ML20030B881
| ML20030B881 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 08/19/1981 |
| From: | Shotwell J MASSACHUSETTS, COMMONWEALTH OF |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8108250088 | |
| Download: ML20030B881 (8) | |
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NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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BOSTON EDISON COMPANY et al.
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Docket No. 50-471
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(Pilgrim Nuclear Generating
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Station, Unit 2)
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COMMONWEALTH OF MASSACHUSETT.S' -
f.UG 2 41981 *. -
3 FIRST SET OF INTERROGATORIES a v.an tamm"uswon TO THE NRC STAFF R3LATIVE TO TMI ISSUES y
Pursuant to 10 C.F.R.
S2.720 (h) (2) (ii), the Commonwealth requests that the attached Interrogatories be answered fully, in writing, and under oath by NRC personnel [ hereinafter,
" Staff"] with knowledge of the facts and designated by the Executive Director for Operations.
For purposes of these interrogatories, the term
" document (s ) " refers to the original and copy (but not both if identical in every respect) of any printed, written, recorded, transcribed, punched, taped, filmed, photographed or graphic matter in the possession or subject to the control of the NRC, or any Commissioner, employee, agent or attorney thereof, whether sent or received or neither, whether a draft or l
95o5 Srf 9108250088 810s19 gDRADOCK 05000471 PDR
- otherwise, however produced or reproduced, and both sides thereof, including but not limited to, any memorandum, correspondence, letter, affidavit, court paper, transcript, diary, report, study, telegram, table, telex message, record, chart, paper, work paper, graph, index, book, notebook, pam-1 phlet, periodical, tape, data sheet, data processing card, note, notation, minute desk calandar, appointment book, sound recording, computer print-out or microfilm.
INTERROGATORIES 1.
For each and every recommendation and requirement contained in NUREG-0578, at pages 6-20 and Appendix A, list the requirement and indicate whether, in the Staf f's opinion, the Applicants' construction permit application, including the PSAR and amendments thereto, satisfies said requirement.
Whether your response for any given requirement is in the affirmative or negative, explain in detail the reasons for your answer, identifying each f act upon which you rely and each document, and the particular parts therof, of which you are aware which supports each fact so identified.
2.
For each Action Plan Item listed in NUREG-0660 and designated therein as applying to construction permit applications which does not appear in NUREG-0578 or NUREG-0718, Rev. 1, Appendix B, please list each requirement set forth in NUREG-0660 under such item and indicate whether, in the Staff's opinion, the Applicants' construction permit application,
including the PSAR and amendments thereto, satisfies said i
J re quirement.
Whether your response for any given requirement is in the affirmative or negative, explain in detail the reasons for your answer, identifying each fact upon which you rely and each document, and the particular parts thereof, of which you are aware which supports each fact so identified.
1 3.
The Supplementary Information to the Commission's proposed Final Rule on the application of lessons learned from the TMI accident to construction permit and manufacturing license applications, as set forth in Eisenhut's letter of July 14, 1981 to all such applicants, states that "some elements in the TMI Action Plan have not been acted upon and thus may be required (of construction permit applicants) at a future date."
Please identify all such elements and describe in detail the Staf f's and/cr Commission's plan and schedule for i
action thereon.
Identify all documents of which you are aware which support your answer.
4.
Applicants have committed in PSAR Amendment 43 to l
performing a site / plant-specific probabilistic risk assersment (PRA).
In the opinion of the Staff, will the PRA be scheduled so that it will be feasible to incorporate into the plant design any modification which might be indicated by the results thereof?
If not, list all such modifications which might be I
precluded or rendered infeasible.
Whether your answer is in the affirmative or negative, explain the reasons for your
~
, i answer in detail, identifying each fact upon which you rely and each document, and the particular parts thereof, of which you 1
are aware which supports your answer.
i 5.
The transcript of the July 8, 1981 meeting of the ACRS Subcommittee on Pilgrim 2 indicates, at p. 73, that in the Staff's opinion, Pilgrim 2's current two-pump EFW system is
" marginal" and that the Applicants will be examining a three-pump system as part of their PRA.
Please describe in detail'the bases upon which the Staff will decide, following the Applicants' analysis, whether the three-pump system must be adopted.
Also indicate whether the current two-pump system meets the Staff's acceptance criteria as outlined in j
NUREG-0022, Supp. No. 6, at p. 30.
6.
The Applicants have committed in PSAR Amendment 43 to f
conducting a number of additional studies or evaluations and submitting additional or modified system designs on the basis thereof.
With respect to each such study state the Staff's opinion as to whether it will be feasible to incorporate into 4
the plant design any modification which might be indicated by the results thereof.
Identify any design modifications which might be indicated by said study but which, in the opinion of i
the Staff, might be precluded or rendered infeasible by the i
time the study is completed.
Explain your answers in detail, identifying each fact upon which you rely and each document, l
and the particular parts thereof, of which you are aware which supports your answer.
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! i 7.
Describe in detail all construction permit conditions l
which tha Staff believes should be imposed relative to the timing of any of the studies which the Applicants have committed to perform.
8.
Explain in detail t/?e bases for all changes in
" requirement category assignments" between the original NUREG-0718 and NUREG-0718, Revision 1.
Identify all documents of which you are aware which discuss or support changes to those assignments.
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9.
In the opinion of the Et:ff. should the Applicants be 1
required, prior to receiving a construction permit, to document l
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all deviations from the Standard Review Plan?
Explain the i
I reasons for your answer in detail.
If your answer depends in
)
any way on the timing or outcome of the current Commission rulemaking proceeding on this subject, explain the reasons for that perceived dependence.
In any event, provide any information available to the Staff and not evidenced by Federal e
Register notices as to the status of that rulemaking proceeding, the likely product thereof (especially, the manner in which the rule will apply to pending construction permit applications), and the likely date of promulgation of a final rule.
Identify all documents of which you are aware which support your answer.
1
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l 10.
Identify all individuals whom the Staff intends to call as witnesses on TMI issues and provide their j
qualifications.
Also provide for each such individual a list of all proceedings of any kind before any tribunal in which said individual has testified and describe,the subject matter of his or her testimony on each such occasion.
Also provide for each such individual a list of all reports, studies, papers, articles, and books, whether published or not, and whether a draft or not, relating in any way to the TMI accident, the lessons learned therefrom, or any of the requirements listed in your responses to interrogatories 1 or 2 above, prepared in part or in whole by said individus1 or by a corporation, partnership, or other organization [other than the l
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NRC) of which said individual is an employee, offictr, I
director, partner, or agent.
11.
PSAR Amendment 43 states, at p. 1C-48, that the "present Pilgrim Unit 2 design i.ncludes much of the instrumentation that meets the requirements of Rev. 2 of Regulatory Guide 1.97."
List every instrument currently within the Unit 2 design which, in the Staff's opinion, meets the requirements of R.G.
1.97, Rev.
2, indicating in each case the particular requirement which it satisfies.
Provide a separate list of all requirements of R.G. 1.97, Rev. 2 which, in the Staff's opinion, are not satisfied by the current design.
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. - _ f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
BOSTON EDISON COMPANY et al.
)
Docket No. 50-471
)
(Pilgrim Nuclear Generating
)
Station, Unit 2)
)
)
)
CERTIFICATE OF SERVICE I hereby certify that the within Interrogatories have been served on the following by deposit of copies thereof in the United States Mail, first class mail, postage prepaid this 19th day of August, 1981:
Andrew C. Goodhope, Esq.
Henry Herrman, Esq.
Chairman Room 1045 Atomic Safety and 50 Congress Street Licensing Board Boston, Massachusetts 02109 3320 Estelle Terrace Wheaton, Maryland 20906 Mr. & Mrs. Alan R. Clecton 22 Mackintosh Street Dr. A. Dixon Callihan Franklin, Massachusetts 02038 Union Carbide Corporation P.O.
Box Y William S.
Abbot, Esq.
Oak Ridge, Tennessee 37830 suite 925 50 Congress Street Dr. Richard F. Cole Boston, Massachusetts 02109 Atomic Safety and Licensing Board Thomae G. Dignan, Jr., Esq.
U.S. Nuclear Regulatory Ropes & Gray Commission 225 Franklin Street Washington, D.C.
20555 Boston, Massachusetts 02110 Patrick J.
Kenny, Esq.
Atomic Safety and Licensing Edward L. Selgrade, Esq.
Appeal Board Deputy Director U.S. Nuclear Regulatory l
Mass. Office of Energy Commission i
Resources Washington, D.C.
20555 73 Tremont Street Boston, Massachusetts 02108 l
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_ _. _ _ _ _,. _ _. -. ~ _.
. Atomic Safety and Licensing Office of the Secreta:
Board Panel Docketing and Service Section U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Chief Librarian Jack R. Goldberg Plymouth Public Library Office of the Executive North Street Legal Director Plymouth, Massachusetts 02360 U.S. Nuclear Regulatory Commission William S.
Stowe, Esquire Wash.' jton, D.C.
20555 Boston Edison Company 800 Boylston Street Thomas S. Moore, Chairman Boston, Massachusetts 02199 Atomic Safety and Licensing Appeal Board Francis S. Wright, Esquire U.S. Nuclear Regulatory Berman & Lewenberg Ccemission 211 Congress St.
Washington, D.C.
20555 Boston, Massachusetts 02110 Christine N. Kohl, Esquire Dr. John H.
Buck Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Sted'en H. Lewis R. K. Gad III U.S. Nuclear Regulatory hoped i Gray Commission 225 Franklin Street Office of the Executive Boston, Massachusetts 02110 Legal Directar Washington, D.C.
20555
- Michael Blume U.S.
Nuclear Regulatory Commission Office of the Executive Legal Director
{ ]
Washington, D.C.
20555 w
JQfAnn Shotwell
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Assistant Attorney General Environmenta.' Protection Division Public Protection Bureau Department c'.* the Attorney General One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265
- By Federal Express m