ML19347G005
| ML19347G005 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/26/1981 |
| From: | Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | COALITION FOR THE ENVIRONMENT, ST.LOUIS REGION, CRAWDAD ALLIANCE, MISSOURIANS FOR SAFE ENERGY |
| References | |
| NUDOCS 8105280045 | |
| Download: ML19347G005 (15) | |
Text
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I19//>S May 26, 1981 s
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/ DAY 2 7 Jggy UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION wa, f
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
to In the Matter of UNION ELECTRIC COMPANY
)
Docket Nos. STN 50-483
)
STN 50-486 (Callaway Plant, Units 1 and 2)
)
HRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO C0ALITION FOR THE ENVIRONMENT, ST. LOUIS REGION; MISSOURIANS FOR SAFE ENERGY; AND CRAWDAD ALLIANCE INTRODUCTION AND INSTRUCTIONS The NRC Staff hereby requests that Coalition For The Environment.
St. Louis Region; Hissourians For Safe Energy; and Crawdad Alliance, pursuant to 10 C.F.R. 95 2.74D, 2.740b and 2.741 o" the Commission's Rules of Practice and the presiding Licensing Board's "Special Prehearing Conference Order," (April 21,1981), answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce all documents requested in the interrogatories and document requests.
Contention No. 2A
" Applicant has not adequately assessed and cannot accurately predict the amount or discharge rate of the radioactive pollutants to be released from Callaway Plant, Unit 1, into the Missouri River, or the amount of dilution to be afforded by the river, which provides drinking water for downstream communities including the City of St. Charles anc St. Louis City and County."
8105280045
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" Anticipated water diversion projects in the Missouri River watershed and conditions of drought and freezing (ice-jams) would lower
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the amount of dilution water available and this could raise the concentration of radioactive material in the river to higher levels than calculated by U.E.
Because the Applicant cannot accurately predict radioactive releases, it cannot accurately predict the potential bioconcentration of radionuclides in fish."
Q-1(a)
With respect to Contention 2A, explain in detail all reasons underlying the assertions that Applicant:
(1) has not assessed adequately the discharge rate of radioactive pollutants to be released from Callaway into the Missouri River; and (2) cannot predict such discharge rate.
1(b)
Over what time frame is it asserted that " anticipated water diversion projects," and conditions of drought and freezing would lower the amount of dilution water available?
1(c)
What release rate (s), if any, are used as part of this contention? Are such release rrtes predicted or experienced rates?
1(d)
Specify in detail the " anticipated water diversion projects" referred to in the contention.
1(e)
Of the water diversion projects listed, by how much (quantify) would such projects, or are such projects expected to reduce the river flow?
1(f)
Explain why and how an alleged failure to predict release rates affects the predictability of bioconcentration of radionuclides in fish.
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1(g)
Provide the technical basis and all reasons underlying the assertion in the contention that Applicant cannot predict the amount or discharge rate of the radioactive pollutants to be released from Callaway Plant, Unit 1 into the Missouri River, or the amount of dilution to be afforded by the Missouri River.
a.
If nodels or parameters were used, describe such nodels or parameters.
b.
Describe any transfer factors used.
1(h) a.
Upon what person or persons do you rely to substantiate in whole or in part your views on Contention No. 2A?
b.
Provide the addresses and education and professional qualifications of any persons named in your response to 1(h)a. above.
c.
Identify which of the above persons or any other person you may call as witnesses on this contention.
d.
Provide summaries of the views, positions or proposed testimony on this contention of 'all persons named in response to subparts (a) and (c) immediately above that you intend to present during this proceeding.
e.
State the specific bases and references to any documents upon which the persons named in response to this I
interrogatory rely to substantiate their views regarding this Contention.
f.
List all documentary or other material that you may use l
during this proceeding to support this contention or refer to during your examination of witnesses. The list should 1
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be by author, title, date of publication (if applicable),
publisher (if applicable).
In addition to listing such documents, provide a copy of all documents that are not NRC documents or documents provided to the NRC in this proceeding.
Such documents need only be listed.
If uncertainty exists as to whether a document was provided to the NRC, provide that document.
Contention 2B
" Applicant completely ignores the potential impact of its radioactive releases on drinking water. The Applicant's analysis of the liquid pathway dosage includes only fish caught within.05 miles downstream from the discharge pipe and shoreline recreation activities.
(See FSAR Site Addendum, Table 11.2-4)."
Q-2(a)
Explain in detail the reasons for and underlying this assertion.
(b)
Explain in detail the technical bases for and underlying this assertion, including a description of any models, and parameters used.
(c)
Does the ignoring of the drinking water pathway beyond.05 miles increase or decrease the allowable radionuclide discharge rate? Explain your answer in detail.
(d)
Identify in detail and describe any drinking water pathways within.05 miles of the site.
(e)
Provide the same information here as was also requested in i
Interrogatory 1(h), subsections (a)-(f) for Contention 2A.
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Contention 2C
" Adsorption and absor'ption o'f some radionuclides in sediment and the potential resuspension of these materials in the event of dredging or flooding could lead to high levels of contamination."
Q-3(a)
Explain in detail the technical basis for this assertion, including a description of any models or parameters used.
(b)
What buildup of sediment did you assume and/or do you believe is applicable?
(c)
What radionuclides are being referred to?
(d)
What technical basis is there that dredging or flooding will or could cause resuspension? Explain your answer in detail.
(e)
Please e1 plain what is meant (by the Joint Intervenors) by "high levels of contamination."
(f)
Provide the same (or similar) information for this Contention 2C that is requested in Interrogatory 1(h), subsections (a)-(f) of Contention 2/..
Contention 20 i
" Applicant has not adequately assessed and cannot accurately predict the amount or discharge rate of the radioactive pollutants to be released j
from Callaway Plant, Unit 1, into the atmosphere.
Furthermore, due to meteorological considerations, U.E. is unable to predict accurately the dispersion of radioactive materials or their fallout rate."
Q-4(a)
Explain in detail the technical basis for this assertion; explain all assumptions and parameters used.
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(b)
Provide the release rates, if any, which you have considered or utilized wt th respect to this contention. Are such release rates predicted or experienced rates? Explain yeur answer.
(c)
Specify and explain in detail the " meteorological considerations" referred to in the contention.
(d)
Explain in detail the basis for your assertion that Applicant "cannot accurately predict the amount or discharge rate of the radioactive pollutants to be released from the Callaway Plant, Unit 1, into the atmosphere."
(e)
Explain in detail how meteorological considerations near the plant affect the predictability of "the dispersion of radioactive materials or their fallout rate."
(f)
Provide the information f9r this Contention 2D that is requested in Interrogatory 1(h), subsections (a)-(f) of Contention 2A.
Contention 2E "There will be inadequate monitoring of the release of tritium, i
noble gases, alpha, beta and gamma emitters when in quantities below the level of detection of commercial monitoring equipment or during accidental releases."
Q-5(a)
Explain in detail the technical or other 3 asis for this assertion; explain all assumptions and parameters used.
(b)
What is the " level of detection of commercial monitoring equipment" referred to in the contention?
(c)
Describe what dose commitments or levels could result to individuals near the plant if releases were continually made
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immediately "below the level of detection of commercial nonitoring equipment.". (Use whatever time frame or time frames i
you consider most appropriate, but explain briefly why that t
time frame was selected.)
(d)
What release rates are used as part of this contention?
(e)
Provide the information for this Cratention 2E that is requested in Interrogatory 1(h), subsections (a)-(f) of Contention 2A.
Contention 2G "U.E.'s estimates of annual emissions do not take into account releases from the spent fuel pool, increased releases as the plant gets older and leakier (e.g., from steam generator tube deterioration) and releases from decontamination procedures Q-6(a)
Explain in detail thc techriicai or other basis for this assertion; explain all assumptions and parameters used.
(b)
What annual release rates do you believe exist or will exist with respect to the spent fuel pool, from steam generator tube deterioration, and from " decontamination procedures"?
(c)
Explain in detail what is meant by " steam generator tube deterioration" and " decontamination procedures." As to "stean generator tube deterioration," quantify the amount of such releases.
(d)
Provide the information for this Contention 2G, that has been requested in Interrogatory 1(h), subsections (a)-(f).
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F 8-Contention IA
" Inadequate and incomplete inspection and testing on embedded plates were performed during the plant's construction."
Q-7(a)
Explain the technical basis for the statement that "If an embedded plate tears loose from the wall, the result could be the collapse of an entire floor, breakage of critical pipes in the primary and emergency core cooling systems, and even core melt-down" (" Amended and Supplemental Joint Petition To Intervene," March 6,1981, p. 5, hereinafter " amended petition").
(b)
With respect to NRC Report No. 50-483/80-14 (See amended petition, p. 5), indicate, and explain in detail any parts of that report that you do not in general find acceptable.
(c)
State the technical basis for such disagreement or unacceptability with respect to each iten listed in (b).
(d)
Do you believe that there is improper welding to any embedded l
l plates other than those plates previously identified by the l
l NRC? Explain the basis for such disagreenent.
(e)
Explain in detail the basis for the statement that "... the Applicant improperly determined, with the NRC's apparent approval, that certain exceptions to structural welding code standards could be tolerated" (Amended Petition, p. 6).
(f)
Provide the information for this Contention 1A that is requested in Interrogatory 1(h), subsections (a)-(f) of Contention 2A.
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Contention IB "Several cracks in concrete structures at the site which affect the plant's safe operation were not inspected and were accepted."
Q-8(a)
Explain the technical basis for your statement that "there exist several cracks in concrete structures at Callaway that affect its safe operation."
(b)
Explain in detail the technical basis for your position that such cracks " affect the safe operation" of Callaway.
(c)
As to the " crack approximately 12 feet long and 8 inches deep" on the north wall of tne Control Building (Amended Petition,
- p. 7), is it your position that the existence of such a crack would be unacceptable for the safe operation of Callaway? If yes, explain the basis for such position.
(d)
With respect to NRC Report No. 50-483/78-03 (See amended petition, p. 7) explain in detail any parts of that report that you do not in general find acceptable that relate to this contention.
State the technical or other basis for such disagreement or unacceptability for each item.
(e)
Provide the information for this Contention IB that is requested in Interrogatory No.1(h), subsections (a)-(f) of Contention 2A.
Contention 1C "A number of instances of honeycombing (air pockets or voids) occurred ouring construction in the reactor building basement of the reactor building dome."
Q-9(a)
Is it your position that the repairs and/or testing to the void described in NRC Report No. 50-483/77-06 and 77-07 were inadequate (Amended Petition, p. 8).
If yes, explain the technical basis for this position.
(b)
Do you have any reason to believe that the August 1,1977, soniscope study and report by Wiss, Janey, Estner and Associates, Inc., was inadequate.
If yes, explain your position in detail with supporting reasons.
(c)
Do you have any reason to believe that additional honeycombing, other than that described in the reports outlined in (a) immediately above exists? Explain the technical basis for your position.
(d)
With respect to NRC Report Nos. 50-483/78-01 and 80/30 (See amended petition, 8-9) explain in detail any parts of those reports that you do not in general find acceptable that relate to this contention. State the technical or other basis for such disagreement or unacceptability for each item.
(e)
Provide the information for Contention 1C that is requested in Interrogatory No.
1(h), subsections (a)-(f) of Contention 2A.
Contention ID "A concrete coverage of reinforcing bars in concrete walls and i
floors in many areas of the plant does not meet NRC requirements."
Q-10(a)
What effect does deviation from "Bechtel Power Corporations
... cover requirements" (Amended Petition, p. 9) have on the safe operation of Callaway, Unit I? Explain your answer in detail and give the technical basis therefor.
(b)
Delineate any other areas in Callaway, Unit I where concrete coverage of reinforcing bars is alleged not to meet requirements, other than those two instances on p.10 of the amended petition.
(c)
What NRC reqeirements do the Joint Intervenors believe are included in the phrase "does not meet NRC requirements" in the above contention ?
(See amended petition, p. 10).
(d)
As to concrete coverage of reinforcing bars, is it your position that if that such concrete coverage, "does not meet NRC requirements," that this situation would be unacceptable?
(e)
With respect to HRC Report Nos. 50-483/77-11 and 78-01 (See amended petition, p.10) explain in detail any parts of these reports that you do not in general find acceptable that relate to this contention.
State the technical or other basis for such disagreement or unacceptability for each item.
(f)
Provide the information for this Contention ID that is requested in Interrogatory 1(h), subsections (a)-(f) of Contention 2A.
Contention IE
" Safety-related piping not in conformity to ASME codes was utilized in the plant."
Q-11(a)
If " safety-related piping" were "not in conformity to ASME codes," explain how this would effect the safe operation of the Callaway plant.
Provide the technical basis or reasons for your response.
(b)
On page 11 of the amended petition, it is stated that "the evaluation and acceptance of this substandard SA-312 piping
were not performed according to the requirements of Section III of the ASME Code." Explain what specific aspects of the
" evaluation and acceptance" did not meet the ASME Code.
Include in your answer specific references to "Section III of the ASi1E Code."
(c)
With respect to liRC Report tios. 50-483/80-10, fiRC/IE Bulletins 79-03 and 79-03A, and Union Electric letter ULNRC-314 (May 11, 1979) (see Amended Petition, p.11), explain in detail any parts of these documents that you do not in general find acceptable that relate to this contention.
State the technical cr other basis for such disagreement or unacceptability for each item.
(d)
Provide the information for this Contention IE that is requested in Interrogatory 1(h), subsections (a)-(f) of Contention 2A.
Contention IF
" Improper inspection techniques and defective welds were used in pre-assembly piping formations."
Q-12(a)
Explain in detail why, in your view, the inspection techniques were " improper."
Include the technical basis for your response.
(b)
Explain in detail the nature, scope and number of " defective welds." Include the technical basis for your response.
(c)
Provide the informatico for Contention IF that is requested in Interrogatory flo.1(h), subsections (a)-(f) of Contention 2A.
Q-13(a)
List all individuals participating in answering these interrogatories.
Provide their names, addresses, business, or occupation, if any, and telephone numbers.
If the individual is a member of one or more of the " joint intervenors" organizations, list that membership.
(Exclude clerical assistance in preparing answer).
(b)
For each such individual, list the approximate percentage of time that individual participated relative to other listed individuhis.
Respectfully submitted, Roy P. Lessy Deputy Assistant Chief Hearing Counsel Dated at Bethesda, fiaryland, this 26th day of May,1981.
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.'t:113SION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
UNION ELECTRIC C0t!PANY Docket flos. STN 50-483
)
STN 50-486 (Callaway Plant, Units 1 and 2)
)
URTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO C0ALITION FOR THE ENVIRONMENT, ST. LOUIS REGION; MISSOURIANS FOR SAFE ENERGY: AND CRARDAD ALLIANCE" 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 by deposit in the Nuclear Regulatory Comission internal mail system, this 26th day of May,1981:
James P. Gleason, Esq., Chairman Barbara Shull Atomic Safety and Licensing Board Lenore Loeb 513 Gilmoure Drive f.eague of Women Voters of Missouri Silver Spring, MD 20901 2138 Woodson Road St. Louis, MO 63114 Mr. Glenn 0. Bright
- Atomic Safety and Licensing Board Mar.iorie Reilly U.S. Nuclear Regulatory Commission Energy Chairman of the League of Washington, DC 20555 Women Voters of Univ. City MO 7065 Pershing Avenue Dr. Jerry R. Kline*
University City, MO 63130 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Gerald Charnoff, Esq.
Washington, DC 20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge Mr. John G. Reed 1800 M Street, N.W.
Rt. 1 Washington, DC 20036 Kingdom City, M0 65262 Dan I. Bolef Treva J. Hearne President, Board of Directors Assistant General Counsel for the Coalition for the Environment, Missouri Public Service Commission St. Louis Region P.O. Box 360 6267 Delmar Boulevard Jefferson City, MO 65101 University City, M0 63130 t
Donald Bollinger, Member Rose Levering, Member Missourians for Safe Energy Crawdad Alliance 6267 Delmar Boulevard 7370a Dale Averue University City, MO 63130 St. Louis, MO 63117 Mr. Fred Luekey Presiding Judge, fiontgomery County Rural Route Rhineland, M0 65069 Mayor Howard Steffen Chamois, MO 65024 Professor William H. Miller Mr. Earl Brown Missouri Kansas Section, School District Superintendent Anerican Nuclear Society P.O. Box 9 Department of Nuclear Engineering Kingdom City, MO 65262 1026 Engineering Building University of Missouri Mr. Samuel J. Birk Columbia, MO 65211 R.R. #1, Box 243 Morrison, MO 65061 fir. Harold Lottman Presiding Judge, Dasconade County Robert G. Wright Rt. 1 Associate Judge, Eastern District Owensville, M0 65066 County Court, Callaway County, Missouri C. Floyd flathews Route #1 Birch, Horton, Bittner and lionroe Ful ton, MO 65251 Suite 1100 1140 Connecticut Avenue, N.W.
Atonic Safety and Licensing Washington, DC 20036 Board Panel
- U.S. Nuclear Regulatory Commission Docketing and Service Section*
Washington, DC 20555 Office of the Secretary U.S. Nuclear Regulatory Conmission Atomic Safety and Licensing Washington, DC 20555 Appeal Board
- l U.S. Nuclear Renulatory Commission l
Washington, DC 206S5 i
Kenneth M. Chackes Chackes and Hoare Attorney for Joint Intervenors l
i 314 N. Broadway l
St. Louis, Missouri 63102 RoyP.Lessyd" Deputy AssisYant Chief Hearing Counsel
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