ML20053D175
| ML20053D175 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/01/1982 |
| From: | Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
| Shared Package | |
| ML20053D166 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206040157 | |
| Download: ML20053D175 (13) | |
Text
.
+
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSOLIDATED EDISON COMPANY OF Docket Nos. 50-247 SP NEW YORK, INC. (Indian Point, Unit 2) 50-286 SP
)
POWER AUTHORITY OF THE STATE OF
)
June 1, 1982 NEW YORK (Indian Point, Unit 3)
)
NRC STAFF RESPONSE TO UCS/NYPIRG'S INTERROGATORY 1 Interrogatory 1 Identify all individual (s), that you intend to present as witnesses in this proceeding on the subject matter of any of the order's questions.
The identification should include the following:
a.
What is the person's full name?
b.
What is the person's address?
c.
What is the person's present or last known position and business affiliation?
d.
What is the person's field of expertise?
e.
If the person is not a Staff employee, on what date did the l
Staff first contact or consult the person?
f.
What are the dates of all subsequent contacts or consultations I
with the person?
g.
Were any reports made to Staff by the persons?
h.
If the answer to question 19 is anything other than a simple negative, indicate for each such report:
(1) the date of the report; (2) whether the report was written or oral; and 8206040157 020601 DR ADOCK 05000247 PDR
e.
(3) whether the report was submitted by the person while acting in an advisory capacity, as a prospective witness, or both.
1.
What 1s the subject matter of the witness' testimony?
j.
What are the facts and/or opinions to which the witness will testify and the grounds for each fact or opinion?
NRC Response Pursuant to an agreement reached between Counsel for UCS and the Staff, this response is provided to UCS/NYPIRG Interrogatory 1.
This response lists the individuals which the Staff intends at the present tire to present as witnesses in this proceeding on the subject matter of Comission Questions 1, 2, 5 and 6.
Please note that since the Staff's testimony regarding these questions is not yet complete, this list is subject to change.
Question 4 The Staff hereby identifies an additional potential witness concerning issues raised under Commission Question 4.
(a) John Hannon (b)
U.S. Nuclear Regulatory Comission Washington, D.C. 20555.
(c) Project Manager in Operating Reactors Branch No.1 of the Division of Licensing, Office of Nuclear Reactor Regulation.
(d) Reactor Inspection and Operation (e) - (h) Not applicable.
(i)and(j)
Mr. Hannon may present testimony conerning whether license conditions should prohibit power operation of Units 2 and 3 when the road network becomes degraded because of adverse weather conditions.
Questions 1, 2 and 5 (a) Robert M. Bernero (b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Director, Division of Risk Analysis., Office of Nuclear Regulatory Research, Nuclear Regulatory Comission.
(d) Risk Assessment.
(e) - (h) Not applicable.
(i) Mr. Bernero will discuss the development of risk assessment and NUREG-0715. fir. Bernero will also testify as to the Staff's view of the risk of the Indian Point facilities.
(j) NUREG-0715 has been updated by the Staff since 1980 by work done since. Many risk studies have been undertaken since the TMI accident. The remainder of this testimony is still in preparation.
(a) Roger M. Blond (b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Section Leader, Division of Risk Analysis, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Comission.
i (d) Severe Accident Consequence Analysis.
(e) - (h) Not applicable.
l (1) Roger Blond will testify concerning the backgro,'nd of risk assessment and the development of NUREG-0715, the risks posed by the accidents at the Indian Point facilities.
(j) Portions of NUREG-0715 have been affected by work done by Staff and Licensees since 1980. The remainder of this testimony has not been prepared.
(a) Frank H. Rowsome, III I
(b)
U.S. Nuclear Regulatory Comission l
Washington, D. C.
20555 i
(c) Deputy Director, Division of Risk Analysis, Office of Nuclear Regulatory Research, Nuclear Regulatory Comission'.
i (d) Risk Assessment.
(e) - (h) Not applicable.
(i) Mr. Rowsome will present testimony on the effect of risks posed by the Indian Point facilities of measures required or referenced in the Director's Order of February 11, 1980. Mr. Rowsome will also provide testimony introducing aspects of the Staff's analysis of Conunission Question 1.
(j) This testimony is in preparation.
(a) Sanford Isreal (b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Risk Analyst, Reliability and Risk Assessment Branch, Division of Safety Technology, Office of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Comission.
(d) Systems evaluation.
(e) - (h) Not applicable.
(1) Mr. Isreal will present testimony on the subject of accident sequence evaluation.
(j) The Indian Point Probabilistic Safety Study contains a reasonable representation of internal accident sequence frequencies at the Indian Point plants.
(a) Robert J. Budnitz (b) 2000 Center Street Berkeley, California 94704 (c) Physicist in Energy / Environmental Research and Nuclear Safety, Future Resources Associates, Inc.
(d) President, Future Resources Associates, Inc.
(e) April 1982.
(f) Constant contact.
(g) No reports concerning this proceeldng have been submitted to the Staff.
(h) Not applicable.
'l
l (1) Dr. Budnitz will present testimony concerning external accident initiators.
(j) Testimony is in preparation.
(a) Benjamin Buchbinder (b)
U.S. Nuclear Regulatory Commission Washington, D. C.
20555.
(c) Chief, Risk Methodology Data Branch, Division of Risk Analysis, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Coi,rni ssion.
(d) Risk Assessment.
(e) - (h) Not applicable.
(i) Mr. Buchbinder will present testimony on the Indian Point Probabilistic Safety Study treatment of fire accident initiation.
(j) This testimony is in preparation.
(a) James F. Meyer (b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Senior Task Manager, Reactor Systems Branch, Systems Integration Division, Office of Nuclear Reactor Regulation.
(d) Reactor Containment Systems Under Core Melt Conditions.
(e) - (h) Not applicable.
(i) Mr. Meyer will present testimony on containment failure modes and mitigation features (Commission Questions 1 and 2).
(j) This testimony is in preparation.
(a) Sarbeswar Acharya (b)
U.S. Nuclear Regulatory Commission Washington, D. C. 20555.
(c) Senior Radiological Engineer, Accident Evaluation Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.
(d) Accident consequence analysis.
~
(e)-(h) Not applicable.
(i) Mr. Acharya will present testimony concerning consequences of certain accident sequences at the Indian Point facilities.
(j) This testimony is in preparation.
(a) Jack Hickman (b) Sandia National Laboratories Albuqueque, New Mexico (c) Supervisor, Nuclear Fuel Cycle Systems Safety Division.
(d) Systems analysis.
(e) July 1980.
(f) Constant contact.
(g) No reports have been provided to the Staff concerning Indian Point.
(h) Not applicable.
(i) Critique of the Indian Point Probabilistic Safety Study.
(j) This testimony is in preparation.
(a) Gregory Kolb (b) Sandia National Laboratories Albuqueque, New Mexico (c) Technical Staff Member, Nuclear Fuel Cycle Systems Safety Division.
~
(d) Systems Analysis.
(e) March 1982.
(f) Constant contact.
(g) No reports have been submitted concerning Indian Point.
(.
- - + - - - -
- +, - - -,
-e----
(h) Not applicable.
(i) Critique of the _ Indian Point Probabilistic Safety Study.
(j) This testimony is in preparation.
Question 6 (a) Phillip R. Nicholson (b)
U.S. Nuclear Regulatory Commission Washington, D. C.
20555 (c) Antitrust Economist in the Antitrust and Economic Analysis Branch of the Division of Engineering, Office of Nuclear Reactor Regulation of the Nuclear Regulatory Commission.
(d) Economics.
(e)-(h) Not applicable.
(i) The impact of shut down of Indian Point Units 2 and 3 on fixed charges associated with each plant.
(j) Few cost savings within the fixed cost category will occur as a result of shut down of Indian Point Units 2 and 3.
l (a) Sidney E. Feld, Ph.D.
(b)
U.S. Nuclear Regulatory Commission Washington, D. C.
20555 (c) Regional Environmental Economist in the Antitrust and Economic Analyses Branch of the Division of Engineering, Office of Nuclear Reactor Regulation of the Nuclear Regulatory Commission.
(d) Resource economics.
(e)-(h) Not applicable.
(1) The replacement energy cost of the shut down of Indian Point Units 2 and 3.
(j) Replacement energy costs resulting from the shut dowr. of Indian Point Units 2 and 3 are likely to be on the order of billions of
- dollars, y
\\
1 I
(a) Erastace N. Fields (b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Electrical' Engineer in the Antitrust and Economic Analysis Branch of the Division of Engineering, Office of Nuclear Reactor Regulation of the Nuclear Regulatory Comission.,
(d) Demand and energy forecasting and electric system reliability.
(e) - (h) Not applicable.
(1) System reliabilty impacts resulting from a shut down of the Indian Point Units 2 and 3.
(j) Based on assessment of capability resource assessments based on load growth projections, there is no absolute need to build new capacity to replace the Indian Point units should they be shut down.
(a) William A. Buehring, Ph.D.
(b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Environmental Systems Engineer, Energy and Environmental Systems Division, Argonne National Laboratory.
~
(d) Environmental Systems Engineer.
l (e) April 1982.
l (f) Constant contact.
(g) No.
(h) Not applicable.
(1)and(j) The testimony, which is in the process of being developed, will address the matters of cogeneration and conservation.
l (a) Frances C. Kornegay (b) Oak Ridge National Laboratory Energy Division Oak Ridge, Tennessee l
l
_g_
(c) Research Staff Member in the Environmental Impact Section in the Energy Division of the Oak Ridge National Laboratory.
(d) Meteorologist.
(e) Decemberb81.
(f) Constant contact.
(g) No.
(h) Not applicable.
(i)and(j)
Incremental increases in air pollutant concentrations resulting from replacing the capacity of Indian Point Units 2 and 3 with fossil-fired units.
(a) Germain E. LaRoche, Ph.D.
(b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Land Use Analyst in the Terrestrial Resources Section of the Environmental Engineering Branch of the Division of Engineering, Office of Nuclear Reactor Regulation of the Nuclear Regulatory Comission.
(d) Terrestrial Ecologist.
(e) - (h) Not applicable.
(1) Impact on the terrestrial environment if the power generated by Indian Point Units 2 and 3 is replaced by fossil fuel burning power sources.
(j) The impacts on the terrestrial ecology from incremental increases in due to the use of fossil fuel burning power 50, N0, C0, and NO,lacement power for Indian Point Units 2 and 3 7
2 7
sources to 3rovide rep would only
)e slight.
(a) Charles W. Billups, Ph.D.
(b)
U.S. Nuclear Regulatory Comission Washington, D.C.
20555 l
(c) Aquatic Scientist in the Environmental Engineering Branch, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Comission.
(d) Acquatic Resources.
(e) - (h)' Not applicable.
(i) Environmental consequences, with regard to aquatic resources, of a shut down of Indian Point Units 2 and-3.
(j), Testimony 4s still in the process of being developed.
I (a) Robert S.-Wood (b)
U.S. Nuclear Regulatory Comission
.. ashington, D. C.
20555 W
(c) Utility Policy Analyst in the. Licensee Relations Section of the Office of State Programs of the Nuclear Regulatory Comission.
(d) Economics, Public Administration Financial Analysis.
(e) - (h) Not applicable.
(i)
Impact of shutJdown ofilndian Point Units 2 e
.. decomissioning costs.
(j) Definitive conclusions regarding the impact on decomissioning costs due to an early shut down of Indian Point Units 2 ard 3 are difficult because so many of the variables affecting decomissioning financing costs are subject to' change.
(a) Edwin D. Pentecost, Ph.D.
l l
(b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Land Use Analyst in the Terrestrial Resources Section, Environment Engineering Branch, Division of Engineering, U.S. Nuclear Regulatory Comission.
l (d) Terrestrial Ecologist.
(e)-(h) Not applicable.
(i)
Impacts to terrestrial biota due to onsite coal and limestone storage and disposal of coal combustion and pollution abatement waste.
(j)
Impacts to terrestrial biota due to onsite coal and limestone storage and disposal of coal combustion and pollution abatement waste include:
loss of vegetation, loss of habitat by certain wildlife species, dust and noise.
(a) Edward F. Branagan (b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 (c) Radiological Physicist with the Radiological Assessment Branch in the Office of Nuclear Reactor Regulation of the U.S. Nuclear Regulatory Comission.
(d) Radiological Physicist.
(e) - (h) Not applicable.
(1)and(j) Testimony is being developed on radiological health effects of operation of Indian Point Units 2 and 3.
(a) Donald R. Hopkins (b)
U.S. Nuclear Regulatory Comission Washington, D. C.
20555 l
(c) Senior Health Physist, Transportation and Materials Risk Branch, Division of Risk Analysis, Office of Nuclear Regulatory Research, i
l U.S. Nuclear Regulatory Commission.
(d) Health Physicist.
(e) - (h) Not applicable.
(1)and(j) Testimony is being developed on the radiological health effects of a transportation accident involving radioactive materials.
1 (a)
E. A. Zeighami, Ph.D (b) Oak Ridge National Laboratory Oak Ridge, Tennessee
1
. 0 (c) Epidemiologist in the Health Effects and Epidemiology Group of the Health and Safety Research Division of the Oak Ridge National Laboratory.
(d) Epidemiologist.
(e) December 1981.
~
(f) Constant contact.
(q) No.
(h) Not applicable.
(i) Health effects of replacing Indian Point Units 2 and 3 with fossil-fired units.
(j) Oil fired replacement capacity is not expected to produce levels of pollution over the estimated thresholds for health effects. Coal fired replacement capacity produces a very small increment to the annual average values for S0, particulates, and N0
- 2 2
(a)
P. J. Walsh, Ph.D.
(b) Oak Ridge National Laboratory l
Oak Ridge, Tennessee l
(c) Group Leader, Health Effects and Epidemiology, Health and Safety Research Division, Oak Ridge National Laboratory.
(d) Health Physicist.
(e) December 1981.
(f) Constant contact.
(g) No.
(h) Not applicable.
(i) Health effects of replacing Indian Point Units 2 and 3 with fossil-fired units.
l (j) 011 fired replacement capacity is not expected to produce levels of l
pollution over the estimated threshold for health effects. Coal l
fired replacement capacity produces a very small increment to the annual average values for S0, particulates and N0
- l 2
2
(a) Sam A. Carnes, Ph.D.
(b) Oak Ridge National Laboratory Energy Division Oak Ridge,' Tennessee (c) Research Staf/ Member in the Social Impact Analysis Group of the Energy Division of Oak Ridge National Laboratory.
(d) Political Scientist.
(e) December 1981.
(f) Constant contact.
J (g) No.
(h) Not applicable.
(1) Social socioeconomic impacts of shutting down and decommissioning either one or both of the Indian Point Units 2 and 3.
(j) The socioeconomic impacts of decomissioning Indian Point Units 2 and 3 would be adverse for residents of the local area.
(a) Keith F. Ackennan, Ph.D.
(b) Oak Ridge National Laborary Oak Ridge, Tennessee (c) Section Leader, Group Metabolism and Dosimetry Section in the Health Safety Research Division, Oak Ridge National Laboratory.
(d) Dosimetry.
(e) - (j) A potential witness on the matter of health effectr to children from radiation.
R -ectfully submitt d,
/
1 Janice E. Moo e Counsel for NRC Staff Dated at Bethesda, Maryland this 1st day of June, 1982.
._