ML20125A626

Outline of cross-examination Submitted by Util to Be Used to Extent That Util 790630 Objections to Intervenor Lower Alloways Creed Township Testimony Are Not Sustained. Certificate of Svc Encl

ML20125A626
Person / Time
Site:	Salem
Issue date:	06/30/1979
From:	Wetterhahn M CONNER, MOORE & CORBER
To:
References
NUDOCS 7908030529
Download: ML20125A626 (6)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

PUBLIC SERVICE ELECTRIC & GAS ) Docket No. 50-272 COMPANY, et al. ) (Proposed Issuance of

) Amendment to Facility (Salem Nuclear Generating ) Operating License Station, Unit 1) ) No. DPR-70)

LICENSEE'S OBJECTIONS TO LOWER ALLOWAYS CREEK TOWNSHIP'S PROFFERED TESTIMONY On April 25, 1979, counsel for Lower Alloways Creek Township (" LACT") filed a document entitled " Response to the Atomic Safety and Licensing Board Order dated April 18, 1979," transmitting the " Testimony of Richard E. Webb, Ph.D.

in Respect to Board Question #3 of Order Dated April 18, 1979." On June 12, 1979, LACT submitted the written testimony of Earl A. Gulbransen, Ph.D. which purported to relate to all three of the Board's questions. As discussed below, Licensee, Public Service Electric & Gas Company, ej al.,

objects to the proposed testimony of Drs. Webb and Gulbransen.

I. The Testimony of Dr. Gulbransen Licensee objects to the proffered testimony of Dr.

Gulbransen as beyond the scope ' "- nnard's questions, as L ~~"-

beyond the scope of the issue ATE DOCUMENT i constituting an attack on the into sysdocument previously entered 1

" M9dF03o5a7 7fdfdN g j32 No. of pages, J

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

PUBLIC SERVICE ELECTRIC & GAS ) Docket No. 50-272 COMPANY, et al. ) (Proposed Issuance

) of Amendment to (Salem Nuclear Generating ) Facility Operating Station, Unit 1) ) License No. DPR-70 )

LICENSEE'S OUTLINE OF CROSS-EXAMINATION If and to the extent that " Licensee's Objections to Lower Alloways Creek Township's Profferred Testimony," dated June 30, 1979, are not sustained, the following represents Licensee 's out.1.ine intended cross-examination:

I. Test. .ty of Dr. Earl A. Gulbransen

1. Qualifications of the Witness to testify with recard to

a. The design and operation of the Salem Generatino Station

b. The design, construction and operation 'f the fuel pool and racks for Salem Unit 1 i

l c. The cause and effects of hypothesized reactor l

accidents on the spent fuel pool

d. The TMI Event

e. NRC ECCS Acceptance Criteria l

l 2. Bias and Prejudice

3. Basis for Testimony Regarding the Three Mile Island event l

l a. Course of the event

b. Basis for conclusions regarding cladding effects

c. Basis for recommended " procedures," including hydrogen embrittlement , hydrogen in the cooling water and4 4 0 d Ix' r I ls<s necessity for hydrogen gauges. 0 gpg 3

&f0 am,

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4. Knowledge of the NRC's ECCS Acceptance Criteria and 1/

Comparison with Testinony.

5. Basis for testimony regarding cladding behavior in reactors, particularly Salem Generating Station, Unit 1.

l

6. Basis for conclusions regarding the safety of the spent fuel pool and the consequences of nuclear accidents.

II. Testimony of Dr. Richard Webb

1. Qualifications of the Witness to Testify Regarding:

a. Plans to store fuel in the spent fuel pool in the Salem Generating Station

b. Accident evaluation and probability

c. The design, construction and operation of Salem Gene ating Station, including the spent fuel pool

d. The " loss of water accident"

e. A permanent fuel repository at Salem

2. Bias and prejudice of the Witness

3. Basis for evaluation of a " Loss of Water Accident," including its hypothesized consequences.

4. Basis for evaluation of conceivable possibilities for causing a " Loss of Water Accident"

5. Basis for evaluation regarding criticality accidents

6. Basis for evaluation regarding reactor accidents that could cause " Loss of Water Accidents," including effect on and actions by the operating crew

-1/ Counsel for LACT should assure that a copy of the NRC's ECCS Acceptance Criteria are supplied to the Witness in advance of the hearing to facilitate cross-examination.

440 184 m __

_3

7. Basis for evaluation of consequences of reactor accidents and " Loss of Water Accidents"

8. Basis for statements regarding probablistic risk assessment and need for future studies

9. Basis for statements regarding a permanent spent fuel repository at Salem

10. Basis for statements regarding impracticality of theoretical analysis and experiment verification III. Testimony of the NRC Sta!!f

1. Qualifications of the Witnesses to Testify

2. Basis for statements related to the effect of the TMI accident on the TMI spent fuel pool

3. Basis for statements regarding causes of the TMI incident and the chronology of events

4. Basis for statements regarding design and operational differences between TMI and Salem Unit 1

5. Basis for statements regarding hypothesized series of events at Salem Unit 1 in partial response to Board Question 3

6. Basis for statements regarding effect of hypothesized releases to the Auxiliary Building at Salem Unit 1 on the operation of the spent fuel pool

7. Basis for statements regarding effect of hypothesi;ed releases into the Auxiliary Building on systems in the Fuel Handling Building at Salem Unit 1

8. Basis for conclusions regarding the Staff's evaluation resulting from the Board's questions on the proposed amendment to increase the spent fuel capacity 440 185

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. 9. Basis for' statements, evaluations and analysis contained in NUREG-0560 as they apply to the Board's questions Respectfully submitted, CONNER, ORE & CORBER - ,

// b' ' ,

Mark J. Wetterhahn Counsel for the Licensee June 30, 1979 440 186

t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board a

In tWe Matter of )

)

PUBLIC SERVICE ELECTRIC AND GAS ) Docket No. 50-272 COMPANY, et al. ) (Proposed Issuance of

) Amendment to Facility (Salem Nuclear Generating ) Operating License Station, Unit 1) ) No. DPR-70)

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Objections to Lower Alloways Creek Township's Proffered Testimony" and

" Licensee's Outline of Cross-Examination," dated June 30, 1979, in the captioned matter, have been served upon the following by deposit in the United States mail this 30th day of June, 1979:

Gary L. Milhollin, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety Licensing Board Panel and Licensing Board U.S. Nuclear Regulatory 1815 Jefferson Street Commission Madison, Wisconsin 53711 Washington, D.C. 20555 Ft. Lester Kornblith, Jr. Barry Smith, Esq. ,

Member, Atomic Safety and Office of the Executive Licensing Board Panel Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission '

' Washington, D.C. 20555 Washington, D.C. 20555  ;

Dr. James C. Lamb, III Richard Eluchan, Esq.

Member, Atomic Safety and Deputy Attorney General l Licensing Board Panel Department of Law and 313 Woodhaven Road Public Safety Chapel Hill, N.C. 27514 Environmental Protection l Section '

Chairman, Atomic Safety and 36 West State Street I Licensing Appeal Board Panel Trenton, N.J. 08625 l U.S. Nuclear Regulatory l commission l Washington, D.C. 20555  !

A40 187 l x _ __

_ )

Richard Fryling, Jr., Esq. Carl Valore, Jr., Esq.

Assistant General Solicitor Valore, McAllister, Aron Public Service Electric & Westmoreland

& Gas Company Mainland Professional Plaza 80 Park Place P. O. Box 175 Newark, N. J. 07101 Northfield, N. J. 08225 Keith Onsdorff, Esq. Office of the Secretary Assistant Deputy Public Advocate Docketing and Service Section Department of the Public Advocate U.S. Nuclear Regulatory Division of Public Interest Commission Advocacy Washington, D. C. 20555 Post Office Box 141 Trenton, N. J. 08601 June D. MacArtor, Esq.

Deputy Attorney General Sandra T. Ayres, Esq. Tatnall Building, P. O. Box 1401 Department of the Public Advocate Dover Delaware 19901 520 East State Street Trenton, N. J. 08625 Mr. Alfred C. Coleman, Jr.

Mrs. Eleanor G. Coleman 35 "K" Drive Pennsville, New Jersey 08070 p

'I I /

Mark J/pletterhahn i

440 188