ML20005B482
| ML20005B482 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 07/02/1981 |
| From: | Van Vranken J ILLINOIS, STATE OF |
| To: | GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8107080281 | |
| Download: ML20005B482 (11) | |
Text
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DATED: July 2, 1981.
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UNITED STATES OF AMERICA 0$51 NUCLEAR REGULATORY COMMISSION b
_i BEFORE,THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF
)
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GENERAL ELECTRIC COMPANY
)
Docket No. 70-1308
)
(Renewal of SNM-1265)
(GE Morris Operation Spent
)
Fuel Storage Facility
)
ANSWERS TO GENERAL ELECTRIC COMPANY'S SECOND SET OF INTERROGATORIES 1.
For each witness whom you will or may call as an expert to give opinion testimony in the hearing of this matter regarding any proposed Additional Contention, state the following:
a.
Name and address; b.
Name and address of his employer or the organization with which he is associated in any professional capacity; c.
The field in which he is to be offered as an expert; d.
A summary of his qualifications to testify regarding the specific proposed Additional Contention or g\\q Contentions about which he is expected to testify; C'!1070GO281 810702
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e.
The substance of the facts to which he is expected to testify; f.
The substance of the opinions to which he is expected to testify and a summary of the grounds for each opinion; and g.
State che dates and addresses of all reports rendered by such experts.
Response
Illinois does not plan to call any witnesses as to Contentions 4(e), 9, or 10.
As to Contention 8:
(d) :
(a)
Gregory C. Minor.
See response to General Eluctric Ccmpany's first set of interrogatories, No. 2 and resumes submitted August 25, 1980.
(e)
He is expected to testify to what he observed as to location and access to the control room at the Morris facility during inspections and to his review of the CSAR.
(f)
There is not enough data in the CSAR to ensure the control room will remain habitable in the event of an accident or large release of radioactive material; nor is there sufficient data to conclude that the access routes will remain at low enough exposure rates and contamination levels to permit personnel access during and following an accident. -
The control room at the Morris Operation is located at the 65' level, beneath the unused computer room and immediately adjacent to the filter room.
Ventilation air is drawn from the outside at elevation 85'.
One access route is through the basin area, another route is through stairwells to the Crane Maintenance and Equipment area.
The filters in the filter room could become contaminated in the event of a release or accident.
The air intake could draw in radioactively contaminated air in the event of a release or sccident, and the access route through the pool or basin area could be inaccessible in an accident condition.
Other access routes are not discernible in the data supplied with the CSAR.
2.
For each person retained or specifically employed as an expert with regard to any proposed Additional Contention, about whom no decision has been made as to whether such expert l
will be called to testify, state the following:
(
l a.
Name and address; j
b.
His particular field of expertise; c.
A summary of his qualifications as an expert regarding the specific proposed Additional Contention or Contentions concerning which he has been retained or specifically employed; and d.
Whether such an expert has submitted or transmitted any reports analyses, or opinions in any form.
If so, l
state the dates and addresses of all reports, analyses or opinions.
l
Response
None.
i l
l 3.
For each Additional Contention proposed by Illinois and admitted by the Board, state with particularity the factual basis for each such contention, including all facts and technical information or data relied upon in formulating such contention.
Response
(a)
Contention 4 (e) :
This is based on the fact that on its face the CSAR does not consider cost of complete removal of all radioactive materials nor of complete restoration of the site for unrestricted use.
(b)
Contention 8:
See answer to Interrogatory 1(f),
supra.
(c)
Contention 9:
This is based on the fact that General Electric Company's operator training and certification program on its face establishes no minimum academic requirements j
l l
nor any standards for passage or failure of tests.
(d)
Contention 10:
This is based on the fact that General Electric Company's Technical Specifications neither precludes receipt, handling or storage of damaged spent fuel nor.
addresses how damaged spent fuel would be received, handled or stored in accordance with 10 C.F.R. Part 72.
4.
With regard to proposed Additional Contention 1, state the regulatory basis for the allegation that General Electric's projected costs should take into account the costs of complete removal of all radioac-ive materials and the costs of complete restoration of the facility to unrestricted use.
Response
10 C.F.R. SS 72.14 (e) (3) and 72.18.
S.
With regard to proposed Additional Contention 1, state with particularity the basis for the allegation that the CSAE does not provide necessary financial arrangements to provide reasonable assurance that decontamination and decommissioning will be carried out.
Response
Nowhere in the CSAR does General Electric Company address the decommissioning ccsts of complete removal of all radioactive materials nor of complete. restoration of the facility to unrestricted use.
6.
With regard to proposed Additional Contention 2, state with particularity the basis for the assumption that "trans-portation, receipt, handling or storage of spent fule which has been -
_ _ _______ A
k damaged at another fe.cility" is a "significant external man-induced event (as used in 10 C.F.R.,
Part 72] affecting the (Morris] facility's design."
Response
Deleted by General Electric Company.
7.
With regard to proposed Additional Contention 3, state the regulatory basis for the allegation that access to and from the control room is required during off-normal or accident conditions.
Response
10 C.F.R.
S 72.72(j).
8.
With regard to propcsed Additional Contention 3, state with particularity the postulated circumstances under which there could be a release of radiation in excess of the dose limitations established by 10 C.F.R., Part 20, and state the specific dose limitations that would be exceeded.
Response
See answer to Interrogatory 1(f), supra.
9.
With regard to proposed Contention 4, state the regulatory basis for the alleged requirement that General Electric's operation training and certification progrtm must contain:
a.
A minimum academic standard; or b.
A numberical standard for passage or failure of testing and verification requirements.
i
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Response
10 C.F.R. Part 72, Subpart I.
10.
With regard to proposed Additional Contention 4, state with particularity _and in factual detail the basis for the allegation that the criteria established for testing and verification, as contained in General Electric's operator training and certification program, are inadequate.
Response
It is inadequate in that it does not provide minimum academic standards nor any standar? for passage or failure of test requirements.
11.
With regard to proposed Additional contention 5, state the regulatory basis for the assumption that an ISFSI cannot receive, handle or store damaged spent fuel, Retponse:
The contention is not based on an assumption that an ISFSI cannot receive, handle or store damaged spent fuel.
12.
With regard to proposed Contention 5, state with particularity and deficiency, of which Illinois is aware, in General Electric's provisions for receipt of spent fuel.
Response
Illinois objects to this interrogatory as being beyond the scope of discovery in that Contention 10 is not directed
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1 toward General Electric Company's receipt of undamaged spent fuel.
As to damaged spent fuel General Electric Company has not identified or described any provisions for such receipt.
Respectfully Submitted, TYRONE C.
FAHNER Attorney General State of Illinois.
i~
BY:
/*'
i
{QHN VAN VRANKEN Assistant Attorney General Environmental Control Division 188 W.
Randolph Street - Suite 2315 Chicago, Illinois 60601 (312) 793-2491 i
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( -.. -- -.-
UNITED STATES O F AME RI C A NUCLE AR REGULATORY COMMISSION BEFORE THE ATOMIC S AFETY AND LICENSING BOARD In The Matter Of
)
c et N 0-1308 GENERAL ELECTRIC COMPANY
)
(Spent Fuel Pool)
(GE Morris Operation Spen! )
Fuel Storage Facility)
)
AFFIDAVIT OF GRE GORY C.
MINOR STATE OF CALIFORNIA
)
)
ss.
COUNTY OF S ANTA CLARA )
GREGO RY C.
MINOR deposes and says under oath as follows:
I, the undersigned, have assisted ia preparing and review-ing respouses to interrogatories on Morris Operation Con ten tions.
To the best of my knowledge, the responses are true and correct.
14/91rg/
[G GO RY C.
MINOR Subscribed and sworn to before me this
.797[
day of May, 1981.
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JEAN H. JONES NOTARY PUBLIC-CALIF 1RN!A o
SANTA CLARA COUNTY c'/ '
N OTARY lUB LI C My Commsen E ;*a lever.ar a t.64 My Commission Expires: //- 9 M48 J
PROOF OF SERVICE I hereby certify that on this 2nd day of July, 1981, I served copies of the foregoing Answers to General Electric Company's Second Set of Interrogatories, upon each of the persons named on the attached Service List, by causing copies to be deposited in the U.S. Mail, in envelopes properly addressed and sealed, first class postage prepaid.
M KOHN VAN VRANKEN P
SE2VICE LIST Andrew C. Goodhope, Esq.
Everett Jay Quigley Chairman R.R.
1 Box 378 3320 Estelle Terrace Kankakee, Illinois 60901 Wheaton, Md. 20906 Mrs. Elaine Walsh (Patrick)
Dr. Linda W. Little 33 Pheasant Trail 5000 Hermitage Drive Wilmington, Illinois 60481 Raleigh, NC 27612 Ronald Szwajkowski, Esq.
Dr. Forrest J. Remick Mayer, Brown & Platt 305 E. Hamilton Avenue 231 South LaSalle Street State College, PA.
16801 Chicago, Illinois 60604 Bridget Little Rorem Essex, Illinois 60935 Edward Firestone, Esq.
Legal Operation General Electric Company 175 Curtner Ave., Mail Code 822 San Jose, California 95125 Atomic Safety & Licensing' Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Cormission Washington, D.C.
20555 Marjorie Ulman Rothschild Office of the Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 A
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