ML20126D486
| ML20126D486 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/18/1992 |
| From: | Repka D, Reynolds N NORTHEAST NUCLEAR ENERGY CO., WINSTON & STRAWN |
| To: | CO-OPERATIVE CITIZEN'S MONITORING NETWORK, INC. (CCMN |
| References | |
| CON-#492-13474 OLA, NUDOCS 9212280012 | |
| Download: ML20126D486 (15) | |
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WTED CORRESPONDENCE Nt3E M D December lif,'C 1992 Uti1TED STATES OF AMERICA
'92 DCC 21 Pc> 3j HUCLEAR REGULATORY COMMISSION
,1ro um u liffflEE T11 ATOMIC SAIETY AND LICEH1U4G BOARD 6iv6
.iiNUi u ;. hi e In the Matter of
)
- g
)
NORTilEAST NUCLEAR ENERGY CO.
)
Docket No. 50-366-OLA
)
(Spent Fuel Pool Design)
(Millstone Nuclear Power Station,
)
Unit No. 2)
)
110RTilEAST NUCLEAR ENERGY COMPANY'S INTERROGATORIES-AND BEQUP&TE.FOR P29J21!CI1QN OF DOCUMENTS Pur suant to 10 C. F. R. SS 2. 7 4 0, 2. 74 0b, and-2. 741, as modified by the Atomic Safety and Licensing Doard's - November 24, 1992 4
Memorandum and Order regarding discovery (at 4-5),
Northeast t
Nucicar Energy Company
("NNECO")
hereby requires Cooperating Citizens Monitoring Network ("CCMH") to respond to the following interrogatories and produce the document requested below.
These interrogratories and document requests relate to CCMN's Contention-1, as admitted in this proceeding, and to the-supporting
.i Declaration of Dr. Michio Kaku, dated August 23, 1992.
v INSTRUCTIONS AND DEFlNITIONS A.
Each interrogatory should be answered separately.
The responses shall include all portinent information known to CCMN, as Wefined below, or to Dr. Kaku.
B.
Each interrogatory shall be answered fully, in writing, under oath or affirmation.
To the extent that CCMN'does not have
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4 specif_ic, complete, and accurato information with which to answer any interrogatory, CCMN should so stato, and the interrogatory should be answered to the extent information is availablo.
C.
Requests for documents should be answered by providing a list, orgar,12 ed by request
- number, identifying all documents responsive to the request.
In addition, CCMN should produce a copy of each document requested.
The copy should be in the f orm and condition in which the document oxists on the dato of service of this request, and shall include all comments, notes, remarks, and other material that may have been added to the document after its initial preparation.
Documents produced in response to the royuosts below should be mailed to the undersigned counsel for illlECO.
D.
The word " document" as used herein means any written matter, whether produced, reproduced or stored on paper, cards, tapes, disks, bolts, charts, film, computer storage devices or any:
other medium and shall includo, without limitation, hooks, reports, studies, statomonts, speeches, notebooks, agreements, appointment calendars, working papers, manuals, memoranda,.
notes, procedures, orders, instructions,. directions, records, correspondence,
. diaries,.
plans,.
. diagrams, drawings,.
periodicals, lists, telephone logs, minutes, and photographs,
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and shall also include, without limitation, originals, copics (with or without notes or changes thereon) and drafts.
E.
" CCM!1" means in the context of this discovery request:
Cooperativo citizen's Monitoring tietwork, _or any of : its L
- agents, employees, consultants,-
contractors, technical advisors, reprosentatives or other persons acting for-or on behalf of all or any of them, or at their direction and control, or in concert with or assisting them.
F.
dIdentify" when used in reference to a natural person means to not forth the following:
a.
namn; b.
laut Known residential address; c.
last known business address; d.
last employer; n.
title or position; i.
f.
area of responsibility; and g.
business, professional,-or other relationship with CCMtl.
G.
" Identify" when used in reference to a document means'to set i
forth tho following:
a.
its title;
. t b.
Its subject matter;-
.c.
its date; i t i
a ei.,-
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Its author; e.
its addressee; f.
its file
' designation or other identifying designation; and l
g.
its present location and present custodian.
I 11.
These interrogatories and document requests shall be continuing in nature as required by 10 C. F. R.. S 2.740(e).
- Thus, any time CCMN obtains information that renders any previous response-incorrect or incomplete, or which' indicates that a response was incorrect or incomplete when made, CCMN-must supplement its previous response.
Such supplements should be provided in a timely fashion.
GENERAL INTERROCATORIES/REOUESTS FOR DOCUMENTS G-1 Identify the
- name, profession, employer,. and area of professional c::pertise of each person whom CCMN expects to call as a witness,- including any expert. witness, at the hearing on this matter.
G-2 Identify;the subject matter on which each witness lis expected to-testify at the hearing.. -. - - - ~. -.. -..
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i G-3 Identify all documents, and all portinent pages or parts
]
1 thorJof, that each witness will rely upon or will'otherwiso uso for his/her testimony at the hearing.
t G-4 Provide copios of all documents identified in response to G-3 i
above.
)
G-5 Identify the educational and scientific oxperience of each.
witness identified in G-1 abovo.
G-6 Identify all persons known to CCMii, and with whom CCMil will consult or roly, or_ with whom CCMit has consulted or rolled upon, regardless of whether they will be called as a witness, i
who have knowledge with respect to:
l G-6.1 The revised til1ECO criticality analysis used to support storago of' spont fuel in the Millstone Unit tio.
2 spent-fuel
- pool, Regions A.
and B
(as designated by Amendment 158,- issued on Juno 4,
1992).
This includes the Monto Carlo calculations i
performed by ill4ECo ' and/or - its contractors, as well as-the use, or failure to use a-vertical buckling term.
G-6.2 The state of_.Boraflex degradation in the Millstone-I Unit 110. _2 spent fuel pool.
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G-6.3 Experimental or observed evidence with respect to Boraflex degradation at any other nuclear f acility.
G-6.4 Monte Carlo / KENO analytical techniques generally or as they are applied to nuclear plant opent fuel pools.
G-7 With respect all persons identified in response to G-6 above G-7.1 Describe the nature of each communication, conversation, or consultation with such individual,-
and when it occurred.
G-7.2 Describe the information received-from such individual.
G-7.3 Identify each letter, memorandum, - tape, note, or other record related to each conversation, consultation, correspondence, or other communication with such individual.
G-7.4 Provide a
copy. of any document. identified in-response to G-7.3.
SPECIFIC INJERROGATORIES/REOUEST FOR DOCUMENTS The following interrogatories and requests for documents are directed to-specific statements made;by Dr. Kaku in his~ August 23 1992 Declaration.
References are made to' numbered pages and numbered paragraphs-in the Declaration.
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S-1 Dr. Kaku states (p.
2, 1 2) that he " road some, but not all, of the documents concerning flortheast's (sic] Utility's (sic) roarrangement of the spent fuel pool for Millstone Unit 2."
Picaso identify the specific documents concorning Amendmont 158 and the supporting criticality analysis that woro " road" and that formed the basis for the statomonts made in the Declaration.
)
S-2 Dr. Kaku hypothesizes (p.
3, T 6) that the K,, calculation for i
the spent Iucl pool rearrangemont "may not reduce the neutron reactivity to below the lovel required by the llRC because of unexpected degradation of the Boraflex boxes and errors made in the criticality study."
Please describo Dr.
Kaku's or CCMil's knowledge of the scope of that degradation at Millstone Unit flo.
2.
S-3 Dr. Kaku asserts (p.
3, 1 7) that "(ojnly 16% of the Doraflex boxes have actually been examined, which is too small to give an accurate picture of the true nature of the degradation."
Please clarify whether this assertion is correct in light of the comment by the' Licensing Board that "Dr. Kaku is mistaken about the sampling."
Soo Memorandum and Order, p. 29, n.
16.
S-4 Dr. Kaku states (p.
4, 1 7) that "moro Doraflex degradation has occurred than expected, or that Boraflex gaps have been concentrated in cortain areas."
Please describe where Dr.
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Kaku believes that Boraflex gaps have been concentrated, provide the basis for this
- belief, and explain the significance attached to such concentration.
S-5 Dr. Kaku expresses (p.
4, 1 8) concern with regard to the "large amount of crosion, beyond the gaps found in earlier observations at other reactor sites."
S-5.1 please quantify the term "large amount."
S-5.2 Please identify the "other reactor sites" to which reference is made, and identify the approximate dates when said gaps where found at these sites.
S-5.3 Please explain whether Dr. Kaku believes that these gaps are greater than those assumed in the NNECO criticality analysis supporting Amendment 158.
S-6 Dr. Kaku concludes (p.
4, i 8) that "the computer calculations may be totally obsolete," that "[t]he neutron reactivity studies may not be modeling the actual state of the Boraflex boxes," and that "all computer programs are suspect."
S-6.1-Please specifically-identify- -the particular
" computer calculations,"
=" neutron reactivity studies,"
and
" computer
--programs" to which reference is made. L 1
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44 S-6.2 Please explain whether Dr. Kaku has ever reviewed the Monte Carlo criticality analysis relied upon to support Amendment 158 for the Millstone Unit No. 2 spent fuel pool.
Kaku states (p.
4, 5 9 (first instance))- that the-i diffusion method for calculating neutron reactivity "is not ideally suited in calculating neutron reactivity with thin, highly absorbing [ sic) boxes" because "[t]here are too many hidden assumptions which may break down in the presence of highly absorbing (sic) boxes."
Please identify the relevance Dr.'Kaku sees in the diffusion method as it relates to the revised criticality analysis now relied upon by NNECO for Regions A and B of the Millstone Unit No. 2 spent fuel-pool.
S-8 Dr. Kaku refers (p.
5, i 10(a)) to " Fick's principle that the flux is proportional to the gradient of the neutron density" and concludes that it "may be violated in the presence of highly absorbing (ric) Boraflex boxes".apparently.because of "large uncertaintie in the gradient of the neutron density."
Please describe Dr. Kaku's understanding of the relationship of Fick's principle to the criticality analysis performed by-3 NNECO to support Amendment 158 for Regions A and B of the Millstone Unit No. J spent fuel pool.
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S-9 Dr. Kaku states (p.
6, 1 10(c)) that "the neutron calculations are performed on the multi-group equations," and-that the variable "N,
the number of partitions of energy" in those equations "should be as high as possible, preferably-in the thousands."
Dr. Kaku also states that the N variable should be equal-to "200 to 500 at the very minimum, rather than 27, which is too small to take into consideration the small edge effects that may occur around the boxes."
Finally, Dr. Kaku concludes that "in the presence of very high levels of neutron absorption, the concept of buckling becomes less relevant and the neutron diffusion equation itself begins to break down."
S-9.1 Please explain how much error Dr. Kaku believes-is introduced in a K,,
calculation by "small edge a
offects "
S-9.2 Please explain whether Dr. Kaku believes that the
" error" in K,n for the current Millstone Unit No. 2 spent fuel pool criticality-analysis (Regions A'and B) will be reduced by using N=200 or N=500.
S-9.3 Please explain whether Dr. Kaku knows if a vertical buckling term was used in the' revised-criticality calculation for Amendment' 158, addressing Regions A and B.
S-9.4 Please-discuss in detail-Dr.-Kaku's basis.'for the.
comment that ~" buckling becomes.less relevant," and
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4 how this affects the validity of the results of the Amendment 158 criticality calculation.
S-9.5 Please discuss, in the context of the levels of neutron absorption present in a spent fuel pool with Boraflex absorbers, the basis for Dr. Kaku's statement that the
" diffusion equation itself begins to break down."
S-10 Dr.
Kaku states (pp.
6-7, S
10(d))
that
" Monte Carlo simulations can, in fact, provide reasonable estimates of neutron reactivity,"
but that "{bjecause of the unusual geometry introduced in Region A and B, one suspects that an unusually large number of iterations (i.e., histories) will be necessary to provide any reasonable approximation."
S-10.1 Please describe why Dr.
Kaku believes that the geometry in Region A and B of the Millstone Unit No. 2 spent fuel pool is " unusual."
S-10.2 Please discuss why "an unusually large number of iterations
[ histories) will be necessary,"
and quantify "an unusually large number."
S-10.3 Please identify what constitutes a
" reasonable approximation," and its basis.
S-10.4 Please describe Dr.
Kaku's understanding of the number of histories of the Monte Carlo calculation _.
l performed for 1113ECO in its criticality analysis supporting Amendment 158 for Millstone Unit No.
2.
S-11 Dr. Kaku states (p.
7, 1 11) "that there are a large number of assumptions that are hidden behind any neutron reactivity calculation," and "that too many approximations are made-in the computer algorithm to give reliable figures."
S-11.1 Recognizing that the N!1ECO criticality analysis is j
based upon Monte Carlo analytical techniques, please identify the specific
" assumptions" and
" approximations" that are of concern.
S-11.2 Please explain the meaning of the term " reliable figures,"
identify the particular
" figures" of concern, and identify the standard of " reliability" that should be achieved and why such a standard should be achieved.
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S-12.To the extent that the information provided'in responses to S-1 through S-11 above rely upon any documents, identify these documents and provide copies.
Respectfully submitted,
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Nicholas S. Reynolds David A.
Repha WINSTON & STRAWN 1400 L Stroet, N.W.
Washington, D.C.
20005 (202) 371-5700 Attorneys for Northeast Nuclear Energy Company Dated at Washington, D.C.
this 18th day of December, 1992 I
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Decembefjkh,I 1992 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'92 LIC 21 P5 :11 ilEFORE THE ATOMIC SAFETY AND LICENSING BOAllQ
.j ; c a y i t...
MK[!% s iovM
_ h t N! "
In the Matter of
)
)
NORTilEAST NUCLEAR ENERGY CO.
)
Docket No. 50-336-OLA
)
(Spent Fuel. Pool Design)
(Millstone Nuclear Power Station
)
Unit No. 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NORTilEAST NUCLEAR ENERGY COMPANY'S INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS" have been served on the following by deposit in the Ur.ited States Mail, first class, or as indicated by an asterisk
(*),
by Federal Express overnight delivery, this 18th day of December, 1992:
Ivan W. Smith Jerry R.
Klino chairman Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Charles N. Kelber.
Adjudicatory File Administrative Judge Atomic Safety and. Licensing Atomic Safety and Licensing Board Panel Board U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory
' Commission Commission Mail Stop EW-439 Washington, D.C.
20555 Washington, D.C.
20555 John T.
llull, Esq Office of Commission Appellate Office of-the General Counsel-Adjudication U.S.
Nuclear-Regulatory U.S.
Nuclear Regulatory Commission-Commission Washington, D.C.
20555 Mail 1 Stop 16-G-16 OWFN Washington, D.C.
20555
o i
Richard H. Kacich Office of the Secretary Director, Nuclear Licensing Attention: Chief, Docketing and flortheast Utilities Service Section P.O.
Box 270 U.S. Nuclear Regulatory liartford, CT 06101 Commission Mail Stop 16-G-16 OWFH Cooperative Citizen's Washington, D.C.
-20555 Monitoring Network (original + 2 copies)
P.O.
Box 1491 New Haven, CT 06506 Mary Ellen Marucci*
104 Brownell Street Professor Michio Kaku*
New flaven, CT 06511 Department of Physics City Collego of New York 138th Street and Convent Avenue New York, NY 10031 5
ts David A.
Repka
\\
Counsel for Northeast Nuclear Energy Company I
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