ML20023B753

Responses to 830418 Interrogatories & Requests to Produce Re Des Contentions 11,17 & 19.Related Correspondence

ML20023B753
Person / Time
Site:	Catawba
Issue date:	05/02/1983
From:	Guild R, Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP, GUILD, R., PALMETTO ALLIANCE, RILEY, J.L.
To:	DUKE POWER CO.
References
NUDOCS 8305060252
Download: ML20023B753 (21)

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UNITED STATES OF AMER NUCLEAR REGULATORY COMf} ON 9 BEFORE THE ATOMIC SAFETY ANDf CEN $[G D g d o.4t e  ;

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A ys; In the Matter of ) '

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DUKE POUER COMPANY, _e_t al. ) -414

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(Catauba fauclear Station, ) May 2, 1983 Units 1 and 2) )

PALMETTO ALLIANCE AND CAROLINA ENVIRONMEf4TAL STUDY GROUP RESPONSES TO APPLICANT'S INTERROGATORIES AND REQUESTS TO PRODUCE REGARDING DES CONTENTIONS 11, 17 AND 19 Palmetto Alliance and Carolina Environment 61 Study Group hereby respond to " Applicant's Interrogatcries and Requests to Produce to Carolina Environmental Study Group and Palmetto Alliance Regarding Palmetto Alliances and Carolina Environmental Study Groups DES Contentions 11, 17 and 19," dated April 18, 1983.

REQUESTS FOR DOCUMENTS Palmetto Alliance and Carolina Environmental Study Group will make available for inspection ano copying, at a time and location to be agreed upon, documents identified in response to interrogatories belou.

8305060252 830502

{DRADOCK 05000413 PDR H

INTERROGATORIES A. General Interroaatories

1. State the full name, address, occupation and employer of each person answering the interogatories and designate the interrogatory or the part thereof he or she ansuered.

The Answers to the following Interrogatories are provided by counsel for Palmetto Alliance, Robert Guild, and spokesman for CESG, Jesse L. Riley.

2. Identify each and every person you are considering calling as a uitness at the hearing in this matter on this contention, and with respect to each such person:

a. State the substance of the facts and opinions to which the witness is expected to testify;

b. Give a summary of the grounds for each opinion, end

c. Describe the uitness's educational and professional background.

As yet no witnesses have been identified with regard to these contentions.

3. Is thE Contention based on one or more calculations?

If so;

a. Describe each calculation and identify any documents setting forth such calculations,

b. Indicate uho performed each calculation.

c. Indicate when each calculation was performed,

d. Describe each parameter used in such calculation and each value assigned to the parameter, and desciibe the source of your data,

e. Indicate the results of each calculation.

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f. Explain in detail how each calculation provides a basis for the issue.

Any calculations underlying these contentions have been made by Applicant's or NRC Staff and are identified in the pertinent parts of Applicant's and NRC Staff documents.

4 Is the contention based upon conversations, consultations, correspondence or any other type of communications with one or more individuals? If so:

a. Identify by name and aodress each such individual.

b. State the sducational and professional background of each such individual, including occupation and institutional affiliations,

c. Describe the nature of each communication uith such individual, when it occurred, and identify all other individuals involved.

d. Describe the information recieved from such individuals and explain how it provices a basis for the issue,

e. Identify each letter, memorandum, tape, note or other record related to each conversation, consultation, correspondence, or other communication with such individual.

Applicants Environmental Reports, Preliminary and Final Safety Analysis Reports; NRC Staff's Draft and Final Environmental Statements and Safety Evaluation Reports for the Catauba Nuclear Station.

B. Specific Interroaatories Relatino to CESG/ Palmetto Alliance DES Contention 11 As admitted by the Board, and revised, by Order of March 24, 1983, DES Contention 11 reads:

A substantial part of the population placed at risk by nuclear operations at and relating to Catauba are also placed at risk by similar operations at McGuire. A realistic assessement of Catauba impacts will take into consideration McGuire risks.

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1. What is the basis for your statement that "[a substantial part of the popoulation placed at risk by nuclear operations at and relating to Catawba are also placed at risk by similar operations at McGuire," and, therefore, that "[a] realistic assessment of Catauba impacts will take into consideration McGuire risks"7 Explain your anster fully.

Many persons are within a thiry-mile radius of both plants including the residents of the City of Charlotte, N.C.

2. What do you mean by "a substantial part of the population" as that term is used in this contention?

Several hundreds of thousands of persons living between the two plants.

3. What do you mean by "placed at risk" as that term is used in this contention?

Potentially exposed to the dangerous effects of radiation.

4 Is the phrase "placed at risk" meant to refer only to the risk of severe accidents or does it refer to the risk of both design basis and severe accidents?

Severe accidents.

6. Please explain what are in your opinion the geographical boundaries of the popoulation allegedly "placed at risk" by the operation of McGuire and by the operation of Catawba.

Please see ansuer to Interrogatory 1, above.

7. What do you mean by " nuclear operations at ano l

relating to Catauba" as that term is used in this

! contention?

Nuclear operations at the facility uhich make severe accidents possible.

B. What do you mean by "similar operations at McGuire" as that temr is used in this contention?

The nuclear operations at McGuire which make severe 4

accidents possible.

9. Uhat do you mean by "Catauba impacts" as that term is used in this contention?

The term impact is intended to reflect the range of effects of the licensing action under consideration here and required to be analyzed and evaluated by the NRC under provisions of the National Environmental Policy Act of 1969 (NEPA), 83 Stat.

852, Council on Environmental Quality (CEQ)

Guidelines, 38 FR 20550 and 10 CFR Part 51.

(a) Does this term include both the environmental and health effects projected to be associated with the operation of the Catauba nuclear station? Explain your answer uhether your response is affirmative or negative.

Yes. The term is understood to include all adverse effects of the proposed licensing action.

10. Uhat do you mean by the term "McGuire risks" as that term is used in this contention?

See answers to Interrogatories 7, 8, and 9, above.

Intervenors are particularly concerned about the effects of a severe accident at McGuire.

11. Uhat are your bases for your responses to interrogatories 1 through 10? Identify any documents, calculations, testimony or oral statements and any legal requirements or guidelines on which you rely.

See answer to General Interrogatories, above.

Simple observation and reasoning, particularly for one living among the population placed at risk by both McGuire and Catauba, provides obvious bases for these ansuers.

12. What do you mean by " realistic assessment" as that term is used in this contention?

One that encompasses the full range of possibilies.

13. (a) Is the term " realistic assessment" intended to be synonymous with an adequate NEPA analysis?

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Yes.

(b) Do you contend that the DES does not

" realistically" assesses the environmental impacts of operating the Catawba Nuclear Station? Explain your answer.

Yes. The DES does not recognize the risk imposed by McGuire.

14 Do you contend that the DES /FES's assessment of

" Catawba impacts" (i.e., the environmental impact of the Catauba Nuclear Station) completely fails to take into consideration the possible effect of "McGuire risks"? Explain your answer.

No. The FES does note and respond to this comment (DES Contention 11) by PA and CESG, albeit inadequately.

15. If your response to the preceding interragatory is negative do you contend that the DES /FES's assessment of "Catauba impacts" fails to place sufficient emphasis upon projected "McGuire risks"?

Explain your answer.

Yes. Ue do not accept the staff's faulty risk numbers nor the vind sectors assumed.

16. If your answer to interrogatories 13 and 14 is negative, do you contend that the DES /FES's assessment of the environnental impacts estimated to be associated with the operation of Catawba is otheruise inadequate or incorrect? Explain your answer.

No. See answer to Interrogatory 1S, above.

17. If your answer to any of the three preceding interrogatories is affirmative, please identify (making reference to particular calculations or data) those aspects of the "McGuire risk" which in your opinion should have been considered in the Catawba DES /FES, and explain the type of consideration which these elements should receive in a proper calculation of the risk of operating Catawba.

Calculation made uas superficial, does not consider weather conditions, population distribution, etc.

18. Do you contend that the URC Staff is required by an 6

regulation, regulatory guide, plicy statement, or other authority to consider "McGuire risks" in assassing the environmental impact projected to be associated with the operation of Catawba? If so, identify all such rquirements.

Yes. See NEPA authority referred to in answer to Interrogatory 9, above.

19. Do you contend that UEPA requires some recognition of potential environmental risks posed bf other nuclear facilities in the area in assessing the environmental " costs" of Catauba? Explain your answer.

Yes. CEO Guidelines and other NEPA authority make clear that the NRC must consider the interdependent, cumulative, direct and indirect effects of the narrou action under consideration.

20. What are our bases for your responses to interrogatories 12 through 197 Identify an documents, calcultions, testimony or oral statements and any legal requirements or guidelines on which you rely.

Please see response to General Interrogatory, above.

Bases are also self-evident in response to individual interrogatories.

21 Do you contend that the accident probabilities and projected dose releases listed in Table S.10 of the DES /FES are incorrect because they do not take into account the possible incremental risks posed by the concurrent operatien of the McGuire and Catauba plants? Explain your ansver.

Yes. These risks were not taken into consideration for McGuire.

22. (a) If your ansuer to the preceding interrogatory is affirmative, please specify the statistical values which the Catauba DES /FES should reflect for incremental accident risks which result from the operation of McGuire. What is the basis for your ansuer?

It is the NRC Staff's responsibility to fully analyze and evaluate these effects; intervenors can only identify the inadequacy of the present treatment.

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(b) What offect do you contend the " incremental risk" from McGuire should have upon the accident probabilities and projected radiation doses in the Catawba DES /FES? In other words, specify the extent to which these probabilities and projected doses should be increased in order to accurately reflect the risk of concurrent operation of McGuire and Catauba. Uhat is the basis for your answer?

The risk should be doubled from the concurrent operation of two similar facilities with similar maximum impact, independent of probability.

23. Do you contend that proper consideration of "McGuire risks" in assessing the ffects of operating the Catawba plant would effect the DES's conclusion that "the risk of incurring any adverse health effects as a consequence of (design-basis or severe accidents] is exceedingly small"? (DES /FES, p. 5-35). Explain the basis for your answer, making reference to any documents, as well as calculations you have to support your ansuer.

Yes. Ue reject the staff's definition of risk as probability x consequences.

24 Do you contend that a " realistic assesiment of Catawba impacts" entailing consideration of any incremental risks posed by the operation of McGuire would reveal such substantial risks (i.e., " costs")

to public health and safety that the DEB /FES's overall cost-benefit conclusion would be affected?

Explain your answer.

Yes. Houever, Palmetto Alliance and CE5G believe that a " realistic assessment" of the impact cf Catauba operation alone would reflect a negative ecst- benefit conclusion. NRC Staff's analysis so minimizes the costs of its licensing actions that intervenors are unable to identify any singular cost uhich would "tip the balance."

25. If your answer to the preceding interrogatory is affirmative, do you contend that the additional environmental " cost" (i.e., risk) created by the con-current operations of the McGuire and Catawba plants is sufficient to tip the cost-benefit balance against operation of Catauba? please explain and provide the basis for your answer.

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Pleast see response to Interrogatory 24, above.

26. If you contend that the operation of the McGuire plant imposes an additional environmental cost upon the operation of the Catauba plant, do you agree that the concurrent operation of these tuo plants also creates an increased environmental benefit?

No. No benefit from the operation of either facility is identified or perceived.

27. In an Octobr 18, 19?2, letter to the Board in this proceeding, the NRC Staff indicated in response to a Board question that the " risk of severe accidents occurring at McGuire is not consioered in the Catauba Environmental Impact Statement as a matter of policy," adding that:

The analysis of severe accidents performed for purposes of the EIC is directed only to the incremental costs of beyond design bcris accidents for the proposed action, in this case the licensing of Catauba. This comports with the Commission's Statement of Interim policy, 45 Fed.

Reg. 40101 (June 13, 1986) (the EIS should contain ' reasoned consideration of the environmental rinks (impacts) attributable to accidents at the particular facility or facilities within the scope of each such statement"), and 10 CFR Section S1.23(c) (the DES

'uill include a preliminary cost-benefit analysis which considers and balances the environmental and other effects of the facility . . .').

(a) Do you agree eith this statement by the NRC Staff? Explain your ansuer.

No. As explained above, intervenors believe that all significant costs associated uith this licensing action are required to be considered under NEPA policy.

(b) Uhat is the bais for your ansuer?

See response to Interrogatory 9, above.

28. Uhat are your bases for your responses to interrogatories 21 through 27? Identify any occuments, testimony or oral statements, and any legal requirements or guidelines on which you rely.

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9 Please see response to General Interrogatory, above, for bases. The bases for the ansuer to each interrogatory are self-evident, f C. Specific Interrogatories Relatino tc1 CESG/ Palmetto Alliance

DES Contention lj!

"As revised and admitted in the Oroer of February 25, l 1983, DES Contention 19 readr.:

Failure to evaluate the environmental costs of operation of Catawba as a storage facility for  ;

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spent fuel from other Duke facilities compromises the validity of the favorable cost-benefit balance struck at the construction permit phase of this

' proceeding. Since the CP stage hearing, Duke Power has considerably expanded the Catawba spent fuel pool capacity and provided for denser storage of irraciated fuel. FS AR Table 1.2.3-1. Applicants intend to use Catawba for storage of irradiated fuel from the McGuire and Oconee nuclear facilities of Duke Power Company. FSAR 9.1.2.4; OL Application, pp. 11 -12.

1. What is the basis for your assertion that the des /FES fails "to evaluate the environmental costs of operation of Catawba as a storage facility for spent fuel from other Duke facilties"? Explain your answer.

DES p. 5-19 contains only a single paragraph treatment of the entire impact of spent-fuel storage asserting without any detailed support that routine releases of radiation from Oconee and McGuire fuels have been considered; but asserting that "a:pects of handling spent fuel from Oconee and McGuire within

' the fuel handling facility at Catawba will be discussed in the Safety Evaluation Report for Catawba." The FES at pages 9-12 and 9-13 purports to respond to Palmetto Alliance and CESG comments on the DES but adds nothing to the earlier deficient evaluation of these effects. The FES at page 5-19 1 purports to treat cask handling impacts but does so in an entirely deficient manner: "No site specific evaluation was made of the probability of a cask-drop accident at Catawba." This cursory treatment l

ignores entirely the impacts of the doubling of the fuel pool capacity and resultant increased heat load and radiation inventory from Oconee and McGuire  ;

scent fuels; loss of fuel pool cooling due to loss of on-site or off-site power; cask drop damage and 10 i

possible criticality incidents from crushed fuel assemblies; accidents involving mishandling of casks including inadvertent unshielded removal of cask lids; and external threats such as air craft crashes all presenting substantially greater risks than were evaluated at the construction permit stage attributable solely to the implementation of Applicant's " cascade plan."

2. (a) Do you contend that tiie DES and the FES fail to evaluate the possible environmental effects associated with the storage of Catauba spent fuel at Catauba? Explain your answer.

No.

(b) Do you contend that the DES and FES fail to evaluate any incremental environmental effects uhich may result from the storage of spent fuel from Dconee end McGuire at Catauba? Explain your answer.

Yes. Please see response to Interrogatory 1, above.

3. Uhat do you mean by " failure to evaluate" as that phrase is Ueed in this contention?

Failure to perform the analysis and evaluation of impacts as required by NEPA and implementing regulations.

4. Do you contend that the DES and the FES entirely fail to " evaluate the environmental costs of operation of Catauba as a storage facility for spent fuel from other Duke facilities? Explain your ansver.

No. However, an inadequate evaluation is as deficient as one which "entirtly" fails to evaluate an environment cost.

negative, do you contend that the DES and the FES have not given sufficient emphasis, or have otherwise not properly considered, the possible environmental costs associated with the storage of spent fuel from other Duke nuclear facilities at Catauba? Explain your answer.

Yes. Please see response to Interrogatory 1 above.

6. If your answer to the preceding interrogatory was 11

affirmative please explain why you believe that the possible environmental costs associated with the storage of spent fuel from other Duke facilities at Catawba have not been properly evaluated (i.e,, why the DES and the FES's present treatment of this issue 3 is inadequate or improper).

Please see response to Interrogatory 1 above.

7. What do you mean by the phrase " environmental costs of operation of Catauba as a storage facility"?

Explain your answer.

Costs are uncerstood to represent the effects required to be considered under NEPA as described in response to Interrogatory 1, above.

8. Specify those environmental costs associated with the storage of Dconee and McGuire spent fuel at Catawba which you contend should be considered in the DES /FES.

Palmetto and CESG are principally concerned with the health effects from large accidental releases of radiation and the economic costs.to society caused by such accidents.

9. Indicate which of the environmental costs discussed in the preceding interrogatory have not been considered in the DES /FES (or have not been considered properly).

None of these costs have been adequately treated.

10. Explain why those environmental costs discusseo in the preceding interrogatory (i.e., those costs not considered in the DES /FES which you contend should have been considered) are signficant.

Palmetto and CESG believe that the costs associated with the incremental risk from use of Catauba as an Away From Reactor storage facility in cascade from Duke's other nuclear plants is significant in the manner described in response to Interrogatory 1, above.

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11. Explain uhat you believe are the consequences of not considering those environmental costs which you contend have not been taken into account (or have not been considered adequately).

Failure to account for these costs compromises the validity of the cost benefit analysis performed and particularly fails to identify and evaluate alternative actions with lesser impact or mitigating measures.

12. Do you intend that the " environmental costs" of storing spent fuel at Catauba be read to include severe accidents? Explain your answer.

Yes. Please see the response to Interrogatory 1, above.

13. Do you contend that a severe accident in the Catauba spent fuel pool is credible? If so, specify in detail the severe accident (s) you consider credible.

Yes. Please see the response to Interrogatory 1, above.

14. Uhat is your definition of " credible"?

Plausible.

15. Have you performed any analyses which demonstrate the credibility of the severe accident (s) referenced in response to Interrogatory 137 If so, provide such analyses or other supporting documentation.

No.

16. Do you contend that the NRC Staff is required by any regulation, regulatory guide, policy statement, or l

other authority to consider "the environmental costs of operation of Catauba as a storage facility for spent fuel frcm other Duke facilities"? If so, identify all such requirements.

Yes. NEPA and implementing regulations require consideration of all significant costs of the proposed action.

17. Uhat do you mean by the phrase " compromises the

! validity" of the CP-cost-benefit analysis?

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Invalidates the favorable NEPA analysis.

18. Do you contend that a proper evaluation of the possible environmental costs asscciated with the storage of spent fuel from other Duke facilities at Catawba would reveal risks to public health and safety so substantial that the DES /FES's overall cost-benefit conclusion would be altered? Explain your answer.

Yes. Please see the response to Interrogatory 1, above.

19. The FES states at p. 5-19 that:

[t]he environmental analysis in Section 5.9 and Appencix D takes into account impacts from exposures to routine releases resulting from spent fueld from Catawba and the spent fuel at Oconee and McGuire that may be stored at Catawba.

In addition, section 5.9.2.12 of the FES discusses at p. 5-19 the effects of handling spent fuel from Oconee and McGuire within the fuel-handling facility at Catawba. Do you contend that the FES has failed to consider adequately the environmental costs of storing Oconee and McGuire spent fuel at Catawba?

Explain your ansuer.

Yes. Please see the response to Interrogatory 1, above.

20. What are the bases for your responses to interrogatories 1 through 197 Identify all documents, calculations, testimony or oral statements, and all legal requirements or guidelines on which you rely.

Please see the response to General Interrogatories, above for bases and the answers to specific interrogatories above.

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D. Specific Interrogatories Relating to CESG/ Palmetto Alliance DES Contention 1]f

1. What is your basis for the statement that the DES /FES averages meteorological conditions in its consideration of accidents?

An explicit statement at DES page 5-35, line 2, and see quoted in Interrogatory 13 belou.

2. Please explain fully why you feel that such averaging is improper or incorrect. Wat is the basis for your statements?

To adequately assess risk one should know and evaluate the worst case. Here extreme weather conditions differ significantly from the average.

In our vieu we understand risk to represent possible consquences, and an accurate assessment shoulo evaluate the extreme and not just the average.

3. Please identify, making reference to particular calculationr and/or data, the factors uhich were considered in the DES /FES and which, in your opinion render the DES /FES inadequate.

Please see Environmental Report Table 2.3.0-2, -3.

Intervenor has also compiled a graphical representation of the data on this table.

4. Uhat do you mean by " atmospheric inversions" as that term is used in the first paragraph of this contention? Specify the percise meteorological characteristics associated with this phenomenon.

In inversions the positive vertical temperature gradient is the reverse of the usual.

l S. What do you mean by " quiet air" as that term is used l

in the first paragraph of this contention? Specify I the precise meteorological characteristics associated with this phenomenon.

Associated with stagnation. Air moving at lou l

velocity as reported at Pasquill G.

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6. Is the term " atmospheric inversion" synonymous with "the extreme condition of inversion"? Is " quiet air l synonynous with "very slow air movement"7 If not, explain how these various atmospheric conditions differ.

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No. Yes. "And" is the operative word as used in this contention.

7. Are the terms " extreme weather" and " extreme, but frequently encountered, weather conditions" as used in the second paragraph of this contention meant to refer to meteorological conditions different from those mentioned in Interrogatories 4 and 57 If so, explain how the various types of atmospheric conditions differ.

No.

8. Do the terms discussed in interrogatories 4-7, above, ccrrelate to established descriptions or types of atmospheric conditions, i.e., "Pasquill type G"? if so, indicate such classification and explain why these atmospheric conditions fit the classifications.

Yes. Pasquill G. The vertical temperature gradient is positive.

9. Is the term

" a very common feature" meant to be synonymous with the term " frequently encountered"?

If not, please distinguish the frequency of odcurrence represented by each of these 2 terms.

Please provide all supporting meteorological data (or other information) upon which you rely.

Yes. See ER Table 2.3.0-2, -3, just as above.

10. What is your basis for stating that atmospheric inversions and quiet air "are a very common feature"?

Direct personal observations of a resident of this area.

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11. Explain fully the applicable geographical boundaries associated with the terms "in this f

' region."

Piedmont.

12. Uhat are your bases for your responses to Interrogatories 1 through 117 Identify any documents, calculations, testimony or oral i

statements and any legal requirementc or cuidelines on uhich you rely in your responses.

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ER material; DES 4.3.3 and 5.14 and 5.13; direct observation; and, plots by Jess Riley of data from ER Table and comparable data for McGuire.

13. The estimated radiological consequences of design-basis accidents set forth in Table 5.9 of the DES /FES are based upon " meteorological dispersion conditions that are an average value determined by actual site measurements." (FES, p. 5-35). Do you contend that the " environmental assumptions" used to calculate these radiation doses entirely fail to take into account the possible effects of " inversion and very slow air movement"? If so, please explain.

No. But average values do not adequately represent the extreme.

14 If your response to the preceding interrogatory is negative, do you contend that the " environmental assumptions" used in the DES /FES fail to place sufficient emphasis upon the possible effects of

" inversion ano very slou air movement"? If not, please explain.

Yes.

15. If your answer to the preceding interrogatory is affirmative, explain uhy you believe that the effects of " inversion and very slow air movement" upon design-basis accident radiation doses have not been properly considered, and why the DES /FES's present treatment of these meteorolcgical factors is inadequate.

The slower the movement and dispersion of radioactively contaminated air the longer the exposure and the greater the desage to effected populations.

16. Uhat additional consideration do you contend should be given to " inversion and very slow air movement" in calculating design-basis accident radiation doses? Explain the basis for your answer.

For exposure at the site boundary from a design basis release, the extreme case is represented by calm at Pasquill G.

17. Do you contend that the NRC Staff is required by any regulation, regulatory guide, policy statement, or other authority to consider "the extreme 17

condition of inversion and very slow air movement" in calculating the radioactive doses associateo with design-basis accidents? If so, identify all such requirements.

Yes. NEPA, and CEQ/NRC implementing regulations.

18. In addition to the " realistic" doses shown in Table 5.9, the NRC staff is also conducting a safety evaluation of design-basis accidents to estimate the potential upper limits of individual exposure in the event of the initiating events listed in Table 5.9.

These calculations assume "very poor meteorological dispersion conditions" (DES /FES, p. 5-35), and result in estimated doses at the Exclusion Area Boundary which "would not be exceeded more than 5%

of the time because of other meteorological conditions at the site," (FES, p. 9-12 ) . Do you contend that the " environmental assumptions" used to calculate these radiation doses entirely fail to take into account the possible effects of inversion and very slow air movement"? If so, please explain.

No. No calculations are presented in the DES /FES.

19. If your response to the preceding interrogatory is negative, do you contend that this analysis in the DES /FES fails to place sufficient emphasis upon the moverent"? If not, please explain.

Yes. However, no calculations are presented nor are the data available to intervenors.

2D. If your ansuer to the preceding interrogatory is affirmative, explain why you belive that the effects of " inversion and very slou air movement" upon these projected radiation doses have not been properly considered, and uhy the DES's present treatment of these metec J1ogical factors is inadequate.

Please see responses to Interrogatory 19, above.

21 . In calculating the potential radiological ensequences associated with severe accidents, the DES /FES takes into account site-specific environmental parameters uhich include

" meteorological data for the site representing all year of consecutive hourly measurements and seasonal variations." (DES /FES, p. 5-37). Do you contend that the methodology used to calculate these doses entirely fails to take into account the possible effects of " extreme, but frequently encountered, 18

weather conditions"? If so, please explain.

It may. However, the answer is cependent on the specific results of the actual sampling plan.

Intervenors are informed that the Staff will make available more specific data underlying these calculations.

22. If your answer to the preceding interrogatory is negative, do you content that this analysis in the DES /FES fails to place sufficient emphasis upon trve possible effects of " extreme, but frequently encountered, weather conditions"? If not, please explain.

It may. Please see response to Interrogatcry 21, above.

23. If you ansuer to the preceding interrogatory is affirmative, explain the reason for your' belief that the effects of " extreme, but frequently encountered, weather conditions" upon severe accident radiation doses have not been properly considered, and uhy the DES.FES' treatment of these meterrological factors is inadequate.

Intervenors have not yet seen the specific data.

24 What acditional considerations do you contend should be given to " extreme, but frequently encountered, weather conditions" in calculating severe accident radiation doses. Explain the reason for your answer.

The NRC Staff should evaluate specifically the uorst meterological case reflectec in the three years of observations for the site.

25. Do you contend that the NRC Staff is required by any regulation, regulatory guide, policy statment or other authority to consider " extreme, but frequently encountered, weather conditions" in calculating the radiation doses associated with serious accidents?

If so, identigy all such requirements.

t Yes.

26. What are the bases for your responses to interrogatories 13 through 2S? Identify all l

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documents, calculations, testimony, or oral statements, and all legal requirements or guidelines, on which you rely in support of your responses.

See answers to Interrogatories 9 and 12, above.

27. Do you contend that the meteorological considerations of the DES /FES should reflect only the " extreme condition of inversion and very slou air movement" in calculating the potential radiological doses associated uith design-basis and severe accidents? Explain the reasons for your answer.

No. The extremes ano average best define the impacts.

The Staff should expressly consider the most severe.

28. Do you contend that the DES /FES's projected radiation doses associated with design-basis and serious accidents are currently incorrect because the possible effects of inversion and very slow air movement have not been acequately considered? If so, what meteorological assumptions do you contend should be made in the calculation of cesign-basis and severe accidents?

Yes. For design-basis accidents, with exposures at the plant site boundary, the Staff should consider an inversion with slow air at the time of the release. For severe accidents, the staff should consider plume transport with minimun dispersion; elow air Pasquill G. Stagnation occurs whcn the center of the plume is over the maximum population concentration. Possible reverse and return air movement causing additional exposures to the maxinum population. Finally, light precipitation over the population concentration causing maximum radiation fall-out during daytime when maximum numbers of persons are unsheltered and thus exposed.

29. Do you contend that additional consideration of the possible effects of " inversion and very slow air movement" upon raciological doses from design-basis and severe accidents at Catawba Nuclear Station would alter the DES /FES's conclusion that "the risk of incurring any adverse health effects as a consequence of [ design-basis or severe accidents] is exceedingly small"? (FES, p. 5-3S). Explain the basis for your answer, making reference to any 2D

calculation or documents you have to support your answer.

Yes. See Table ER 2.3.0-2 and -3, page 6. Ue do not accept the NRC assumption of a lou probability of a design-basis or severe accident; nor that the resultant risk is exceedingly small. We unoerstand risk to mean consequences which are catatrophic as described above.

30. Do you contend that additional consideration of the effects of these meteorological factors upon raciological consequences would reveal risks to public health and safety so substantial that the DES /FES's overall cost-benefit conclusion woulo be affected? Explain your answer.

Yes. Containment breach accident under conditions of light South to Southwest airflou at Pasquill G uould be devastating.

31 . Do you dispute the validity of the follouing statement, which appears at p. 4-12 of the FES:

The meteorological cata cets used for oose consequence assessments for accidental or routine ,

releases contained in the FES adequately reflect expected occurrences of stable atmospheric exposures at the planta)do d)elete H)ELP m) ark vicinity of the Catauba site." Explain your answer.

Yes. Please responses above.

32. Uhat are the bases for your responses to interrogatories 27 through 31? Identify all documents, calculations, testimony or oral statements, and all legal requirements or guidelines, on uhich you rely in support of your responses.

Please see responses to General Interrogatories and the bases explicitly referred to answers to specific interrogatories above.

sl-Robert Guild s/-

J e s s e' L . Riley ,

P.O. Box 12097 854 Henley Place Charleston, S.C. 29412 Charlotte, N.C. 26207 Counsel for palmetto Alliance Spokesman for Carolina ,

Environmental Study Group '

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