ML20004G109
| ML20004G109 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/26/1981 |
| From: | Goddard R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | PRAIRIE ALLIANCE |
| References | |
| ISSUANCES-OL, NUDOCS 8106290208 | |
| Download: ML20004G109 (12) | |
Text
i 6/26/81 UNITED STATES OF AMERICA
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f40 CLEAR REGULATORY COMMISSI0l1 g
BEFORE TriE ATOMIC SAFETY AND LICENSING BOARD In the Matter of H
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Docket Nos. 50-461 L
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A (Clinton Power Station, Units W
1 and 2) 4 NRC STAFF IliTERR0GATORIES TO INTER)/ENOR PRAIRIE ALLIANCE Pursuant to 10 C.F.R. 92.740(b), the NRC Staff serves the following interrogatories upon the Prairie Alliance, Intervenor, in accordance with the Atonic Safety and Licensing Board's Menorandua and Order of May 29, 1981, admitting the Prairie Alliance as an Intervenor in this proceeding, adaitting certain of its proposed contentions, and ordering a public hearing.
l Instructions and Definitions 1.
Information sought in these interrogatories shall include inforaation within the knowledge, possession, control or access of any agents, employees, independent contractors or consultants of intervenors as well as intervenors themselves.
2.
As used herein, " documents" includes, but is not limited to, papers, photograpris, criteria, recordings, memoranda, books, records, writings, letters, telegraas, or other forms of correspondence, records of meetings or of conversations or of phone calls either in writing or upon mechanical or electronic or electrical recording devices, notes, 8106290'LDI h
exhibits, reports, studies, opinions, surveys, evaluations, formulas, designs, drawings, charts, and all drafts, revisions and differing versions (whether formal or informal) of any of the foregoing, and also all copies of any of the foregoing which differ in any manner (including handwritten nototions or other written or printed matter of any nature) fraa thc original.
3.
Section 2.740(e) of the Commission's Rules of Practice states that a party is under a duty seasonably to supplement his response with respect to questions directly addressed to (1) the identity and location of persons having knowledge of discoverable matters and (2) the identity of each person expected to be called as an expert witness at the hearing, the subject r. utter on which he is expected to testify, and the substance of his testimony; and to seasonably amend a prior response if he obtains information that the response was incorrect when made, or he knows that the response, though correct when made, is no longer true and the circunstances are such that failure to amend the response is in substance a knowing concealment.
Interrogatory 1 Witn respect to each admitted contention set out in the tienorandum and Order of Itay 29, 1981, (a) State the name, business, and residence address of each person expected to be called by Prairie Alliance as an expert witness at the evidentiary hearing;
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(b) Witn respect to each person named in response to Interrogatory 1(a), state the subject natter on which that person is expected to testify; and (c) With respect to each person naaed in response to Interrogatory 1(a), state (1) which contentions will be addressed, (2) the substance of that person's testimony, and (3) what do you expect the testinony. to prove.
(d) Witn respect to each person named in response to Interrogatory 1(a), provide the educational background of the proposed expert after high school (include all courses taken in area of expertise), the work experience of the proposed expert in the area of expertise, and a bibliography of any publications of the proposed expert.
Interrogatory 2 Specifically, as to Contention 1(a)(2), state which "special facilities" present a concern to the Prairie Alliance with respect to emergency response actions.
Identify each of such "special facilities" by name, location, and the nature of the facility.
To the extent that the nuaber or nature of persons, residing at or attending each such facility is significant to your concern, identify the population of such facility with maximum specificity.
Interrogatory 3 Specifically, as to Contention 2:
(a) State t.'c basis for your assertion that Illinois Power Company's quality assurance and quality control program is consistently
deficient in its ability to assure a sufficient number of experienced personnel.
Identify the areas where Illinois Power Company's personnel (or contractor personnel) are lacking in what you assert to be required experience, and provide your source of this information.
(b) State the basis for your assertion that Illinois Power Company's quality assurance and quality control program is consistently deficient in its ability to insure integrity of welding procedures, specifying the particular welding procedures to which you refer.
Identify the source of your information.
(c)
Identify sucn " numerous other quality assurance and quality control functions" in which Illinois Power Company's present quality assurance and quality control program is deficient.
Identify the source of your informdtion regarding such functions.
Interrogatory 4 Specifically, as to Contention 5:
(a) State the basis for your assertion that welds which were found to be defective during construction have not been adequately analyzed or repaired?
(b) State the basis for your belief that there is not sufficient redundancy in the present system design to accommodate an ATWS event.
(c) State the basis for your belief that an ATWS analysis for systems interaction is a necessary safety prerequisite to licensing the Clinton Power Station.
Identify other nuclear facilities at which such an ATWS analysis for systems interaction has been performed.
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Interrogatory 5 Specifically, as to Contention 6:
(a)
Identify the HUREG-0660 actions (1) which Illinois Power Coapany has not implemented, (2) you believe should be implemented, and (3) are not included in NUREG-0737. As to each of these state your basis for identifying thea as regulatory requirements, and provide your definition for the phrase " regulatory requirements."
(b) State your basis for believing that the present instrumentation at CPS inadequately displays and records the reactor pressure vessel water level.
(c) State your basis for believing that the presenc instrumentation at Clinton Power Station is not adequate to detect inadequate core cooling in case of an abnormal occurrence.
- Further, aefine the tenn " abnormal occurrence" as you have used it in Contention 6(b).
(d) Provide the basis fcr your belief that direct indication of safety relief valve position is necessary, as opposed to reliable indirect indication.
Describe in detail the mechanisn(s) by which such direct indication might be provided.
(e) As to Contention 6(e), define the accidents which you are referring to, and state the standards you consider adequate for the nonitoring of accidents.
Further, identify these standards with reference to their source in NRC regulations.
(f) As to Contention 6(h), specify those surveillance and monitoring actions (instruments and/or controls?) which are located in back row panels and which you feel should 'se completely unobstructed and
accessible on a continuous basis.
Explain why such accessibility is necessary for each item so identified.
(g) As to Contention 6(1) and (j), define the phrase "new criteria".
Interrogatory 6 As to Contention 7:
(a) Explain your reason for believing that the seismic response spectrum used for Clinton Power Station does not envelope the two seismic events of September 29, 1891 and September 27, 1909 set forth in your cited references.
(b) 00 you believe that there exists within the site region a known worst case seismic activity other than the two cited earthquakes (if so, identify sucn worst case seisaic activity).
Further, define the phrase "seisnic activity" as you have used it herein.
(c) At the secono special prehearing conference in this proceeding held on April 14, 1931, a representative of Prairie Alliance identifiea tne phrase "the site region", as used in Contention 7(a), as "a 50 mile radius around the site." (Transcript 155).
Does the Prairie Alliance still identify the " site region" as constituting a 50 mile radius from the plant? If so, please relate that site region to the two cited earthquakes.
(d) Provide the HRC Staff with the documents on which the Prairie Alliance is relying with respect to Contention 7(a).
(e) As to Contention 7(b), identify those federal vector pathways which you believe require hardening the containment, provide a i
detailed description of their proximity to Clinton Power Station, and the type and volume of civilian air traffic upon such vector pathways.
(f) State the Lesis for your belief that air traffic in this area is increasirg.
(g) What does Prairie Alliance believe to be the prob' ability of 41rcraft impacting the Clinton Power Station per year of operation?
Identify tne type of aircraf t which you identify as the basis for such probability and provide the calculations by which such probability has bNn computed.
Set forth in detail all relevant assumptions and conclusions supporting this assnaed probability of impact.
Interrogatory 7 As to Contention 8:
(a) Define tne term " sump flow monitoring calculations".
(b) State the basis for your belief that seismic qualification of sump flow nonitoring indication devices is required by General Design Criteria 13.
(c) State the basis for your belief that this instrunentation is needed in the afternath of a seismic event to achieve a cold shutdown condition.
(d)
Explain your theories for believing that accessibility of the transmitters of sump flow monitoring instruments is required by General Design Criteria 14.
(e) State the basis for your belief that accessibility of the transmitters ~ of sump flow monitoring instruments is necessary for operability of these instruments.
(f) Explain why you believe these instruments are not readily accessible for periodic calibration. If it is your belief that periodic calibration during plant shutdowns is insufficient, state the basis for such belief.
Interrogatory 8 As to Contention 9:
(a) Explain why the FSAR consideration of occupational radiation exposure to be expected from either normal or abnormal operation of Clinton Power Station, Units 1 and 2 is inadequate.
(b)
Identify the location you are referring to in Contention 9(a) when using the phrase " airborne radioactivity" and " emissions".
(c) State the basis for your belief that the present number of airborne radioactivity monitors is inadequate. Specify what you feel would be an adequate number of airborne radioactivity monitors, and state the basis for your belief that such additional monitors are required.
Identify such requirement in Nuclear Regulatory Commission regulations.
(d) State what you believe to be an acceptable time response for detection of airborne emissions, and your basis for such belief.
(e) State the basis for your belief that accuracy within 20%
for area radiation monitoring equipment is inadequate.
Identify the degree of accuracy which you believe is adequate and the basis for such belief. Can you identify a supplier of such equipment which would provide greater accuracy than the existing instrumentation? If so, identify the supplier, the equipment, and provide specifications therefor.
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Interrogatory 9 As to Contention 10(a):
(a) In view of the test data that has been provided on the docket for a number of boiling water reactors, state the basis for your assertion that the Clinton Power Station's ZCCS core spray distribution is of unproven operating capability.
(b)
Identify the inaccuracies in models used to predict ECCS performance of the Clinton Power Station which have not been proven accurate or for which operational restrictions could not provide a suitable allowance.
Interrogatory 10 As to Contention 11(b):
(a) Denonstrate the basis for your assertion that the source terms for releases which were used by Illinois Power Company were inadequate by reason of lacking conservatism.
(b)
Identify the conservatisms which you would incorporate into the calculations of atmospheric effluents of routine release.
and state your basis for asserting that such conservatisms must be used by Illinois Power Company.
Interrogatory 11 As to Contention 12:
(a) Indicate the type of preoperational testing program which l
you believe necessary to establish adequacy of design and functiona; capability of the Clinton Power Station's spent fuel transfer system, and state the basis for such belief.
lb) State the basis for your belief that the spent fuel transfer system will result in occupational exposure above ALARA level, and the mechanism by which such exposure (s) will occur.
Document Production Request Please provide the NRC Staff with all documents identified and the answers to Interrogatories 1 through 11 above.
Respectfully submitted, RichardJ.Go$frd _.o/2 A um_-
Counsel for NRC Staff Dated at Bethe.da, Maryland this 26th day of June, 1981.
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UNITED S1ATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ILLIN0IS POWER COMPANY, ~et al.
)
Docket Nos. 50-461 OL
)
50-462 OL (Clinton Power Station, Units
)
1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF INTERROGATORIES TO INTERVENOR PRAIRIE 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, through deposit in the Nuc1 car Regulatory Commission's internal mail system, this 26th day of June, 1981.
Hugh K. Clark, Esq., Chairman P. O.
Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson Atomic Safety and Licensing School of Engineering Board Panel Howard University U.S. Nuclear Regulatory Commission 2300 Sixth Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20059 Atomic Safety and Licansing Dr. Oscar H. Paris Appeal Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Docketing and Service Section Peter V. Fazio, Jr., Esq.
Office of the Secretary Schiff Hardin & Waite U.S. Nuclear Regulatory Ccmmission 7200 Sears Tower Washington, D.C.
20555 2 3 South Wacker Drive Chicago, Illinois 60606 Philip L. Willman, Esq.
Assistant Attorney General i
Prairie Alliance Environmental Control Division P. O. Box 2424 188 West Randolph Street, Suite 2315 Station A Chicago, Illinois 60601 Champaign, Illinois 61820
2-b Jeff Urish, Vice President Bloomington-Normal Prairie Alliance 730 Wilkins-Normal, Illinois 61761 Reed Neuman, Esq.
Assistant Attorney General 500 South Second Street Springfield, Illinois 62701 Gary N. Wright
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Illinois Department of Nuclear Safety 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704 Mr. Herbert H. Livermore RR I Box 229A Clinton,. Illinois 61727
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Richard J. O ard Counsel f NRC Staff 3
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