquake.
(4) Please provide the calculations by which your answers to Interrogatory 22(k) (3) were derived.
(5) Please specify the effects upon the response parameters (acceleration, velocity, displacement, period, duration) and in the soil stability characteristics for the Operating Basis Earthquake.
(6) Please provide the calculations from which your adswers to Interrogatory 22(k) (5) were derived.
(1) (1) Are you contending that the effects specified in your answer to Interrogatory 22 (k) (3) will render Bailly N-1 unable to withstand the loads induced by the Safe Shutdown Earthquake? If yes, (2) Please specify those structures, systems, or components of Bailly N-1 which, contrary to 10 C.F.R. Part 100, Appendix A, S VI(a) (1) l" Y WT** y
will not remain functional in the event of a Safe Shutdown Earthquake.
(3) Please provide the calculations by which your answer to Interrogatory 22 (1) (2) was derived.
(m) (1) Are you contending that the effects specified in ycur answer to Interrogatory 22 (k) (5) will rencer Bailly N-1 unable to withstand the leads induced by the
-Operating Basic Earthquake? If yes, (2) Please specify those structures, systems, or components of Bailly N-1 which, contrary to 10 C.F.R. Part 100, Appendix A, S VI(a) (2) ,
will not remain functional in the event of an Operating Basis Earthquake.
(3) Please provide the calculations by which your answer to Interrogatory 22(m) (2) was derived.
(n) (1) Are you contending that the alleged alteration in the subsoil structure beneath Bailly identified in your answer to Interrogatory 22(j) will affect the susceptibility of the Bailly site to surface faulting? If yes, (2) Please provide the bases for your contention.
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1 (3) Please specify'the effects upon the magnitude of and probability for surface faulting at the Bailly site.
(4) Please provide the calculations by which your answer to Interrogatory 22 (n) (3) was derived.
(o) (1) Are you contending that the effect.
specified in your answer to Interrogatory 22 (n) (3) will render Bailly N-1 unable to withstand surface faulting as required by 10 C.F.R. Part 1Ca, Appendix A, S VI(b) (3)?
If yes, (2) Please specify those structures, systems, or components of Bailly N-1 which will be unable to withstand such surface faulting.
(3) Please provide the calculations by whict.
your answer to Interrogatory 22(o) (2) l l was derived.
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l (p) (1) Are you contending that the alleged l
alteration in the subsoil structure beneath Bailly identified in your answer to Interrogatory 22(j) will affect the magnitude of seismically-induced floods and waves at the Bailly site? If yes,
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- (2) Please provide the bases for your contention.
(3) Please specify the effects upon the magnitude of such floods and waves.
(4) Please provide the calculations by which your answer to Interrogarory 22(p) (3) was derived.
(q) (1) Are you contending that the effects-specified in your answer to Interrogatory 22 (p) (3) will render Bailly N-1 unable to withstand, consistently with 10 C.F.R. Part 100, Appendix A,. S VI(c) , such floods ,
and waves? If yes, (2) Please specify that part of the design of Bailly N-1 which is defective in response to such floods and waves.
(3) Please provide the calculations from which your answer to Interrogatory 22(g) (2) was derived.
- 23. The licensing board in the construction permit ptoceeding found that NIPSCO "will not engage in any dewatering activities during the operation of" Bailly N-1.I!
(a) Are you contending that the alleged alteration of subsoil structure at the Bailly site as a result of dewatering will persist after de-watering has ceased prior to operation of Bailly?
1/ Northern Indiana Public Service Co. (Bailly Generating Station, Nuclear-1), LBP-74-19, 7 AEC 557, 589 (1974).
(b) If your answer to Interrogatory 23(a) is no, please specify the manner in which dewatering of the Bailly site during the extended period of construction will result in a violation of 10 C.F.R. Part 100.
(c) If your answer to Intarrogatory 23 (a) is yes, (1) Please provide the bases for your con-tention.
(2) Flease specify whether cessation of de-watering will affect the subsoil structure beneath Bailly. If yes,
- i. Please describe the impact of cassation of dewatering upon the 1
subsoil structure.
ii. Please state whether your answers to Interrogatory 22 accounted for the
' impact of cessation of dewatering upon the subsoil structure.
iii. Please provide answers to In*er-rogatory 22 which account for the im-pact of cessation of dewatering upon the subsoil structure if you have not previously done so.
- 24. You have contended that "the load bearing capacity of the plant and its foundation will be affected as will the effects of a core melt in a situation of altered
l water tables."1/ The licensing board in the construction l
permit proceeding found that NIPSCO "will not engage l 1
in any dewatering activities during the operation of" Bailly.$$/
(a) Are you contending that the water table at the Bailly site will be affected by dewatering after dewatering has ceased prior to operation of Bailly?
(b) If your answer to Interrogatory 24(a) is yes, (1) Please specify the magnitude, range, and duration of the effect.
(2) Please provide the calculations by whica your answer to Interrogatory 24 (b) (1) was derived.
(c) If your answer to Interrogatory 24(a) is no, please identify any manner in which dewatering of the Bailly site during the extended period of construct'on will allegedly result in a violation of the Com-mission's regulations.
(d) Please describe how the load-bearing capacity and the foundations of Bailly N-1 would be affected by " altered water tables."
I l */ " Supplemental Petition of the State of Illinois," Conten-l
! tion 3.E., p. 11 (Feb. 26, 1980).
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(e) (1) Are you contending that the load-bearing capacity and foundations of Bailly are de-ficient under the Commission's regulations in a " situation of altered water tables?"
If yes, (2) Please provide the bases for your contention.
(3) Please identify those systems, structures, or components of Bailly N-1 which are deficical.
(4) Please provide the calculations upon which your answer to Interrogatory 24 (e) (3) was derived.
(f) Please describe how the effects of a core melt will be affected by " altered water tables."
(g) (1) Are you contending that there would be signifi-
. cant differences between the environmental impacts of a core melt at Bailly in the presence of " altered water tables" and environmental impacts of a core melt at Bailly in the absence of " altered water tables"?
(2) If yes, please provide the bases for your i contention.
- 25. (a) Please identify the tasks associated with con-struction of Bailly which you contend were per-formed in an incompetent manner by NIPSCO, its contractors, or its subcontractors, and which thereby resulted in a delay of construction of Bailly.
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(b) For each task identified in your answer to Interrogatory 25(a),
(1) Specify the period of delay associated with ,
the task.
(2) Identify the companies which are responsible-for the delay associated with the task.
(3) Identify the individuals within the companies identified in your answer to Interrogatory 25 (b) (2) who are responsible for delay associated with the task.
(4) Specify which actions associated with the tasks were performed in an incompetent manner.
(5) Specify those actions which a competent person would have performed but which were not performed j in connection with the task.
(6) Specify those actions which a competent person would not have performed but which were per-formed in connection with the task.
(c) For each individual identified in your answer I
to Interrogatory 25 (b) (3) ,
(1) Specify the information which he did not know but should have known in order to perform the task competently.
i (2) Specify the training which he did not receive but should have received in order to perform the task competently.
(3) Specify the ability which he did not possess but should have possessed in order tp perform the task competently.
(d) For each task identified in your Laswer to Inter-rogatory 25(a),
(1) Specify whether or not the delay is attrib-utable to the need to repeat actions which were initially performed in an incompetent manner.
(2) Specify whether or not the delay is attrib-utable to the failure to perform actions as quickly as a competent person would have performed the actions.
- 26. With regard to each Illinois contention admitted in this proceeding:
(a) Identify each person whom Illinois expects to call as an expert witness in re:spect to ecch contention.
(b) State the subject matter on which the expert wit--
ness is expected to testify.
(c) State the substance of the facts and cpinions l to which the expert witness is expected to testify and summarize the ground for each opinion.
(d) Identify all documents relied upon or examined by the expert witness in answering subparagraph 26(c) above. .
/, e ) Identify all documents not identified in answering subparagraph 26 (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.
- 27. With respect to each tilinois contention admitted in this proceeding:
(a) Identify any person having knowledge of the facts relating _to each Ill'nois contention (other than the expcrt witnesses identified in response to Interrogatory 26(a)). This question is limited to those persons whom Illinois expects to call as witnesses other than expert witnesses in this proceeding, or with whom Illinois 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 by which repre-sentative of Illinois and summarize the substance of any. facts er opinions communicated by such person to the representative of Illinois relating to the subject matter of each Illinois contention.
(c) If Illinois expects to call any person identified in response to Interrogatory 27(a) above to testify, state the substance of his or her testimony, sum-marize the basis for any opinions contained in such testimony, and identify all documents which a
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27-will be introduced as evidence or relied upon by such person in support of such testimony.
- 28. Please identify all documents which Illinois 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 Interrogatories.
- 29. Please identify the documents upon which Illinois relies which relate to each Illinois contention admitted in this proceeding other than those documents identified in responses to previous Interrogatories.
R'spectfully e submitted, EICHHORN, EICHHORN & LINK 5243 Hohman Avenue Hammond, Indiana 46320 By:
William H. E~ichhorn Attorneys for Northern Indiana Public Service Company LOWENSTEIN, NEWMAN, REIS
& AXELRAD 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036
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