ML20063J744

Discovery Questions on New Contentions Accepted by ASLB 820814 Order.Related Correspondence

ML20063J744
Person / Time
Site:	Midland
Issue date:	08/25/1982
From:	Sinclair M SINCLAIR, M.P.
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8209020526
Download: ML20063J744 (3)

Text

%* rrnp CORIlDPO?mWO' e'

Mary' P. Sinel .KETEC 5711 Summerse .

Midland, MI 48640 y y -1 N1114 JLwJu f00 ttG SERVCk' -

Consumers Power Co. BRANCH 1945 West Parnall Road Jackson, MI 49201 In the Matter of: )

) Docket Nos. 50-329 CONSUMERS POWER COMPANY, ) 50-330

)

Operating License (Midland Plant, Units 1 and 2) )

DISCOVERY OUESTIONS FOR CONSUMERS POWFB CO.

ON NEW CONTENTIONS ACCEPTED BY BOARD ORDER, g AUGUST 14, 1982 August 25, 1982 r These interrogatories are illed in accordance with the Board order of August 14.

. m 1982, tollowing the pre-hearing conference of Agust 12-13, 1982.

Terms are detined as follows:

"Staft"--means any consultants or expert witnesses retained by the Nuclear Regulatory Commission (NRC) for any issue discussed as well as the regular NRC staff.

" Documents"--shall include reports, studies, notes, worksheets, meeting reports and summaries, correspondence, telecons or other communications.

1.

Contention 3 questions the adequacy of the methodology in the DES for determin-ing the possibility of severe accidents at the Midland nuclear plants, and recommends

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NUREG/CR'/2497, as a better basis.

Questions:

1. Have any accidents occurred at Palisades and Big Rock that were a part of '

the data base tor NI' REG /CR/2497, June,1982 ?

2. It so, describe them, r-

3. If so, explain if they were initiated by:

a operator error

b. non-safety equipment impacting on safety equipment '

M"EC-8209020526 820825 D5D3

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c. equipment malfunction

d. not believing readings of non-safety grade instruments

c. Instruments giving the wrong reading

f. maintenance during operation that disabled the safety systems -

g. minor mishaps

h. failure of "afety systems

1. lack of QA control during operation II. Contention 5 deals with questions about the adequacy of the basis of the data in the Atonthly Cooling Pond Performance Tables on the cooling pond provided in the ,

DES (4-7, 4-8). .

Questions:

'l. Provide all internal correspondence on the cooling pond between Consumers Power Co. , Bechtel and the NRC. .

2. What data base did you rely on to arrive at 880 acres as an adequate size for a cooling pond for the Slidland plants?

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3. Who supplied this data base?

4. What experience in cooling pond operation are you relying on for your assurance that this pond is workable and adequate to its tasks ?

5. What qualifications did the statf have that you relied on for determining the f adequacy ot this pond ? Provide information on their backgrounds in terms of not a 1

only their ed ucation, but also their experience for this evaluation.

6 Have you sent any observers to the Dresden pond which was identified by the NRC stait as most closely identical in performance to the %tidland plants because of .

climate and meteorological conditions?

7. If so, when did they make their observations ?

8. If so; please provide their report.

l 9. What.are the differences in size between the Dresden pond and the Slidland plant ?

f -

10. Are there one or two reactors at Dresden ?

11. What will be the differences in heat load during full operation between the D

Tlidland nuclear plants and Dresden?

12. Explain the source of data for each factor in the \tonthly Cooling Pond Per-formance Tables.

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13. What studies have been made to determine the diect of the fogging on the people in the area and the Bullock Creek elementary school? (Dr. Edward Epstein, the meteorologist from the University of Michigan who was our expert witness on togging, discussed this at n' seminar of the nuclear engineering department in October, 1972, and said, "I don't know how those people are going to live.")

Contention 7 deals with the effects of low doses of radiation on polymer cable insulation and jacketing and the synergistic effects of radiation and temperature in degrading those materials.

Questions:

1. Send all correspondence with the hTC on this study and its implications for the Midland nuclear plants.

2 What percentage of the plant's electrical wiring system is not accessible to inspection once the plant is started ?

3. For what percentage of the estimated lifetime of these plants can the cabic insulation be expected to retain its integrity before its degradation by synergistic effects makes it unsafe ?

Respectfully submitted, J2 -u i n dhw Mary P. Sigair cc:

l Secretary, U.S. Nuclear Regulatory Commission Michael 1. Miller, Esq.

William Paton, Esq.

Mr. Wendell Marshall Ms. Barbara Stamirls James E. Brunner P.S. Di$~covery questions for Contentions 6, 8 and 16 will be submitted at a later date.

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