ML20032A997
| ML20032A997 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/23/1981 |
| From: | Von Zellen B DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SAFE ENERGY FOR NEW HAVEN |
| To: | COMMONWEALTH EDISON CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8111040251 | |
| Download: ML20032A997 (11) | |
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'.. f RELATED CORRESPONDENCE Sin..niscippi Allicnco fsr tha Env. ire t
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326 North Avon Street
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ctober 23, 1981 Rockford, Illinois 61103
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In the Matter of o
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Doc Nos. 50 454 OL COMMONWEALTH EDISON COMPANY,';-
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DAARE/ SAFE /PIRSTERO ND 21 OF INTERROGATORIES TO'BE# ANSWERED-BY(N 30 P1:14
..$y THE COMMONWEALTH. EDISON COMPANY
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The Inte'rvenors'DAABE/ SAFE 3equest, pursuant to j-235Sfhsh
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- d vised Schedule" dated September 3.9T19815 that tile' Commons n
. a %:yQ wea3th Edison Company answer separately $Jand fully in writ-
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ing, each of the follow *,ng Interrogatories and produces the m n=Pf requested documents at the address of136 Ilehamwood Drive, 7
'" /p DeKalb, Tmnois 60135, telephone 835 756 2801 and not later than=end Mi$5 of period designated by the Nuclear Regulatory'C=miasion.
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. INSTRUCTIONS AND DEFINITIONS mc.m 7
1.
As used in these Interrogatories, whenever
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appropriate, the term "and." as,well;as "o," shall be con-
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strued either disjunctive.Ly or conjunbtively as neccessary i
d to bring within the scope of these interrogatories any in-formation which might otherwise be construed to.be outside their scope.
2.
As used in these Interrogatories, the term
" person" includes, without limiting the generality of its
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._ 8111040251 811023 PDR ADOCK 05000454 O
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Sinniacippi Allianca far tha Envircnmant 326 North Avon Street Rockford, Illinois 61103 meaning, every nature person, corporate entity, partnership,
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association, governmental body'or agency.
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As used in these Interrogatories, the term "docuinent," " list," " summary," or instruction " summarize" or I
" provide" shall mean all written or recorded material of any M
kink or character known to Commonwealth Edison, its agents
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(4 or consultants or in the possession, custody'or control'of Commonwealth Edison, its agents or consultants, iiicluding, g
I without limitation, letters, correspondence, telegrams, mem-oranda, notes,' rWeGrds, minutes, contracts, agreements, re-f cords or notations of telephone or personal conversations'or t
conferences, interoffice communications, microfilm, bulletins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, invoices, tape recordings and worksheets.
The term " document" shall also-include copies containing information in addition to that con-tained in or on the original and all the attachments, append-L.
ices, enclosures or documents referred to in any documents produced pursuant to this Request.
4.
When used with respect to any act, occurrence, transaction, statement, request, conduct, communication, in-stance, aspect of any event, defect, or omission, " Identify" means, without limitation, to describe in complete detail the event or events constituting such act; when used with respect to a. document, " Identify" means without limitation, to state 9
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'Sirinissippi Aliicnca fer tha Envircnmant 326 North Avon Street 3_
Rockford, Illinois 61103 its date, the type of document (e.g., letter, memorandum, telegram, chart, photograph, sound reproduction, et cetera),
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the author and addressee, the present location and the custo-k dian, and a description of its contents.
5 If any of the information contained in the
' '. f answers to these Interrogatories is not within the personal knowledge of the. person signing the Interrogatory,.so state and identify each person, document and communication on which.
he relies for the information contained in answers not solely bases on his personal knowledge.
6.
If you cannot answer any portion of the fol-lowing Interrogatories in full, after exercising diligence to secure the information to do so, so state and answer to the extent possible, specifying your inability to answer the remainder and stating whatever information or knowledge.you have concerning the unanswered portions.
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If you claim privilege with respect to~any information which is requested by these Interrogatories, i,
specify the privilege claimed, the communication arid /or ans-wer as to which that claim is made, the parties to the com-munication, the topic discussed in the communication and the basis for your claim.
10.
Pursuant to the Licensing Boards " Memorandum and Order" of August 18, 1981, at page 11 paragraph 2 there-of, these Interrogatories are continuing Interrogatories and I
'Sinnics!ppi Allicnca fer tha Environm3nt 326 North Avon Street
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Rockford, Illinois - 61103 require supplemental answers if Commonwealth Edison, its a-y, gents,or consultants, obtain'further information between the 46 time the answers are served and the time of an initial dec-
.cY' ision in the proceeding.
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INTERROGATORIES Why did Comonwealth Edison seek permission from t
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ion work in progress" on the Byron nuclear powe al sources such as the sale of stock and bonds?
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How.does Comonwealth Edison plan to reimburse with interest the ratepay-i ers whom have contributed capital investment (CWIP) funds for Byron v a
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payment of their electricity use invoices?
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When is Comonwealth Edison going to issue comon s oc in an-amount equivalent to the expenditures the rate v-I
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Af. A Why"did Commonwealth Edison petition the Illinois Comerce Comi
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- 1960 to relievs it of its obligation to encourage and stimula e ene
-servation?
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Should a partial core meltdown, such as occurred b5 Would Comonwealth obtain the funds neesessary to allow decontamination?
P Edison seek sources of funding different in nature than those sought byIf th y.
General Public' Utilities, the owners of Dil?is affirmative, how.wou 5
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by GPU?
In evaluating proposals for the design of the Byron plant reactors, cool-and A/E study's on automated monitoring and control system,what criteria were c Ej 6.
ing system, in the selection process; of those criteria, which were selected and wh construction work; h
were discarded; and how were the selected criteria weighted?
Why did Comonwealth Edison begin site preparation and ground ' p h
work on the Byron nuclear station before the EIS was completed and t eIf th h
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safety evaluation rep' ort was recieved by the NRC7 j
question is that this was done because the NRC allowed this proceedur then were there any other reasons for this action, and if so, what?
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y Commonwealth Edison has been allowed tio omit groundwater studies EIS for the Byron station on the basis that Comonwealth Edison claims no 8.
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radioactivity will precipitate into the groundwater. Provide detailed evidenca I
concludes the impossibility of contamination of groundwater from any sou al basis for this claim?
during' normal and abnormal operation of the plant. Provide also a long j
term anklysis of' routine radioactive venting upon groundwater.
j Why did Conimonwealth Edison fail to initiate a second EIS to su l
NRC for a second safety evaluation in 1976 after the discovery of the r,
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River Fault Zone, considering that this major fault which runs 2.14 m from the reactor site and interconnects with minor faults on the Byron l plant site was not discovered until after the first and only safety eva -
If the answer to this question merely untion was completed by the NRC?
refers' to an NRC mandate not to do so, provide evi i.
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a faultline and its interconnections indicated a continuance of the poor !
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6-4 maintance of safety standards, and overall safety oversights, as attest-7 ed to by Commonwealth Edison's history of culmulative plant operations.
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During preconstruction excavation on the Byron station, minor faults re were found on the plant o**e right under the reactor foundation.
This base of faults and fractured limestone was grouted with concrete to stab-ilize the foundation, What alternatives to grounting with concrete were considered and what rare the estimated costs of each alternative?
Was-it
- the possibility of a more securaly stable site considered and if so, why fit was it, and why was it refected?
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11.
Please provide a full and detailed listing of all " licensee event re-pu ports" and summary of " violation." which Commonwealth Edison has been cited for in its plants operations cince 1964 by the NHC as being in
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noncompliance with Commission regulations.
Include the nature of'each 5
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^ citation or event, the remedial action taken for each (with costs in z cluded), and a summarization of each which could occur at the Byron
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n 12.
Provide av the pubically available information and official comments -
related to the January, 1978 federal grand jury investigation and crim-inal indiction of' Commonwealth. Edison and certain of its employees on l's or about March 26, 1980.
13 Provide a complete record of official incidents of lax packaging or i leakages of radioactive. materials experienced by Commonwealth Edison in the transportation of low-level and high-level wastes to and from storage sites.
Indicate the nature of the materials, nature of acett-
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ent or leakage, and extent of damage fo. each.
14 ProvEb the data base and sources used to determine the dose. impacts of projectedtroutine, and projected emergency releases of radioactive mat-erials from the Byron plant.
What are the cumulative dosages of radia-tion to residents from all operating and projected Commonwealth Edison plants?
15 What was the exact schedule of events involved in the practice emergen-cy evacuation drill conducted in September for the Zion nuclear plant?
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Provide, and include the actual events and the deviations from the or-iginal plans.
Explain.
Is a similar exercise to be conducted for the Byron plant?
If so, when, and please give as approximate a timetable of events as possible.
16.
If there is an evacuation plan in preparation for Byron, to what degree will it be limited to the scale evidenced in the practice evacuation?
Explain. Is there anything specific to the Byron plant evacuation plan-Ang which will differ from those of Commonwealth Edison's other plants?
17.
Which of the factors listed in contention three have been considered for inclusion in the Byron evacuation plan, and by what method?
18.
Provide a summary of all personal injury claims pertaining to the con-struction work at the Byron nuclear power station, and a summary of the litigation pending at Commonwealth Edison's operating plants.
Include the nature of each claim and resolution reached.
--w-19.
Document all design changes and modifications made to the or41nni design specifications for the Byron nuclear power station, including why they were initiated and at what cost.
20.
Describe the layout of the post-tension wires in the centainment building
.of the Byron nuclear station.
Document all breakages of the wires which t l.have occurred, their removals, and or replacements.
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What company (s.( higned the electrical wiring of the control roba for the Byron nuclear station, and which installed.it?
Describe what 6cn-e
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nections exist between these companies, if anyt
'22.
Concerning DAARE/SAFEscontention five, document the basis of the clain assertion that the generating capacity of the Byron station will be need-ed within the foreseeable future along the time schedule advanced by C-
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T Commonwealth Edison.7 In light of the NBC's obligation under NEPA to 'det-ermine if 'th re exists an alternative, environmentally superior means-f: ~
to meet real power needs, describe the alternative means. considered init F
EQ place of the nuclear energy provided by the Byron plant.
Provide the a
cost estimates and criteria which led to their exclusion f.om further i
consideration by Commonwealth Edison.
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_ 23 In light of the re'ceWt rapid es.calations in the costs of nuclear energy production and Commonwealth Edison's traditional assertion that power consumption is inversely re]ated to energy price fluctuations, document Commonwealth Edison's-claim that the generating capacity of the Byron plant in addiMon to current capacity will be economically competitive as opposed to alternative means discussed in above Interrogatory. Des-cribe how current and futher rate hikes in utility costs will not fur-ther erode any basis for competitiveness.
24 Pertaining to contention six (DAARE/ SAFE), has the replacement of the zirconium cladding material by another material been considered by l
Commonwealth Edison as a safety precaution?
If so, or if not, why or why not.
Summarize
- considerations and cost-analyses used to compute I
replacement.
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List and summarize which of the factors raised in DAARE/ SAFE contention I-
- nine 21be a&hamed in the Safety Evaluation Report and Supplemental Safety p
Evaluation Heport to be issued in April and May of 1982;, including the nature and scope with whi'ch each will be dealt.
l 26.
With respect to each Contention advanced by DAARE/ SAFE which has been admitted by the Atomic Safety and Licensing Board,' list the following:
a.
A concise statement of the opposing facts for each. Contention which will be submitted or re?.ied upon at the hearing process, I
which is currently or will be in possession of Commonwealth l
Edison or its agents, together with references to the specific sources and documents and portions thereof which have been re-lied upon to establish such facts; b.
the identity of each person expected to be called as a witness at the hearing; h
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the subject matter on which the witness is expected to testify; d.
the substance of the witness's testimony.
27.
With respect to each witness identified in Commonwealth Edison's ret sponse above, identify each document which the witness will rely upon in whole or in part in the preparation of his testimony or in the dev-elopment-of his position; identify alao, the witness's qualifications to testify of the subject matter on which the witness will testify.
Finally, identify all persons who participate in the preparation of the' i
answers, or any portion thereof, to these Interrogatories.
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J RELATED CORRESPONDENCE Sinniscippi Allicnco fer tho Env.ersnm:nt.
L 326 North Avon Street 00tMETED Rock'ard, Illinois 61103 USNRC M Ef 30 P1:i4
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OFFICE OF SECRETARY
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BRANCH a.
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The undersigned, a member of'DAARE/ SAFE, certifies that on
&A 'C5M lti this date he served a copy of. these " Interrogatories" on e.,...
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eachmemberoftheserYliell'ist,Y,'UIitedStatesmail, post-
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DATE:
October 23' 1981
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Dock 0t N 3. 50-454 and 50-455
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Marshall E. Miller, Esq., Chairman Dr. A. Dixon Callihan Atomic Safety and Licensing Board Union Carbide Corporation Panel P. O. Box Y U. S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Dr. Richard F. Cole Mr. Steven C.
Goldberg Atomic Safety and Licensing Board Ms. Mitzi A. Young Panel Office of the Executive Legal U. S. Nuclear Regulatory Commission Director W shington, D.
C.
20555 U. S.. Nuclear Regulatory Commission Washington, D. C.
20555 Myron M. Cherry, Esq.
Atomic Safety.and Licensing Appeal Cherry, Flynn & Kanter Board Panel One IBM Plaza U.
S. Nuclear Regulatory Commission Room 4501 Washington, D. C.
20555.
Chicago, Illinois 60611 Atomic Safety and Licensing Board Secretary Panel Attn:
Chief, Docketing and U. S. Nuclear Regulatory Commission Service Section Washington, D.
C.
20555 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Chief Hearing Counsel Ms. Betty Johnson Office of the Executive Legal 1907 Stratford Lane Director Rockford, Illinois 61107 U. S. Nuclear Regulatory Commission Washington, D.
C.
20555
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Ms Diane Chavez SAFE 602 fek Rockford, Illinois 61104 Dr. Bruce von Zellen Department of Biological Sciences Northern Illinois University DeKalb, Illinois 60115
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