ML20138L895
| ML20138L895 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/28/1985 |
| From: | Reis H FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J. |
| References | |
| CON-#485-962 OLA-2, NUDOCS 8510310434 | |
| Download: ML20138L895 (11) | |
Text
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UEIATED CnHerwoNne (3
UNITED STATES OF AMERICA SD'
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In the Matter of
)
Docket Nos. 50-250-OLA-2
)
50-251-OLA-2 FLORIDA POWER AND LIGHT COMPANY
)
)
(Turkey Point Nuclear Generating
)
(Spent Fuel Pool Expansion)
Units 3 & 4)
)
)
LICENSEE INTERROGATORIES TO CENTER FOR NUCLEAR REPPONSIBILITY AND JOETTE LORION Florida Power & Light Company (Licensee) hereby serves its First Set of Interrogatories to the Center for Nuclear Responsibility and Joette Lorion (Intervenors) pursuant to 10 C.F.R. S 2.740b.
Each interrogatory is to be answered fully, in writing, and under oath or affirmation within 14 days after service.
Each answer should clearly indicate the interrogatory to which it is intended to be responsive.
If Intervenors after exercising due diligos.ce, cannot answer any portion of any of the interrogatories in full, Intervenors shall so state, shall answer the interrogatorics to the extent possible, shall explain in detail the inability of the Intervonors to answer the remainder of the interrogatories, and shall state when Intervenors expect to be able to answer any unanswered portions.
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The interrogatories are divided into two sections.
Section I consists of five (5) general interrogatories which should be answered for each and every contention admitted by the Board in this proceeding, (i.e. contentions 3,4,5,6,7,8 and 10).
Section II consists of interrogatories that are specific to a particular contention.
I.
General Interrogatories (to be answered for each and every admitted contention.)
(a)
State whether Intervenors intend to call any person or persons as witnesses, including expert witnesses, in this proceeding in support of each contention and, if so, identify any such person or persons.
(b)
Provide summaries of the views, positions, or proposed testimony on each contention of all persons identified in response to Interrogatory I(a) that Intervenors intend to present during this proceeding.
(c)
Identify all documents, books, reports and papers that Intervenors intend to employ or rely upon in presenting their direct case on each contention.
(d)
Identify all documents, books, reports and papers that Intervenors intend to employ or rely upon
in conducting cross-examination of NRC Staff 6
and Licensee witnesses testifying in connection with each contention.
(e)
If the representations made in any contention or in the bases for any contention are based in whole or in part on any documents prepared by the Licensee or the NRC Staff which Intervenors contend are deficient, identify the documents and identify any particular portions thereof Intervenors regard as deficient, explain in what way they are deficient, and identify all documents, 4
studies, analyses, calculations or expert opinions, relied upon by Intervenors that provides support for Intervenors claim that a deficiency exists.
II.
Specific Interrogatories 1
(a)
With respect to contention 3 (1)
Identify the specific portions of 10 C.F.R. Parts 20, 50 and 100 that Intervenors claim could be exceeded as a result of a cask drop accident at Turkey Point.
(2)
Please specify how, why and in what manner the relevant portions of 10 C.F.R. Parts 20, 50 and 100 will be exceeded and identify any books, papers or documents and any persons i
1.
or expert witnesses that Intervenors claim 5
support this contention.
(b)
With respect to contention 4 (1)
In its response to NRC Staff Question No.
7, which is attached to a letter dated October 5,
1984, from J. W. Williams, Jr. to Steven A. Varga, the Licensee presented a radiological analysis of a postulated spent fuel pool boiling event at Turkey Point.
Identify any aspect of this radiological analysis which the Intervenors contend is not site specific for Turkey Point and identify any documents, studies, analyses, calculations or expert opinions which Intervenors claim provide support for such contention.
(2)
For each aspect identified in your answer to Interrogatory II(b)(1), state whether or not the assumptions used for Turkey Point were appropriate.
If not appropriate, please provide the reason for your answer.
(3)
Identify the specific portions of 10 C.F.R. Parts 20 and 100 that Intervenors claim could be exceeded as a result of a spent fuel pool boiling event.
Please specify how, why and in what manner the relevant L
portions of 10 C.F.R. Parts 20 and 100 will 5
be exceeded and identify any books, papers or documents and any persons or expert witnesses that Intervenors claim support this contention.
(c)
With respect to contention 5 (1)
Do Intervenors contend that the current rerack design for the storage of fuel rods is deficient?
If yes, provide the grounds for this contention and identify any documents, studies, analyses, calculations or expert opinions which Intervenors rely on to support such contention.
(d)
With respect to contention 6 (1)
Do Intervenors contend that the Staff Safety Evaluation does not correctly analyze or consider the deterioration of spent fuel pool materials or structure?
If yes, identify the specific sections of the Staff Safety Evaluation that Intervonors contend are deficient and explain how these sections are deficient.
(2)
Do Intervenors contend that the Licenseo Safety Analysis (as supplemented by answers
to NRC Staff questions) does not correctly s
analyze or consider the deterioration of spent fuel pool materials or structure?
If yes, identify the specific sections of the Licensee Safety Analysis (as supplemented) that Intervenors contend are deficient and explain how these sections are deficient.
(3)
Please explain how increased exposure, decay heat and radiation levels in the spent fuel pool will result in deterioration of fuel cladding.
Describe the specific physical phenomena involved.
(4)
Identify any books, papers or documents and any persons or expert witnesses that Intervenors contend support the views set forth in response to interrogatories II(d)(1)-(3)
(c)
With respect to contention 7 (1)
Do Intervenors have any information concerning the radiation exposure incurred by workers involved in spent fuel pool re-racking at any other nuclear power plant.
If so, identify the nuclear plant involved, the information concerning the exposure levels of workers, and the source of Intervenors' information.
a (2)
In the attachment to a letter dated August s
24, 1984, from J. W. Williams, Jr. to Steven A. Varga, the Licensee identified its proposed actions to maintain doses ALARA during the spent fuel pool expansion for Turkey Point.
This attachment also stated that the Licensee reanalyzed the occupational radiation exposure expected as a result of this expansion, and lowered the expected exposure from 88-130 person-rem to 59 person-rem.
(a)
Do Intervenors contend that the proposed actions in this attachment are not sufficient to maintain doses ALARA?
If yes, please explain why Intervenors contend that these actions are not sufficient to maintain doses ALARA.
(b)
Do Intervenors contend that an estimate of 59 person-rem for the Turkey Point spent fuel pool expansion indicates that the Licensee is not proposing sufficient actions to maintain occupational radiation exposures ALARA?
If yes, please provide the basis for Intervenors answer.
(f)
With respect to contention 8 s
l-l, i
f (1)
Identify the " numerous documents" referenced in basis (a) for contention 8.
(2)
Identify the specific sections of all documents t
listed in (1) above that support the statement i
i that " water in spent fuel pools should normally be kept below 122 degrees F."
I (3)
Explain why Intervenors contend that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not adequate time to provide makeup water to the spent fuel pool in the event of a loss-of-cooling accident.
f (g)
With respect to contention 10 (1)
Identify the requirements of ANSI N16-1975 L
that will not be met if the spent fuel pool
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capacity is increased and explain.how and f
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why the requirements will be violated.
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(2)
Identify the specific portions of 10 C.F.R.
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Part 100 that will be exceeded by any potential t
radiation release from the spent fuel pool.
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i Respectfully submitted,
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CO-COUNSEL Harold F. Reis " ~
Norman A. Coll i
t Steel. Hector & Davis 4000 Southeast Financial Newman & Holtzinger, P.C.
Center 1615 L Street, N.W.
Miami, FL 33131-2398 Washington, D.C.
20036 (305)-577-2800 (202) 955-6600 October 28, 1985 1
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
FLORIDA POWER & LIGHT COMPANY )
Docket Nos. 50-250 OLA-2
)
50-251 OLA-2 (Turkey Point Plant,
)
Units 3 and 4
)
(Spent Fuel Pool Expansion)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee Interrogatories to Center for Nuclear Responsibility and Joette Lorion" in the above captioned proceeding, together with a Notice of Appearance of Counsel, were served on the following by deposit in the United States mail, first class, properly stamped and addressed, on the date shown below.
Dr. Robert M.
Lazo, Chairman Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Emmeth A.
Luebke Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nucicar Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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Office'of Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Chief, Docketing and Service Section
.(Original plus two copies)
(
Joette Lorion 7269 SW 54 Avenue-Miami, Florida 33143 Mitzi A. Young Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
Norman A. Coll l
Steel-, Hector & Davis 4000 Southeast Financial Center f
Miami, Florida 33131-2398 l
tOk vhb Harold F.
Reis l
Newman & Holtzinger, P.C.
1615 L Street, N.W.
l Washington, D.C.
20036 Dated:
October 28, 1985 i
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