ML19351F122
| ML19351F122 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/04/1980 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8012290537 | |
| Download: ML19351F122 (21) | |
Text
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HF. LATED CORRESPONDENCE 12/k/80 & coe g Ub, . :
UNITED STATES OF MERICA ,L'- Q'tC -
NUCLEAR REGUIATORY CCMMISSION ;
04 , f Me e1 o s b.6,,
BEFORE ME ATCMIC SAFETY AND LICENSIF, BOARD 3 , f '*
8 h
C In the Matter of l A \e l l Docket Nos. So kk5 ;
APPLICATICK OF MIAS 17tILITIES l and 50-446 i l
GENERATING CCMPANY, ET AL. FOR AN l l
OPERATIEQ LICEESE FOR C NANCHE -
PEAK S HAM EI2CMIC STATION l UNITS fl AND #2 (CPSES) J -
CASE'S THIRD SET OF INTERROGATORIES Ji TO APPLICANTS AMD REQUESTS M PRODUCE COGS NOW CASE (Citizens Association for Sound Energy), hereinafter referred to as CASE, Intervenor herein, and files this, its Second Set of Interrogatories to Applicants and Requests to Produce.
Pursuant to 10 CFR 2 7kOb and 2 741, please answer the following interroga-tories in the manner set forth herewith. Each interrogatory should be answered fully in writing, under oath or affirmation, and include all pertinent informa-tion known to Applicants, their officers, directors or employees as well as any pertinent information known to their advisor's or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of Applicants, their officers, directors or employees as well as their advisors or counsel. Answer each interrogatory in the order in which it is asked, ambered to correspond to the number of the interrogatory; do not combine answers. Please identify the person providing each answer or response.
These interrogatories and requests to produce shall be continuing in nature.
Thus, any time Applicants obtain information which renders any previous response 8012290
& $00 ggf a
incorrect or indicates that a response was incorrect vaen made, Applicants should supplement their previous response to the appropriate interrogatory or request to produce. Applicants should also supplement their responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. The term " documents" shall induda any writings, drawings, graphs, charts, photographs, reports, studies, and other data capilations fra which information can be obtained. We request that at a date or dates to be agreed upon by mutual consent, Applicants make available for inspection and copying au documents which CASE has specifically requested or subject to the requests set forth below. An interrogatories which do not request documents should be answered pursuant to 10 CFR 2 7 Mb(b).
CASE'S INTERROGATORIES AND REQUESTS 'IO PRODUCE Contention 5 The Applicants' failure to adhere to the quality assurance / quality control provisions required by the construction permits for. Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and the construction
[ practices employed, specificau y in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, velding, inspection and testing, materials used, craft labor quali-fications and working conditions (as they may affect QA/QC), lack of compliance, failure to report items of non-compliance, lack of methods of identification and control of nonconformance, program surveillance, procedural deficiencies, storage of electrical components, failure to follow pipe fabrication procedures, failure to fonov equipment maintenance, and possible damage to the pressuriser, have raised substantial questions as to the adequacy of the construction of the facility. As a result, the Commtission cannot make the findings required by 10 C7R 50.27(a) necessary for the issuawe of an operating license for Comanche Peak.1 1
l CASE has incorporated into the verding of this contention the Inspection and Enforcement Report subjects identified in ACORN's Offer of Proof of 8/29/80, pursuant to the Board's Rulings of 10/31/80.
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- 1. It is CASE's understanding that TUGC0 is now in full control and charge of all activities at CPSES.
- a. Is this correct?
- b. If so, please answer the following questions regarding concrete activities:
(1) Regarding activities concerning concrete, when did TUGC0 take complete charge of such activities?
(2) Re: concrete, please briefly trace who had contral and charge of concrete activities at the plant initially, how they interfaced with TUGCO and TUGCO's rnie in QA/QC regarding concrete activities.
3 Follow this through to delineate the changes whien have been made regarding responsibility for concrete activities through to the present time.
(3) Why were the changes indicated in (2) above madet (4) What is the name of the TUCCO employee who has primary responsi-bility for concrete activities at the present time?
(5) Does the Ccapany plan to have the individual referenced in (k) above testify in the operating license hearings?
(6) If the answer to (5) above is no, will this individual be available to depose regarding concrete activities?
(7) If tha answer to (6) above is no, why not?
- i (8) Has the individual referenced in (4) above always had primary re-sponsibility for concrete activities at CPSES since construction first began?
l (9) If the ausser to (8) above is no, what are the names of the TUGC0 employees who formerly had such responsibility?
(10) For each of the nas.so r.typlied in response to (9) above, indicate the dates during which time each had such primary responsibility.
i (11) For each of the names supplied in response to (9) above, indicate l
vbether or not Applicants plan to have such individual testify in the operating license hearings.
1.b.(continued):
(12) Fcr each of the names supplied in response to (9) preceding, indi-cate whether or not such individual vill be available to depose regarding concrete activities?
(13) If the answer is no regarding any of the names referenced in (9) preceding, for each such individual advise why not?
- c. If the answer to 1.a. preceding is yes, please answer the following questions regarding velding activities:
(1) When did EUC0 take couplete charge of such activities?
(2) Please briefly trace who had control and charge of welding activities at CPSES initially, how they interfaced with nGCO, and TJGCO's role in regard to velding activities. Follow this through to delineate the changes whien have besa made regarding responsibility for velding activities through to the present time.
(3) Why were the changes indicated in (2) above made?
(k) What is the name of the EECO employee who has primary responsi-bility for velding activities at the present time?
(5) Do Applicants plan to have the individual referenced in (k) above testify in the operating license hearings?
(6) If the answer to (5) above is no, vill this individual be available to depose regarding concrete activities?
(7) If the answer to (6) above is no, why not?
(8) Has the individual referenced in (k) above always had primary responsibility for velding activities at CPSES since construction first began?
(9) If the answer to (8) above is no. what are the names of the WGC0 employees who formerly had such responsibility?
(10) For each of the osses supplied in response to (9) above, indicate the dates during which time each had such primary responsibility.
.k.
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l.c. (conticued):
(11) For each of the names supplied in response to (9) preceding, indi-cate whether or not Applicants plan to have such individual testify in the operating license hearings.
(12) For each of the names supplied in response to (9) preceding, indi-cate whether or not such individual vill be available to depose regarding concrete activities? -
(13) If the answer is no regarding any of the cases referenced in (9) preceding, for esca such individual advise why not?
- 2. Do you believe that Applicants' present practices and procedures can and will catch each and every construction error or deficiency at CPSES?
3 Do you consider the oversight and inspection procedures of the IRC to be:
- a. unnecessary?
- b. a duplication of the efforts of Applicants?
- c. a vaste of timet ,
- d. a vaste of money?
- e. too restrictivet
- f. too costly? *
- g. necessary?
- h. essential to assure the safe construction of CPSEST
- 4. Do you believe that the NRC's inspection of activities at CPSES to be:
- a. done adequately to assure the safe construction of CPSEST
- b. Poorly done?
- c. inadequate to assure the safe construction of CPSEST (N(7fE: In Questions 3 and 4 above, when we say " safe construction" we mean constructed in such a ==nnar so that the operation of the plant will not contaminate workers or the surrounding population or areas with radioactivity 5-
- h. (continued):
or subject vorhers or members of the public to the threat of danger, harm, or loss, frca radioactivity or frca accidents, or damage or harm the flora and fauna, mMaal life, birds, water, sir, or archeological aspects of the area.)
5 Are you familiar with a concept generally known as " Murphy's law"?
- 6. If the answer to 5. above is yes, please answer the following questicas:
- a. Do you believe there is a poss'ibility that this concept could come into play and apply at.CPSEST
- b. What is the technical or other basis for your answer to a. above?
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- c. Do you believe that CPSES will be immune from accidents?
- d. Do you believe that a " worst case" accident could not happen at CPSEST
- e. What is the technical or other basis for your answer to d. above?
7 Provide the name(s) of the individual (s) who answered Questions 2 through l 6 preceding. If more than one person answered, indicate who answered each question or portion of question.
- 8. Do Applicants plan to have the individual (s) referenced in 7 above testify 1 in the operating license hearings? Answer regarding each individual referenced.
9 It the answer regarding any or all of the individuals referenced in 7 above is no, vill such individual (s) be available to depose? Answer regarding each individual referenced.
- 10. If the answer to 9 above is no, why not? Answer regarding each individual referenced.
- 11. Regarding Inspection Report 78-17 (under cover letter of 10/26/78), especimuy the following portions which were excerpted from that report:
"...a Cadweld splice in the Unit 1 Contair=ent vall reinforcing steel had pulled apart upon application of a light force while preparing the spliced bar for additional splicing. The mode of failure was such that grosaly poor workmanship had to be the cause, either by intent or by negligence. The Cadweld splicer...had made a total of 687 splices over a period beginning January 21, 1977, and terminating March 27, 1978...and involved both Units j 1 and 2. The Cadweld splicer had been terminated in March 1978 for disciplinary
11.(continued):
reasons not related to his actual work.
"The following facts were established...
"All but 12 splices made by the splicer were embedded in concrete and thus were not readily available for ar==ination...The licensee's Product Assurance Group... reinspected 3106 cadwelds in Unit 1 containment not already embedded...
"The BkR (Brown & Root) inspector stated that he recalled the particular work that evening because of the difficulties and hazards involved...
The inspector related that he and several Cadwelders (the record indi-cates four) with their helpers were dispatched to Unit 1 Containment vall to add short bars to already installed diagonal bars in order to a.chieve the needed elevation for subsequent concrete placements. These pernonnel rode a construction elevator up the inside of Containment, crawled over the f.op of the liner, down Nelson studs on the outside and into place in the reinforcing steel. The work was to take place about 150' above the ground with no scaffolding and only site area lighting available. _
"The inspector indicated the splice setups were done with the aid of flashlights and that he used a penlight to perform his inspections, a condition which might explain why the extra witness marks were missed."
Regarding this &E Report, please suppb 2e following information:
- a. What were the " disciplinary reasons" !ar which thils worker was teminated?
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- b. The report indicates that all but 12 of the 687 splices which were made by this employee vere embedded in concrete and thus were not raaM1y available for examination; regarding this:
(1) Were the remaining 675 splices which were embedded in concrete i ever arm =ined?
(2) Were all of those 675 splices examinedt (3) If the answer to (2) above is no, how many were ar==4ned?
(k) How was such examination accmplished? What method was usedt (5) Who (supply both the c apany designation and the epecific name) conducted such examination?
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_ = . .- _
l 11.b.(continued):
1 (6) What were the results of such avamination? Answer with reasonable specificity. ;
(7) Is the individual referenced in (5) preceding stin employed at '
CPSEST (8) Is the individual referenced in (5) preceding still employed at CPSES in the same position in which he was employed at the time of such examination?
(9) What was the individual's job title referenced in (5) preceding at the time of such examination?
(10) If the answer to (8) preceding is no, what is the individual's present title?
(11) If the answer to (2) preceding is no, how can you be sure that see or all of such splices were not and are not defective 7
- c. Is it the s+mndard modus operandi for work being done on the contain-ment vall about 150' above the ground to be done with no scaffolding 7 l
( d. If the procedure referenced in c. above is not currently the practice, was it at the time the work referenced in this I&E Report was donef
- e. If the procedure referenced in c. above was the practice at the time the work referenced in this I&E Report was done but' is no longer the practice, when was such practice changed?
- f. Was the procedure referenced in c. above the practice at the time that similar work was done on the Unit 2 containment vall?
- g. Is it the standard modus cperandi for work being done on the contain-ment vall about 150' above the ground to be done with only site area lighting available7
- h. If the procedure referenced in g. above is not currently the practice, was it at the time the work referenced in this I&E Report was done?
- 1. If the procedure referenced in g. above was the practice at the time the work referenced in this IkE Report was done but is no longer the practice, when was such practice changed?
- 11. (continued):
- j. Was the procedure referenced in g. above the practice at the time that similar work van done on the Unit 2 contaiment vall?
splice setup
- k. Is it the standard modus operandi forport being done on the contain-ment vall about 150' above the ground to be done with the aid of flash-lights?
- 1. If the procedure referenced in k. above is not currently the practice, was it as the time the work referenced in this I&E Report was done?
- a. If the procedure referenced in k. above was the practice at the time the work referenced in this I&E Report was done but is no longer the practice, when was such practice changed?
- n. Was the procedure referenced in k. above the practice at the time that similme work vas done on the Unit 2 containment vall7
- o. Is it the standard modus operandi for work being done on the contain-ment vall about 150' above the ground to be inspected with a penlight?
- p. If the procedure referenced in o. above is not currently the practice, was it at the time the work referenced in this I&E Report was done?
- q. If the procedure referenced in o. above was the practice at the time the work referenced in this I&E Report was done but is no longer the practice, when was such practice changed?
l r. Was the procedure referenced in o. above the practice at the time that similar work was done en the Unit 2 contaiment vallt
- s. What is the current status of the work on the Unit 1 contaiment vall?
- t. What is the current status of the work on the Unit 2 containment vall? ,
- u. If the work on the Unit 1 contaiment vall has been completed, when was such work completed?
- v. If the work on the Unit 2 containment vall has been completed, when was such verk c mpleted?
- 12. Vest are the dates when concrete pours were made on the dome of the Unit 1 I
contaiment?
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Contentien 24 A favorable cost / benefit balance cannot be made teesuso Applicant bas failed to adequately consider:
- a. The costs of safely deccumissioning the facility after its usetul life,
- b. The costs in terms of health, as well as the economic costs of a possible accident in the on-site storage of spent fuel.
- c. The fuel costs and supply.
- d. The costs of vaste storage.
- 13. Applicantd page 8.1-19 of the September 19o0 Amendment to the ER (OLS) states:
"A summary description of tne benefits of tue CPSES project is presented in Table 5.1-21..." Also, Amendment page 8-iv indicates that there are cev tables added, Tables 8.1-21 and 8.1-22; CASE did not receive these two Tables.
Please supply a copy of these two Tables (copies, ratt.er than providing them for copying and inspection) .
- 14. Do you agee that all the costs set forth in CASE's Answer 55, pages ik and 15 of CASE's Supplement to Applicants' First Set of Interrogatories of 12/1/80 should be considered in the cost / benefit balance for Ccmanche Peak?
- 15. If not, which of the costs listed do you believe do not have to be ecosidered in such cost / benefit balance?
- 16. What is the basis (legal, technical, and/or other) for your answer to Questions ik and 15 above?
- 17. What are the criteria which you propose be used to determine whether the cost / benefit balance for CPSES is favorable for licensing CPSES?
- 18. List the criteria referenced in Question 17 above in order of importance in making a cost / benefit balance.
-19. What is your basis (legal, technical, and/or other) for your ansvers to Questions 17 and 18 above?
- 20. What standard do you contend snould be applied to the cost / benefit balance for CPSES to determine whether that balance is favorable for licensing the facility?
- 21. What is your basis (legal, technical, and/or other) for your answer to Question 20 above?
- 22. Is it Applicants' position that you have fulfilled all the requirements of 10 CFR 51.20 in the cost / benefit analysis which you have included in your ER (OLS)?
Contention 2ha (decomunissioning):
- 23. Is all the infomation regarding decanaissioning filed by Applicants contained in the ER (013), Sections 6.2.1 3 and 5.87
- 24. If the answer to Question 23 is no, please list the other sections of the ER (OLS) or other documents where such information is contained.
- 25. a. Do you intend to call any witness in the upcoming hearing with regard to Contention 2ka7
- b. If the answer to Question 25.a. above is yes, supply the following information regarding each such vitness:
(1) Name, address, and telephone meicer of the witness.
(2) Company affiliation and title.
(3) A susssary of the witness's professional and educational background.
(k) Any other infomation bearing on the witness's specific qualifications to testify with respect to Contention 2ha.
(5) The nature of the witness's testimony and a brief summary of such testimony.
(6) List or identify any and all documents which that witness intends to rely on in giving such testimony.
(7) State whether or not such vitness nas conducted any research or made any studies on which such vitness vill rely.
(8) If the answer to (7) above is yes, state briefly the scope and nature of such research or study, and identify any documents which were relied on in its prep e tion.
(9) Provide copies of the witness's testimony.
(10) Provide for inspection and copying any documents referenced in (6), (7) l l
and (S) above.
- 26. Have you prepared any documents (as defined on page 2 of this pleading) with respect to Contention 2ha other than those referenced in 25b(6,7, and 8) l above? l l
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- 27. If the Answer to 26 above is yes, please specify the nature of such document (s) )
and identify any documents on vnich you relied in its preparation.
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- 28. Have you caused to be prepared any documents with respect to Contention 2ka7
- 29. If the answer to 28 above is yes, please identify each suen doctament by subject and author, including tne author's professional and educational background.
- 30. Is it anticipated that the author (s) referenced in 29 above vill be called to testify in the upcoming hearings? -
- 31. Please provide for inspection and . copying all suen doctments referenced in 23 above.
- 32. Please identify all documents relied on in preparation of all documents referenced in 26.above.
- 33. Please provide for inspection and copying all documents referenced in 32 above.
3k. Have you met with or contacted any other person with respect to Contention 24a1
- 35. If sne ausser to Question 3h above is yes, provide the following information:
- a. The dates of any such meetings or contacts.
- b. Specify the persons involved, including name , company affiliation and title.
- c. The purpose of tnose meetings or contacts.
- d. The results or conclusions regarding those meetings or contacts.
- 36. Do you intend to file written testimony in the upcoming hearings with respect to Contention 2ka?
- 37. If the answer to Question 36 above is yes, please supply the following in-formatLon regarding each sponsor's testimony:
- a. Name, address, and telepnone number of tne sponsor.
- b. Company affiliation and title.
- c. A sunnaary of the sponsor's professional and educational background.
- d. Any other information bearing on the sponsor's specific qualifications to testify with respect to Contention 2ka.
37 (continued):
- e. The nature of the sponsor's testimony and a brief suunnary of such testimony.
- f. List or identify any and all documents on which such sponsor intends to rely in giving such testimony.
- g. State whether or not such sponsor has conducted any research or made any studies on which such sponsor vill rely.
- h. If the answer to (g) above is yes, state briefly the scope and nature of such research or study.
- i. If the answer to (g) above is yes, identify any documents which were relied on in the preparation of such research or study.
J. Provide copies of the sponsor's testimony.
- k. Provide for inspection and copying all documents referenced in (f) above.
- 1. Provide for inspection and copying all doctanents referenced in (g) above.
- m. Provide for inspection and copying all documents referenced in -(i) above.
- 38. ht do you think is meant by the term " safely" in Contentico 2ka?
- 39. ht is your basis (legal, technical and/or other) for your response to 387 kO. ht particular structures, facilities and/or equipsent do you believe must be the subject of the decoimaissioning analysis for the cost / benefit i analysis at CPSES?
kl. h t is your basis (legal, technical and/or other) for your response to kO?
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- 42. Do you believe that the timing of performing deccummissioning after the useful l
life of CPSES will affect the cost / benefit analysis?
h3. If the answer to h2 above is yes, please specify how you believe the timing l of deccustissioning would af feet the cost / benefit analysis.
I kh. ht is your basis (legal, technical and/cr other) for your response to 42 and h3 above.
- 45. How do you believe the dollar cost of deccasmissioning should be factored into the cost / benefit analysis?
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k6. What is your basis (legal, tecnnical and/or other) for your response to k57 k7. What was the reason for changing your method of decommissioning? Specify the factors vnich vent into your decision.
- 46. Table 10.1-1, page 5.5-3, Amendment 1, September 1960 of the ER (OIS) is a reproduction of a table from NUREG/CR-Ol30.
Have you done a similar analysis of such costs specifically for CPSES, or are you simply assuming that the costs for CPSES will be the same as shcvn in Table 10.1-17
- 49. If you have done a similar analysis of such costs specifically for CPSES, please provide a copy of that analysis so that we may ccampare it with Table 10.1-1, as or similar to
- 50. If you believe the costs for CPSES will be the samejas shown in Table 10.1 1, provide the following information:
- a. What is your basis for assuming that the following items vill nacunt to the respective percent of total as shor n below:
(1) Spent Fuel Disposal, 7 3% of total (2) Other Building Internals Disposal, 25.6%
(3) Staff I4bor, 26.7%
(k) Electrical Power, 10.h%
(5) Special Equipment, 2.k5 (6) Miscellaneous Supplies, k.6%
(7) Facility Demolition (non-radioactive), 19 0%
(8) Specialty Contractors, 1.25 *
(9) Nuclear Insurance, 2.k5 (10) Environmental Surveillance, 0 5%
- b. What percent of total do you anticipate the following items vill be:
(1) Activated Materials Disposal?
(2) Containment Internals Disposal?
(3) Waste Disposal?
- c. What is your basis (legal, technical and/or other) for assuming the percentages for each of the itans referenced in your answer to b. above?
- d. Are you also assuming a 255 contingency allowance as is indics?,ed in Table 10.1-17
- 51. If you believe the percentages will be different for CPSES from those in Table 10.1-1, as set forth in 50.a. above, provide the percentages which you are assuming regarding each of the items listed in 50.a above.
- ik -
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- 52. In Applicants' ER (OLS)., Amendment 1, September 1950, you state in Section 8.2.1 3 Deccmissioning Cost (page 6.2-3): "Deccmissioning of CPSES is projected to ecxumence in the year 2022. The cost is estimated to be $50 minion (1780 dollars)." But in Section 5.8.1.2 Cost (top of pase 5.8 k) you state: "The cost estimate for deccanaissioning CPSES is $50 million m unit (1980 dollars)." (Emphasis added.)
Since there are two units at CPSES, shouldn't Section 3.2.13 read:
"Deccx::missioning of CPSES is projected to ccanmence in the year 2022. The cost is estimated to be $100 million (1980) ."? *
- 53. If the answer to 52 above is no, why not?
Sk. If the answer to 53 above is yes, vill Applicants amend their ER to reflect this change?
- 55. With fur *her reference to Table 10.1-1, page 5.3-3 of the ER (OLS), please supply the following infor=ation:
- a. The total costs allowed in this Table for Spent Fuel Disposal, Activated Materials Disposal, and Waste Disposal total only $5.894 million. Regard-ing this:
(1) Do these three items constitute all the radioactive materials to be decczanissioned?
(2) If the answer to (1) above is no, what other items should be included in the list of radioactive materials?
(3) If the answer to (1) above is yes, is it the Ccxhpany's position that the total cost for decocimissioning for all radioactive vaste disposal vill be around $6 million (1978 dollars)?
(h) If the answer to (3) above is yes, vaat would this be in 2022 dollars when the decccmissioning for CPSES is expected to begin?
(5) How did you arrive at your answer to (h) above?
- b. For each of the following items, describe br'iefly what these items con-sist of:
(1) Spent Fuel Disposal (2) Activated Materials Disposal (3) Contairmnent Internals Disposal (h) Other Building Internals Disposal (5) Waste Disposal
! (6) Staff I4bor (7) Dectrical Power (8) Special Equipment g ,- s-,
55.b. (continued):
(9) Miscellaneous Supplies (10) Facility Demolition (non-radioactive)
(11)SpecialtyContractors (12) Nuclear Insurance (13) Envirocmental Surveillance (lk) 25% Contingency
- c. The publicatica date of NUREG/CR-0130 was June 1978; regarding this:
(1) Since that time, have any nuclear reactors (of any type whether govertanent-evned, camnercial, or foreign) been deccanmissioned?
(2) If the answer to (1) above is yes, have you secured information regarding the costs of their decommissioning?
(3) If the answer to (2) above is no, why not?
(k) If the answer to (2) above is yes, provide the following informa-tion for each such reactor:
(a) Esme of reactor, location, and owner.
(b) Date of decommissioning.
(c) ht was the ecst estimate for deccanaissioning when the first estimate was made by the reactor's owner?
(d) h t type of reactor was it (PWR, etc.)?
(e) ht size reactor was it (MW)7 (f) What was the actual cost for deccumissionirig?
(g) Briefly st==arize any problems whien tne owner ran into regarding such deccumissioning.
(h) h t type of decommissioning was done (immediate dismantling, etc.)?
(1) Will further steps nave to be taken later to complete deconunissioning?
(j) If the answer to (1) above is yes, what are those steps?
(k) h t is toe owner's estimate of the cost of the other steps referenced in (i) above?
(1) Nn does the owner anticipate the other steps referenced in (i) above vill have to be taken?
(m) Provide for inspection and copying all documents on which you relied in answering (a througb 1) above.
(5) Since that time, have any reactor owners, operators or manufacturers or goverranental agencies or anyone else to your knowledge made any estimates of the costs of decommissioning?
(6) If the answer to (5) above is yes, provide the following information regarding each such estimate, study, report, etc.:
55.c.(6) (continued):
(a) Masse of reactor, location, and owner.
(b) Anticipated date of decommissioning.
(c) ht was the cost estimate for decoussissioning when the first estfm te was made by the reactor's owner?
(d) ht type of reactor was it (WR, etc.)?
(e) h t size reactor was it (MW)?
(f) h t is the current (as of the time of the estimate, study, report, etc.) cost estimate for decamaissicaing?
(g) h t is the date of such estimate, study, report, etc.?
(h) Briefly sumarize any problems which the owner or operator has run into regarding such decosmissioning.
(1) Will further steps have to be taken later to ccarplete deccmaissioning?
(j) If the answer to (i) above is yes, what are those steps?
(k) ht is the owner's estimate of the cost of the other steps referenced in (1) above?
(1) irnen does the owner anticipate the other steps referenced in (1) above vill bave to be taken?
(a) ht type of decommissioning was done (immediate dismantling, etc.)?
(n) Provide for inspection and copying all documents on which you relied in answering (a through.m) above.
(o) If the estimate, study, report, etc. was not for an individual reactor but rather was for decasaissioning of reactors in general, answer as many of the above questions (a through n) as you can.
- 56. In Section 5 8.1.1 of the ER (OLS), Amendment 1, September 1960 (hereinafter referred to as the ER), page 5 8-2, you state "NUREG/CR-0130 divides the dismantlement of the facility into five general areas of effort:
"1. Planning and Preparation.. 2. Decontamination.. 3. Disassembly and f
l Transport. . .k . Demolition. . 5. Site Restoration. . ."
Regarding these areas of effort, supply the following information:
- a. Regarding area 1. Planning and Preparation:
by members of the punlic (1)Haveyouincludedanycontingencycostsforlawsuitsfvbichmay arise as a result of your decanaissioning activities?
l (2) If the answer to (1) above is no, why not?
l (3) If the answer to (1) above is yes, what is the amount estimated for such costs?
(4) h t is your basis (legal, technical, and/or other) for your ansvers to (1, 2, and 3) above?
(5) Have you included any contin 6ency costs for lawsuits or cladas by workers
! which may arise as a result of accidents, overexposure to radiation, 1
- 17
56.a.(5) (continued):
i etc. during deccustissioning? l l
(6) If the answer to (5) preceding is no, why not? ,
I (7) If the answer to (5) preceding is yes, what is the amount estimated for such costs?
(8) ht is your basis (legal, technical, and/or other) for your ansvars to (5, 6, and 7) abovet ,
side effects of (9) Have you included any contingency costs for/possible lawsuits or claims by members of the public or by workers which may arise as
- s. result of your deccanissioning activities of an unanticipated nature, such as having a stop work order imposed by the court while the court considers a lawsuit whien has been filed? Have you given any consideration to such possibilities and tne additional costs which would result?
(10) If the answer to (9) above is no, why cott (11) If the answer to (9) above is yes, what is the amount estimated for such costs?
(12) h t is your basis (legal, technical, and/or other) for your ansvers to (9, lo and 11) abovet
- b. Regarding area 2. Decontamination: -
(1) h t is the effect on the local watershed and ground water from decontamination chemicals which will be used in the decontamination process?
(2) ht is the effect on the fish frca decontamination chemicals which will be used in the decontamination process?
(3) ht safeguards and procedures have you~ planned which would assure that neither decontamination chemicals nor radioactive materials will be released to the air, land, or water during decontamination?
(h) How do you propose to shield your workers frcan exposure to Beta radiation during decontamination?
(5) h t is the currently permissible radiation dose permitted for workers during decontamination?
(6) Has the amount of radicactivity which it is penaissible for workers to receive always been the same as it is currently?
+
So.b. (continued):
(7) Has the amount of radioactivity which it is pemissible for workers to receive been lowered fra vnct it previously vas, so snat now workers can receive less radiation dose than was previously considered acceptable?
(8) Do you celieve that taere is a possibility that the radiation dose which is pe:uissible for workers to receive vill be icvered again, so tnat by the time deccmaissiening of CFSES takes place workers will not be allowed to receive as hign a radiation dose as is now acceptable?
(9) If your answer to (8) above is yes, do you consider this to be a good possibility, an unlikely possibility, or how likely do you consider tais to be?
(10) What spe,cific meesures do you plan to keep workers fra exceeding the permissible radiation dose during decontamination?
(11) If the possibility discussed in (8) above should turn out to be the case, what effect would tais have on the amount of time workers could work before receiving their maximum permissible dose, on the number of verkers required to complete the job, on the difficulty of securin6 vorkers for decontamination activities, and on tne costs of decontamination?
(12) What is your basis (legal, technical and/or other) for your ansvers to the folleving questions under Question 56.b:
(a) Question (1)
(b) Question (2)
(c) Question (3)
(d) Question (h)
(e) Question (5)
(f) Question (6)
(g) Question (7)
(h) Question (8)
(i) Question (9)
(j) Question (10)
(k) Question (11)
- c. Regarding area 3. Disassembly and Tra.2 sport:
(1) What particular equipment and materials do you anticipate vill be "potentially contaminated"?
(2) Are these materials and equipment, in part, some of the equi;unent and systems referenced in area 2. Decontamination, from vnich it
56.c.(2)(continued):
vill be impossible to removed by pnysical or chemical means all the radioactive contaminatient (3) once the equipment and materials have been removed, vnere vill they be transported to?
(4) How will such equipment and materials be transported? -
(5) will special vehicles be required for such transport?
^
'pt):
(6) If the answer to (5) above is yes, explain what special shieldio6, etc. will be required.
(7) What is your basis (legal, technical and/or other) for your ansvers to the following questions under Question 56.e: tvision tation (a) Question (1)
(b) Question (2)
(c) Question (3)
(d) Question (k)
(e) Question (5)
(f) Question (6) g Board (g) Question (7) omis siot Respectfully submitted, 8
OmiS S103 0anh 02 . r l [s.) Juanita Ellis, President ion CASE (Citizens Association for Sound Energy) 1426 S. Polk ormnis S102 Dallas, TX 75224 214/946-94k6 l 214/9k1-1211, work,part-time,usually l Tuesdays and Fridays 12/4/80 ident 1
FOR 1
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