ML20052C055
| ML20052C055 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/30/1982 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CHARLOTTE-MECKLENBERG ENVIRONMENTAL COALITION |
| References | |
| NUDOCS 8205040309 | |
| Download: ML20052C055 (9) | |
Text
9 4
STAFF 4/30/82 UNITED STATES OF AMERICA d3 b
NUCLEAR REGULATORY COMMISSION 2
IEECEgy g 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 2
M474 1
e 1982 s
\\
6 In the Matter of DUKE POWER COMPANY, ET AL.
Docket Nos. 50-413 0
6 50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
NRC STAFF'S FIRST SET OF INTERROGATORIES AND DOCUMENT PRODUCTION REQUESTS TO CHARLOTTE-MECKLENBURG ENVIRONMENTAL C0ALITION In accordance with 10 CFR Sections 2.740, 2.740b and 2.741, the NRC Staff hereby serves Charlotte-Mecklenburg Environmental Coalition (CMEC),
as an intervenor in the above-captioned proceeding with NRC Staff's First Set of Interrogatories and Document Requests to Charlotte-Mecklenburg Environmental Coalition. These interrogatories and document requests relate to CMEC Contentions 1, 2, 3 and 4, as conditionally admitted in the Licensing Board's Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference), dated March 5, 1982.
Each interrogatory shall be answered separately and fully in writing under oath or affirmation, and shall include all pertinent information available to the CEMC, its officers, directors, members, employees, advisors, or counsel, based upon the personal knowledge of the person answering. Answers to these interrogatories are required to be served upon all parties to the proceeding within 14 days after service of the interrogatories. By each request for production of documents, the NRC Staff seeks to inspect and copy pertinent documents which are in the 8205040 Mi DESIGNATED ORIGINAL Certified By_ [ 6 () Y d 50l(U
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possession, custody, or control of CMEC, its officers, directors, members, employees, advisors or counsel.
As used herein, the term " documents" shall include any writings, drawings, graphs, charts, and schedules, however produced; photographs or other pictorial representations; recordings and tapes, whether sound or visual; and data compilations of whatever form.
Each interrogatory should be answered in six parts as follows:
(1) Answer the direct question asked or provide the information requested (separately as to each subpart as applicable).
(2) Identify fully any documents (a) used as the basis for the answer to the interrogatory or (b) related to the subject of the interrogatory upon which you intend to rely in establishing the pertinent contention.
(3) Give the name, address, occupation and employer of the person or persons (a) answering each interrogatory, or (b) who have served, presently serve, or it is anticipated will serve as consultants or advisors to CMEC on the subject matter of the interrogatory.
(4)
Identify each person whom you expect to call as a witness to testify as to the issue addressed in the pertinent interrogatory. As to each such person, please state (a) the subject matter of his or her testimony and (b) the substance of the testimony.
(5)
Is the answer based on a calculation? If so, describe (a) the calculation, b) identify any documents setting forth such calculation, c) identify the person who performed each calculation, 1) when it was performed, (e) each parameter used in such calculation, each value assigned to the parameters, and the source of your data, (f) the results of each calculation, and (g) how each calculation provides basis for the answers.
(6)
Is the answer based on conversations, consultations, correspondence or any other type of communications with one or more individuals? If so, (a) identify each such individual by name and address, (b) state the educational and professional background of each such individual, (c) describe the information received from such individual and its relation to your direct answer, (d) identify each writing or record related to each such conversation, consultation, correspondence or other communication with such individual.
o
, e In addition, CMEC is requested, pursuant to 10 CFR Section 2.740(e) to supplement its responses as necessary with respect to the identity of each person expected to be called as an expert witness at the hearing in this proceeding, the subject matter on which he or she is expected to testify, and the substance of such testimony. Similarly, CMEC is requested to amend its responses if CMEC subsequently learns that any response made to the interrogatories herein was incorrect when made, or that the response though correct when made is no longer correct.
INTERROGATORIES CMEC Contention 1 1.
Identify each " projection" of radioactive emissions in the Catawba ER, with appropriate paragraph, table or figure references, which you contend is " understated."
2.
What do you mean by "such releases" as used in paragraph (a) of Contention I?
3.
What is the basis for your statement that "during the operating life of a LWR such releases will become progressively greater"?
4.
Is your statement in paragraph (a) of contention 1 that during the operating life of a LWR such releases will become progressively greater based upon the use of a value for " failed fuel fraction" of 0.0012 in ER Table 3.5.1-2?
If so, please explain the relationship between that parameter and your statement.
5.
What, if any, other parameter values, assumptions, conditions, data, or methodologies, is your statement in paragraph (a) of Contention 1 based upon?
6.
As to each parameter value, assumption, condition, datum, or methodology identified in the answer to Interrogatory 4 or 5, explain in detail the facts and reasoning which relate such parameter value, assumption, condition, datum, or methodology to your statement in paragraph (a), Contention 1.
7.
Explain fully the relationship between your statement in paragraph (a) of Contention 1 and the cost-benefit balance for l
Catawba.
l
_4_
s 8.
Identify each and every way in which you contend that the " wide divergences" between such projections for the McGuire station (as shown in the ER and FES for the McGuire operating license) and Catawba (as shown in the Catawba ER)" show a " lack [of]
proper scientific foundation"?
9.
Do you challenge any apsect of the methodology or basis for measuring liquid and gaseous effluent releases contained in NUREG-0017?
10.
State each such challenge, if any, and explain in detail the facts, analyses and conclusions upon which such challenge is based.
11.
Do you have any basis other than your answer to Interrogatory 9 upon which you challenge the basis for measuring liquid and gaseous effluent releases?
- 12. Do you contend that projections of liquid and gaseous effluents from McGuire and Catawba must be the same?
13.
Explain fully your answer to Interrogatory 12.
14.
Explain fully the relationship, if any, between any differerces in liquid or gaseous release between McGuire and Catawba, and the cost-benefit balance for Catawba.
CMEC Contention 2
- 15. What do you mean by " radioactive emissions set out in the ER for normal operation of Catawba" as used in Contention 2?
Please provide references to appropriate paragraphs, tables or figures of the ER in answering this interrogatory.
- 16. What do you mean by " actual accidental releases of radionuclides" as used in Contention 27
- 17. What is the relationship between such releases and normal operation of Catawba?
l 18.
Explain fully, with all pertinent facts and reasons, the basis l
for your answer to Interrogatory 17.
l
- 19. What is the relationship, if any, between your use of the phrase, " actual accidental releases" which have occurred in operating nuclear power plants in the United States, and the term " anticipated operational occurrences" as used in Section 3.5 of the ER.
O 4 J 20.
Explain fully where, and in what manner, the ER fails "to take into account the actual accidental releases which have occurred at operating nuclear power plants" in the United States, as that phrase is explained in your answer to interrogatories 16-19, above.
CMEC Contention 3
- 21. As used in Contention 3, what " radionuclides" are referred to?
If different for subparts (a), (b), or (c), please indicate in what respect they are different.
22.
Please provide all of the facts and reasons upon which you base your statement that "the models and methods used in the ER...
project an erroneous and overly optimistic dilution effect in the discharge canal and in the lake."
23.
Please provide all the facts pertinent to, and the analytical basis for, your contention that "the only suitable and realistic model is one that, in respect to any particular radionuclide, calculates the resulting concentration by dividing the, e.g.,
annual projected release into the the total annual amount of water leaving the lake."
24.
Is it your contention that under all circumstances "the steady-state completely mixed model used in the ER results in a lower figure for the concentration than that yielded by the methodology described in the preceding sentence" [of contention 3(a)]?
25.
Please explain the basis for your answer to Interrogatory 24.
26.
State each and every fact, reason or legal authority upon which you base your statement that the cumulative impact of radionuclides released into the Catawba River from the McGuire and Catawba nuclear stations during normal operations "should be taken into account in calculating concentrations of radionuclides in water from the Catawba River by communities downstream from Catawba."
27.
Identify precisely the " communities downstream from Catawba" referred to in the last sentence of Contention 3(b), and the location of water intake for such communities.
28.
Please identify each fact, analytical assumption, study or other information upon which you base your statement that
" gaseous releases from normal operation of Catawba will be carried up to 50 miles from Catawba and will be brought back into the Catawba River watershed through rainfall."
29.
Identify each location on the Catawba River " upstream of Catawba" referred to in paragraph (c) of Contention 3.
i
5 J CHEC Contention 4
- 30. What do you mean by "long-range genetic... health effects" as that phrase is used in Contention 4.
- 31. What do you mean by "long-range... somatic health effects" as that phrase is used in Contention 4.
32.
Specify by citation all " applicable NRC guidelines" that are referred to in Contention 4.
33.
Identify the "recent work" referred to in Contention 4.
34 Identify the source (s) of " routine releases of radioactivity" that are referred to in Contention 4.
35.
Identify the source (s) of " releases of the natu's specified in Contention 2" that are referred to in Contention 4.
Define and specify the type (s))(i.e., airborne effluents 36.
and/or liquid effluents) of (a " routine releases of radioactivity " referred to in Contention 4, and (b) " releases of the nature specified in Contention 2" which are referred to therein.
37.
Identify all documents (including page numbers) which you intend to use to show that "the long-term genetic and somatic health effects of such releases [are] damaging to adults and extremely hazardous to the human embryo and fetus."
- 38. Specify the page numbers in the ER in which "the ER inadequately assesses the long-range genetic and somatic health effects of routine releases of radioactivity."
- 39. List the location of the individuals and/or groups who will receive "the long-range genetic and somatic health effects of routine releases of radioactivity" and of " releases of the nature specified in Contention 2."
40.
For each type of radioactive effluent identified in response to Interrogatory 36, provide the bases (i.e., methodology of analysis, and any documents used in that analysis) for your statement that "the ER inadequately assesses the long-range genetic and somatic health effects" of the particular type of release (i.e., airborne effluents and/or liquid effluents).
- 41. What is your position as to the manner in which such "long-term genetic and somatic health affects" should be taken "into account"?
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1
1 A Request for Documents Pursuant to 10 C.F.R. Section 2.741, the NRC Staff requests you to make available for inspection and copying at a time and location to be designated any and all documents, of whatever description, identified in the responses to the above Staff interrogatories, including, but not limited to:
(1) any written record of any oral communication between or among Intervenors, their advisors, consultants, agents, attorneys, and/or any other persons, including but not limited to the Applicants, and their advisors, consultants, agents, attorneys and/or any other persons; and (2) any documents, correspondence, letter, memorandum, notes, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts, and notes of meetings.
If CMEC maintains that some documents should not be made available for inspection, it should specify the documents and explain why such are not being made available. This request extends to any such document, described above, in the possession of CMEC, its advisors, consultants, agents, or attorneys.
Respectfully submitted, h'
.5
,. s George E. Joh son Counsel for NRC Staff Dated at Bethesda, Maryland this 30th day of April, 1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOPIC SAFETY AND LICENSING BOARD In the Matter of UUKE POWER COMPANY, ET AL.
)
Docket Nos. 50-413 50-414 (Catawba Nuclear Station.
Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S FIRST SET OF INTERROGATORIES AND DOCUMENT PRODUCTION REQUESTS TO CHARLOTTE-MECKLENBURG ENVIRONMENTAL C0ALITION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 30th day of April, 1982:
- James L. Kelley, Chairman Michael McGarry, III, Esq.
Atomic Safety and Licensing Board Panel Debevoise and Liberman U.S. Nuclear Regulatory Commission 1200 17th Street, N.W.
Washington, D. C.
20555 Washington, D. C.
20036 i
Dr. Dixon Callihan Robert Guild Esq.
i Union Carbide Corporation Attorney for the Palmetto Alliance P.O. Box Y 314 Pall Mall Oak Ridge, Tennessee 37830 Columbia, South Carolina 29201 Dr. Richard F. Foster Palmetto Alliance P.O. Box 4263 2135h Devine Street Sunriver, Oregon 97701 Columbia, Sooth Carolina 29205 Richard P. Wilson, Esq.
- Atomic Safety & Licensing Board Panel Assistant Attorney General U.S. Nuclear Regualtory Commission P.O. "ox 11549 Washington, D. C.
20555 Columbia, South Carolina 29211
- Docket and Service Section
- Atomic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regualtory Commission Washington, D. C.
20555 Washington, D. C.
20555
. Donald R. Belk Safe Eneroy Alliance 2213 East Seventh Street Charlotte, North Carolina 28204 Henry Presler, Chairman Charlotte-Mecklenburg Environmental Coalition 942 Henley Place Charlotte, North Carolina 28207 Jesse L. Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207 William L. Porter, Esq.
Albert V. Carr, Esq.
Ellen T. Ruff, Esq.
Duke Power Company P. O. Box 33189 Charlotte, NC 28242 (L ~
" bl George E Johnson Counsel for NRC Staff l