ML20010B366
| ML20010B366 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/09/1981 |
| From: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8108140409 | |
| Download: ML20010B366 (31) | |
Text
.f RELATED CORRESPONDENCE s
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UNI'IED STA'IES OF PMERICA
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NUCLEAR REGULAT COMMISSION BEFORE THE A'IOMIC AY db, ENSING BO$h 0'f!:c:!!h Secretary gy y
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In the Matter of
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.4 CONSUMERS POWER COMPANY Docket No.
50- 55 8
(Big Rock Point Nuclear
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Power Station) f CHRISTA-MARIA, E7 AL.,
INTERROGA70 RIES TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION STAFF Pursuant to 10 CFR Section 2.740, and in accordance with the ORDER FOLLOWING SPECI AL PREHEARING CONFERENCE dated January 17, 1980, Intervenors Christa-Maria, JoAnn Biers, and James Mills request that these interrogatories be answered fully, in writing, and under oath by any members, employees or representitives of the United Stctes Nuclear Regulatory Commission, Atomic Safety and Licensing Board legal staff who have personal knowledge of the facts or issues in question.
The answer to each interrogatory should contain the name and' identification of each person supplying or contributing to the answer, whether or not he or she has verified the answer.
The answer should also explain the role of each individual in preparing the answer.
For the purposes of these interrogatories, (a)- the term " spent fuel rack" refers to each completed assembly that is or will be installed in the spent fuel pool to hold spent fuel.
An exampl? appears at page 3-3 l
of the Spent Fuel Pack-Description and Safety Analysis l
prepared for this application and dated April 1979.
l (ref erred to as 'the Description and Safety Analysis).
The term includes both existing and proposed spent fuel l
racks unless otherwise specified.
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l (b) the term " component" means one of the parts with which something is menufacured or constructed.
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example, the components'of a spent fuel rack include, but may not be limited to the spent f uel cells or cans, the top and bottom grids, the leveling legs, and the lead-in guides (See pp. 3-3 and 4-4 of the Description and Safety Analysis), as well as rivets, nuts, bolts, plates, insulators, weld wires,.and other parts of'the spent fuel rack.
Similarly, the pool liner constitutes a component of the spent fuel pool, as do any filters, demineralizers, water circulators, and other parts of the spent fuel pool system.
In addition, the term refers to all raw materials from which the component was made.
Each ouestion is to be answered in four parts as follows:
A.
Provide the direct answer to the question.
I B.
Identify and provide all documents and studies, and' the particular parts thereof, relied upon by Licensee as the basis for the answer.
C.
Identify and provide all documents and studies, and the pat icular parts thereof, examined but not relied upon by the Licensee, which pertain to the subject matter in question.
D.
Exp]ain whether the Nuclear Regulatory Commission, the Licensee or any independent contractor is presently engaged in further research or work that may bear on the issues covered in the interrogatory.
If so, please identify the research or work and the persons responsible for it.
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1.
State the amounts of airborne radiation in the atmosphere above the spent fuel pool (but within the containment) due to operation of the spent fuel pool for (1) normal operations and (2) in the event of all credible accidents.
Answer both -(l) and (2) as to the current situation and after the proposed expansion of the spent filel pool, a.
PleLse identify the constiuents of this airborne radiation per foot up to ten feet above the surface of the spent fuel pool.
Please answer for above ten feet.
b.
What amount of airborne radiation originating in the I
spent fuel pool are vented directly into the environment by the continous ventilation system?
I c.
How much airborne radiation can be expected to be vented directly into the atmosphere as a result of all credible accidents involving the spent fuel pool, including those involving inadequate cooling of reactor f.uel and core melt?
Answer both (b) and (c) as to the current situation and after the proposed expansion.
2.
Please explain what ef f ect an accident i nvolving an explosion,. inadequate cooling of the reaccor fuel and core melt would have'on (1) the spent f uel pool and its operation (2) the
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components of the spent fuel pool (3) the system components shared by the reactor and the spent fuel pool and.(4) the fuel stored in the pool.
How would these effects differ before and after the expansion of the spent fuel pool?
3.
Please identify which of the components in Licensee's response to Invervnors Interrogatory number 3-3(a) Set I, including pool valves, strainers, pipeing, circulation pumps, pool filters. :econdary cooling loop, pool walls, and pool liner are net seismically qualified under 10 CFR Part 50.
Which of these components can withstand a seismic event up to and including the safe system shutdown earthquake (SSE) ?
4.
What effect would a design basis and SSE have on (a) each of the compon9nts of the spent fuel pool, (b) the components shared by the reactor and the spent fuel pool and (c) the spent fuel cooling system?
e i
5.
Could a design basis or SSE result in the breach of the i
spent fuel pool?
State the facts on which the answer is based.
l-In the event of a breach l
a.
identify its effects and the measures available to contain the water in the spent fuel pool and containment.
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identify the amount of radiation contained in the water released during a breach.
c.
would water be discharged to the environment?
If so, how and in what amounts.
6.
In the event of a breach, or other credible accident such as a core. melt, explosion or inadequate cooling of core fuel, what steps would be taken to cool the fuel stored in the spent fuel pool?
a.
What is the source of the emergency cooling water?
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b.
How is the emergency cooling water delivered to the pool?
c.
How long does it take to return the. water level in the pool to normal using this procedure?
4 d.
Are there procedures for cooling the spent-fuel during the period before the emergency cooling system is operational?
Answer (a), (b), (c), (e) and (f) with regard to this cooling source.
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e.
Is the emergency cooling system dependent on an onsite or offsite power source?
Specifv the power source by location and type.
f.
What effect would failure of the power source identified in (e) above have on the ability to cool the fuel stored in the spent fuel pool, g.
Is there offsite power available to operate the spent fuel pool and cooling mechanisms in the event of loss of power on site?
How long would it take to revive the cooling system using this power source?
7'.
Is the spent fuel pool above grade?
What effect would an SSF have on the pool walls above grade?
8.
What effect will the increased density of spent fuel have on the ability to cool fuel in the spent fuel pool during an (a).
SSE (b) breach (c) loss of offsite power?
9.
Please identify the level of radioactivity from the spent fuel pool reaching the environment and its pathways during normal operetion of the spent fuel pool.
Please answer for (a) SSE and (b) meltdown.
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10.
What is the status of licensee's activities with regard to SEP Topic III-7D, SEP Topic VI-2, SEP Topic VI-4 and SEP Topic IX-20?
Please summarize the conclusions of each of the abeve.
11.
What is the impact of blasting by the Medusa and Pen-Dixie Cement Companies on the monitoring devices contained (a) within containment (b) within the spent fuel pool and (c) within the control room.
Are these devices examined regularly to determine whether blasting has altered their operation?
4 12.
Please identify the frequency and velocity of sound waves generated by blasting by the Medusa and Penn-Dixie Cement Companies?
a.
What are the effects of such blasting on the geologic formations underlying Big Rock Point?
b.
What effect do these vibrations have on the physical structure of the spent fuel pool and its components?
13.
Please identify the geologic formations underlying and within a one mile radius of Big Rock Point.
Are there any limestone caverns underlying the Big a.
Rock Point site?
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If there are limestone caverns underlying Big Fock l
Point or within a one mile radius,.how are vibrations from blasting by the Medusa and Penn-Dixie Cement Companies transmitted through such caverns?
14.
How much I-29 is released from the spent fuel pool and what percent is this of the total I-29 release from the entire Big Pock facility?
15.
Is there a stainless steel barrier plate on the pool floor to guard against a cask drop?
16.
How many defective fuel elements have been placed in the spent fuel pool?
a.
What is the average number of defective fuel elements expected to be placed in,the pool in the future if the modification is granted.
- 17. Mas the Licensee ever failed to seal containment during (a) an a:cidental release of radiation (b) during other. events?
When?
a.
How many times has containment had to be realed?
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b.
Has containement ever been sealed as a result of a malfunction or failure of the spent fuel pool or any of its comp..nents?
When?
18.
How much Krypton 85 is presently released from the spent fuel pool.
Please answer this question as to the current situation and afte-the proposed expansion.
19.
How did the Licensee analyze its spent fuel cooling system taking into account the proposed increase in fuel storage capacity?
Justify the assumption that Licensee will be able to keep the pool temperature at 140 for the normal case and 170 when only one pool cooling pump and one cooler is used.
20.
Identify by type and number all malfunctions, accidents, abnormal occurances, events and oversights that have occured at Big Rock Point involving (1) the spent fuel pool, (2) back-up generators, (3) cooling systems and (4) isolation components.
How many of such occurances have been reported to the NRC pursuant to 10 CFR 20.4 03, 10 CFR Part 21 or 30 CFR 50.72.
23.
What postulated accidents, which might affect the safety of plant operating personnel in the spent fuel storage building or which might result in the release o) radiation or radioactive A
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a.
Which of the postulated accidents or their effects will be increased in probability, magnitude, or consecuence if the proposed modifications are carried out?
b.
What provisions have been made to protect workers at-t the plant from the effects of such accidents?
c.
What provisions will be taken to protect plant workers from accidents during modification of the fuel racks?
d.
Will any of the workers involved in reracking be temporary employees?
e.
What steps will be taken to ensure that radiation-doses to temporary employees da not combine with previou. exposures to place the employee's exposure level beywod allowable limits?
22.
What is contained in the effluent released from Big Rock Point?
a.
Fow is this effluent monitored?
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b.
What effect will increasing the amount of spent fuel in the spent fuel pool have on the amount of radioactive isotopes in the effluent discharged from Big Rock Point?
c.
How often are inplant effluent samples taken?
d.
Who tests these samples?
e.
Whac isotopes are tested for?
f.
How lorig does it take to test these samples?
g.
How soon after the sample is taken is it tested?
h.
Is there a backlog in testing these samples?
i.
If there is a backlog, how long is it and what effect does it have on the accuracy of testing?
23.
Please answer 22(a) and 22(c) through (i) with respect to environmental samples.
24 Are environmental samples from Big Rock Point routinely analyzed for alpha?
If not, why not?
a.
What is the testing schedule?
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Who conducts the tests?
c.
How long'after the samples taken are the tests.
performed?
d.
Is there a backlog in testing the samples, and if so what effect Caes it have on the accuracy of the test?
e.
On the occasions when environmental samples are tested for alpha, how much has been found?
Has the level of alpha ever exceeded that prescribed'in 10 CFR?
25.
Are there any radioactive isotopes that instruments on site at Big Fock Point cannot or do not measure?
a.
Are these isotopes produced during operation-of the i
reactor or storage of spent fuel at Big Pock Point?
b.
What are the effects of exposure to these isotopes?
c.
Is it common practice-within the nuclear industry to measure these isotopes on site.
26.
Please describe the maintenance procedures for the spent o
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a.
How often is the pool drained?
- b.. How often are the pool components such as tiles, piping systems systems and racks inspected?
c.
How often have such inspections resulted in repairs?
d.
What were the nature of these repairs?
e.
How long did such repairs take to' complete?
f.
Have such repairs ever involved the repair of cracks or breaks in the piping associated with the spent fuel cooling system or the pool liner?
4 g.
How many times during the operation' of Big Rock Point has the col been drained for repair to the pool or its component parts?~
2 '..
Pave spent fuel rods or bundles ever slipped out of.the racks onto the floor of the spent fuel pool?
When?
a.
Fow was this discovered?
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b.
How long had the rod or bundle been on the bottom of the spent fuel pool before discovery?
c.
Was this event recorded by instrumentation in the spent fuel pool?
If not, why not?
d.
What effect did this event have on the spent fuel rod or bundle involved?
Wlat effect did this event have on the pool liner?
e.
f.
How close to the south wall of containment was the rod or bundle located?
g.
What steps have been taken to prevent recurrance of this event?
28.
Hss there ever been an unplanned drainage of the spent fuel pool?
When?
a.
Fow did it happen?
b.
What happened to the water?
Was any of the water discharged directly into the c.
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d.
What effect did such drainage have on the spent fuel pool and the fue] stored therein?
e.
r,vw long did it take to restore the water in the pool to normal.
29.
Is the spent f'.o1 pool at Big Rock Point used to store any material other than spent fuel?
a.
What is this material?
b.
How long has it or will this material be stored in the spent fuel pool?
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c.
What effect does storage of such material have on the spent fuel and the amount and type of radiation released from the pool?
30.
Fow many flights over Big Rock Point or within 5 miles by private, commercial, and military-including air national guard-aircraf t have occurred since 1975 by year and type of aircraft.
a.
What effect would crash of such an aircraft into the-control room at Big Rock Point have on the operation of N'
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the reactor and the speat fuel pool.
b.
In the event of such a crash, does Big Rock Point have a technical support center from which operation of the reactor and spent fuel pool can be monitored and controlled?
c.
Fave private, commercial and military aircraft been rerouted away from the vicinity of Big Rock Point?
If so, how close will these aircraft now fly to Big Rock Point?
-31.
How close is the nearest groundwater to the spent f uel pool?
a.
Does any substance from Big Rock Point se'p into the goundwater?
b.
If there is seepage, identify-the composition of the substance, its quantity and effect on groundwater quality.
c.
Fas the groundwater ever been tested for contamination by the spent fuel pool?
What were the results?
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32.
Does Consumers Power currently, or plan 1 the future to use the Big Pock Foint site for purposes other than a nuclear generating station, such as a hazardous waste s*orage facility?
If so, what will the site be used for?
33.
Does Consumers Power have any plans to construct a rad waste reprocessing bailding within t'.ie compound at Big Rock Point?
a.
What purpose will such a building cerve?
b.
Describe in detail the activities performed in such a building, the radiological hazards associated with such activities and the amounts of radiation released during such activities.
c.
Could irradiated spent fuel hardware, such a old or defective racks, pool tiles or valves be stored in such a building?
d.
Could any other irradiated equipment be stored in this building?
34.
Was containment at Big Rock Foint designed to withstand the effects of tornado loading or the' impact of tornado missiles?
a.
Pave any studies been performed which assess the
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potential effects of such occurances on containment? - If so, what were the results of these studies?
b.
P) ease answer (a) above with regard to the control room at Big Rock Point.
35.
What effect will the increased use of plutonium enriched fuel elements at Big Rock Point and the reduced proximity of same to each other under the revised storage plan have on the safety margin or safety factor of safe storage?
36.
Following reracking of the spent fuel pool, what will be done with the old spent fuel racks?
a.
%here will these racks be stored?
b.
If the old racks are to be stored offsite, describe in detai] the shipping and packing process and all eteps taken to reduce the risk of radioactive exposure to the public and the environment.
i 37.
Has the spent fuel pool at Big Rock Point ever been eveldated as a Source of radioactive material with. the potential to be released during an accident?.
a.
What were the results of this evaluation?
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a b.
In the event ~of such a release, identify the amount of radiation that would be released to the environment and the environmental pathways it would follow.
c.
Does Consumers Power consider this to be a credible event?
If not, why not?
38.
In the event of a core meslt accident, how long would it take to seal containment?
a.
How long after isolating the containment-could reentry of containment occur?
b.
During isolation is emergency cooling equipment accessible?
P is the potential that more " leakers" will be stored 39.
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in the spent fuel pool?
a..
Does stori, 2 " leakers" in the spent fuel pool increase the amount of radiation released from the spent fuel pool?
Please answer by amount and kind of isotope.
~4 0.
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on site standby and emergency diesel generators have failed to operate.
a.
Please state the total amount of. time such generators have been unavailable for emergency service.
b.
During a loss of on site power or a reactor accident would offsite power be available if the standby generators were inoperable?
41.
How many times has Licensee failed to isolate containment because of malfunctions of isolation components?
Please state the reason for such failures and date on which they occurred.
42.
How do " compacting" and "high density racking" differ?
Will expansion of the spent f uel pool at Big Rock Point result: in compaction of the spent fuel stored therein?
i 43.
What types of fuel are stored in the spent fuel. pool?
a.
What kind of interaction takes place between the experimental cladding, U 235 and mixed oxide fuel stored at Big Rock Point?
b.
What are the effects of such interaction on.the radiation levels inside containment?
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What effect do " hot spots" have on mixed oxide fuels stored in the spent fuel pool at Big Fock Point?
44.
Does the feedwater train to Big Rock Point operate on offsite power?
a.
What effect would loss of offsite power have on the feedwater train and the operation of Big Rock Point?
b.
What redundant power and water sources are available in the event of loss of offsite power or failure of the feedwater train?
c.
What is the source of the redundant cooling water?
d.
How is this water delivered to'the spent fuel pool and the reactor?
e.
Can this (these) water source (s) operate independently of the feedwater train?
f.
Is this redundant water. source capable of cooling the fuel stored in the spent fuel pool and the reactor during a core melt or other accident for which isolation of containment is necessary?
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45.
What effect would failure of both heat exchangers and both pumps in the cocling system have on operation of the spent fuel pool and the spent fuel stored therein?
46.
Have there ever been any unplanned releases from Big Rock Point?
If so, identify the number and nature of the release.
47.
Please identify which radiation survey instruments use "G.M.
type probes".
g a.
Please indicate the maximum effect that (a) humidity, (b) temperature, (c) vibrations, and (d) usage, can have on the accuracy of these instruments.and explain-how these instruments are read giving examples of maximum high readings due to the four factors listed above.
b.
How long have radiation survey instruments using-G.M.
type probes been calibrated annually?
c.
Have these radiation instruments ever been used longer than a year without calibration?
If so how long were they used before calibration and when were they used for 3cnger than a year without calibration?
Provide documentation of such calibration.
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Please explain in lay terms how these instruments are calibrated.
e.
Are these instruments currently being calibrated on a quarterly basis?
If so, what prompted the change and when did this more frequent calibration schedule begin?
f.
Which calculations of spent fuel pool radiation are measured by these instruments?
48.
What was done with the leaky fuel bundle mentioned in the November 12, 1963 letter of Travelers Insurance Company to Mr. Haueter?
a.
What effect did this problem have on the spent fuel pool?
b.
Could this happen again in the future?
49.
Please explain what the pocket ionization chambers referred to in the August 29, 1979 letter of American Nuclear Insurers to Mr. Cooper are.
a.
Why do these chambers require drif t checking?
. b.
What is drift checking?
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c.
Is drift checking currently being conducted:on a regular basis?
If rot, why not?
50.
How would the spent fuel pool be maintained safely in the event that a large electrical fire iestroyed (a) the control room and (b) the electrical equipment room?
Is this a-credible event?
If not, why not?
51.
Fow would the spent fuel pool be maintained safely in the event that a fire at the Big Rock plant resulted in a-loss of AC power?
Is this a credible event?
If not, why not?
52.
Has Consumers Power Company complied with all the fire prevention'and protection recommendations made in the Nuclear Mutual Limited Property Loss Prevention Reports of 1973 through 19817 a.
What recommendations concerning fire prevention and protection have not been complied with?
b.
Are the control room and the Big Rock plant generally in' compliance with the. recommendations made in the report?
List all non-compliances.
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52.
What i s the likelihood of a fire destroying or incapacitating in any way (a) the control room, (b) the electrical equipment room, or (c) the computer room?
53.
Please list and explain all problems that Consumers Power Company has had in isolating the containment.
54.
Explain in detail the "further activity" listed in Licensee's response to Intervenors Interrogatory 7-2 Set II.
55.
What i s the probability that containment would be isolated if a bigh radiation signal were given as of August 1, 1981?
Explain the basis for this response.
('.g. wate r level, cooling, etc.)
56.
How would pool safety e
be maintained if containment was sealed due to a severe accident preventing reentry?
57.
Please list all radiation monitors in containment and provide a schedule of how often they are checked for accuracy and calibration.
a.
Please indicate any problems Consumers Power has had with radiation monitors including calibration.
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Fow do the radiation monitors at Big Rock Point differ from those currently being installed at.new nuclear facilities?
i c.
Have any radiation monitors ever been replaced at Big Rock Point?
If so, why?
d.
How old are the radiation monitors used ast Big Rock Point?
i 58.
Based on CAMS and Grab samples, have radiation releases a
from Big Rock Point ever exceeded allowable limits?
If so, when-,
and by how much?
a 59.
To what extent did the accident at ihree Mile Island (TMI) affect the spent fuel pool there?
a.
If there had been an explosion or meltdown at SMI, what would the effect on the spent fuel pool have been?.
b.
What would the effects of such an accident have on a spent fuel pool containing the number of fuel assemblies proposed by Licensee for Big Rock Point?
60.
Consumers Power Company is seeking s building permit for t construction of a rad waste facility on site at Big Rock Point.
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What rules, regulations, or limits on storage specifications presently exist with regard to (a) fire protection, (b) flooding, and (c) monitoring of radiation levels inside and outside such facilities?
61.
Following 7MI, the Nuclear Regulatory Commission (NRC) promulgated certain "backfit" requirements designed to reduce the potential of TMI-type events.
Which of these "backfit" requirements apply to Big Rock Point and the operation of the spent fuel pools?
a.
What changes in the operation, maintenance and construction of the reactor, the-spent fuel pool or their component parts and the reactor control room at Big Pock Point are required in order for Consumers Power Company to comply-with these requirments?
b.
How long will it take to make these changes?
c.
Does a schedule for these modifications exist, and-if so, what is it?
d.
Fxplain in detail what each of the changes applicable to Bic Rock Point are designed to accomplish.
e.
What effect would failure t'o make the required changes have on the potential for a 7MI-type accident
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occuring at Big Rock and the level of radiation released-during such an event?
f.
. Will failure to make such changes increase the possibility of such an event ocurring at Big Rock?
g.
Is Consumers Power exempt from any or all of these changes or modificati3ns?
If so, which ones and why?
h.
What i s the Probabalistic Risk Assessment (PRE)?
i.
When will the review of the PRE be completed?
j.
Has the NRC waived any of the backfit requirements based on the-PRE?
k.
Have the projections in the PRE been approved or substantiated by the NRC?
Explain.
1.
Pas the NBC relied in any way on the PRE in reviewing the Consumers Power Company license amendment to expand the spent fuel pool at Big Rock Point, or in the preparation of any environmental documents on the amendr9nt?
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Respectfully submitted, f
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Herbert Semmel Antioch School of Law 2633 16th Street, N.W.
Washington, D.C.
20009 Counsel for Intervenors Christa-Maria, et al.
Dated August 9, 1981 i
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CERTIFICATE OF SERVICE I hereby certify that copies of Intervenors Interrogatories to the Nuclear Regulatory Commission Staff dated August 9, 1981 in Consumers Power Comany, Big Rock Point Nuclear Power Plant, No. 50-155, were served.on all persons identified in the attached list by depositing copies in the United States mail, first class,
- p. stage prepaid, the 10th day of August, 1981.
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%w Scott Warner e
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Jeesph Calle, Esquire Atenic Safety and Licensing Isha -, Lint oln and Beale Ecard Panel 3
1220 Connecticutt' Ave, N.W.
U.S. Nuclear Regulatory Suite 325 Cor.=i s sion Washington, D.C.
20555 Washington, D.C. 20036 Philip P. Ste;3 toe, Esquire Herbert Grossman, Esq., Chairman Isham, I.incoln and Beale Atomic Safety and Licensing One First National Plaza suite 4200 Board Panel Chicago, Illinois 60503 U.S. Nuclear Regulatory Commission Washington D.C.
20555 Ator.ie Safety and Licens:.:e Appeal Board Panel U.S. Nuclear Regulatcry Dr. Oscar H. Paris Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Docketing and Service Section Commission Office of the Secretary Washington D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Fredrick J. Shon Atomic Safety and Licensing John O'Neill, II Board Panel Route 2, Box 44 U.S. Nuclear Regulatory Maple City, MI 49664 Commission Washington D.C.
20555 Janice E. Moore, E 7 Counsel for NRC Staff U.S. Nuclear Regulatory Cor=.ission Washington, D.C.
20555 John A. Leithauser f
Energy Resources Group General Delivery Levering, MI 43755 2
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