ML20062E927

Licensee Wi Pub Svc First Set of Interrogs to & Request for Production of Documents From,Intervenors Lace & St of Wi. Interrogs Concern,Inter Alia,Identification of Intervenors Contentions & Presentation of Evidence

ML20062E927
Person / Time
Site:	Kewaunee
Issue date:	11/20/1978
From:	Baker D, Keane S WISCONSIN PUBLIC SERVICE CORP.
To:
References
NUDOCS 7812130220
Download: ML20062E927 (5)

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UNITED STATES OF AMERICA v .

NUCLEAR REGULATORY CO TIS.3IGN O BEFO'tE THE ATOMIC SAFETY AND LICENSINC BOARD

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In The Matter of ) Docket No. 50-305

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WISCONSIN PUBLIC SERVICE . .

l ) Acondaent to License CORPORATION, ET AL. ) No. DPR-43 l ) (Increase Spent Fuel (Kewaunee Nuclear Power Plant) ) Storage Capa:ity)

)

LICENSEES' FIRST SET OF INTERROGATORIES TO

AND REQUEST FOR PRODUCTION OF DOCUMENTS FROM INTERVENORS AND STATE OF WISCCNSIN Pursuant to 10 CFR 55 2.740, 2.740b and 2.741, I

i the Licensees in the above entitled proceeding, by their i

undersigned counsel, hereby request that joint intervenors, Lakeshore Citizens for Safe Energy and Safe Haven, Ltd., and the State of Wisconsin answer in writing under oath or affirmation the following interrogatories; and to provide copies or make available for inspection and copying any documents designated in answers to any of the interrogatories within fourteen (14) days of service of this document.

Parties responding to these discovery requests are under a duty seasonably to supplement any responses as provided in the procedural rules of the Nuclear Regulatory Cocnission.

Interrogatory No. 1 - Identify, separately for each of Contentions 2, 8, 12, 13a, 13b, 13c and 13f, any witnesses you intend to present in this proceeding concerning the subj ect matter of the contention. Such identification should include names, addresses, educational backgrounds, occupations, and professional qualifications, l

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Interrogatory No. 2 - For each person identified in response to Interrogatory No.1, provide a su==ary of the position and proposed testimeny of the person as to each contention which you intend to present in this proceeding.

Interrogatorv No. 3 - For Contentions 2, 8, 12, 13a, 13b,13c and 13f, identify by author, title, date of publica-i tion and publisher all books, documents and papers upon which you intend to rely in presenting your case and provide l

copies (or make the same available for inspection and copying).

{ Interrogatory No. 4 - In regard to Contention 2, do you assert that under some circumstances the co=bined emissions from the Point Beach Nuc' lear Power Plant and the Kewaunee Nuclear Power Plant will excedd regulatory levels?

Interrogatorv No. 5 - If the answer to Interrogatory No. 4 is anything other than an unqualified no, state the j type and level of excessive emissions you claim will occur

' and state the circumstances under which you assert such an j excessive level of emissions would occur and provide the I (

complete scientific basis for such assertions including any codels or calculations used.

Interrogatorv No. 6 - Do you contend that the neutron absorber materials proposed for use in the Kewaunee Spent Fuel Pool are similar to those used at the Connecticut Yankee facility?

Interroestory No. 7 - What specific problems do you assert are likely to be associated with the neveron absorber plates proposed for use in the Kewaunee Spent Fuel Pool and what is the scientific basis for any asserted proble=s?

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. rs Interroratory No. 8 - Do you assert that monitorirg of neutron absorber plates is either desirable or necessary?

Interrogatory No. 9 - If the answer to Interrogatory i No. 8 is anything other than an unqualified no, state why, e

you assert monitoring is desirable or necessary, including I

any scientific basis therefor and state, precisely what kind and frequency of monitaring you assert is necessary or desirable.

Interroratorv No. 10 - In reference to Contention 12, what wastes, if any, other than old racks, filters, and resins as described on pages 3-3 and 3-4 of Licensee's Spent

! Fuel Pool Modification Environmental Impact Evaluation are i

referred to?

Interroratory No. 11 - Do you assert that (other than the old racks removed from the spent fuel pool) there will be an increase in the level of generated wastes due to the

! proposed modification?

Interrogatory No. 12 - If the Answer to Interrogatory _

I No. 11 is anything other than an unqualified no, state the level and source of wastes which you assert will be increased and state the scientific basis for the assertion, Interroratory No. 13 - If the answer to Interrogatory l No. 11 is anything other than an unqualified no, state the materiality to this proceeding of the asserted increase in wastes generated.

Interreratorv No. 14 'Jith respect to Contention 13a, do you assert that the borated water will have corrosive effects on materials in the spent fuel pool?

Interroaatorv No. 15 - If the answer to Interrogatory l

No. 14 is anything other than an unqualified no, state the

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• type of materials (by alloy) and its source within the pool which you assert will suffer corrosive effects and

{ state the scientific basis for the assertion and the mechanisms by which the corrosion is to occur.

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Interroestory No.

_11 - If the answer to Interrogatory No.14 is anything other than an unqualified no , state what specific analyses you assert are necessary.

'li Interroestory No.

17 - With respect to Contention 13b, identify the specific effects you assert are likely to occur, identifying in detail the mechanisms and scientifi c basis for any asserted effects.

Interrogaterv No.

18 - With respect to Contention 13c, do you assert that materials within the spent fuel pool will be subject to electrolytic corrosion?

Interroestorv No.

19 - If your answer to Interrogatory

! No. 19 is anything other enan an unqualified no, state

[ specifically the alloys you claim will be subject to such

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1 electrolytic effects and specify the scientific basis for such an assertion and the mechanism by which an electrolytic cell will be created in the pool.

Interroestorv No. 20 - With respect to Cententien i 13f, what cerrosive effect, if any, do you assert will result from any asserted build up of crud layers?

Interroeatorv No. 21 - With respect to Contention 13f, what thickness of crud layers do you contend will build up?

t Interroaatorv No. 22 - With respect to Contentien 13f, specify the mechanism which you assert will result in I

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. v. i the formation of aeracion cells and specify the scientific basis for any such claimed =echanism.

Respectfully submitted, Steven E. Keane David A. Baker By A* -

David A. Baker Of Counsel F01.EY & LARO:iER 777 East k'isconsin Avenue Milwaukee, ~41sconsin (414) 271-2400 l .

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