ML20155B981
| ML20155B981 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 06/02/1988 |
| From: | Bauser M FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | Rich C RICH, C. |
| References | |
| CON-#288-6485 88-560-01-LA, 88-560-1-LA, OLA, NUDOCS 8806140039 | |
| Download: ML20155B981 (11) | |
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i UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING B4&RD0N -6 A9 51 CUtCI CT 3EdQ A? *
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In the Matter of: )
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FLORIDA POWER AND LIGHT COMPANY ) Docket No.: 50-335-OLA
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(St. Lucie Plant, Unit 1) )
) ASLBP No.: 88-560-01-LA LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR Florida Power and Light Company (Licensee) he-eby serves its first set of interrogatories to Campbell Rich (Intervenor) pursuant to 10 C.F.R. S 2.740b. Each interrogatory is to be answered separately, fully, in writing, and under oath or affir-nation within 14 days after service. Each answer should clearly indicate the interrogatory to which it responds.
The interrogatories are divided into two sections. Section I consists of five general interrogatories which should be an- H suered for each and every contention admitted by the Board in this proceeding. Section II consists of interrogatories that are specific to particular contentions.
I. GENERAL INTERROGATORIES (to be answered for each and every admitted contention):
l A. State whether Intervenor intends to call any person l
or persons as witnesses, including expert witnesses, in this I
proceeding in support of each contention and, if so, identify any and all such persons giving the name, address and professional qualifications of each.
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B. Provi.de summaries of the views, positions, or proposed testimony on each contention of all persons identified in response to interrogatory I.A. that Intervenor intends to present during this proceeding.
C. Identify all documents, books, reports, papers, studies, analyses and calculations that Intervenor intends to employ or rely upon in presenting his direct case on each contention.
D. Identify all documents, books, reports, papers, studies, analyses, and calculations that Intervenor intends to employ or rely upon in conducting cross examination of NRC Staff and/or Licensee witnesses testifying in connection with each contention.
E. If the representations made in any contention or in the bases for any contention are Lased in whole or in part on Intervenor's belief that certain docaments, books, reports, papers, studies, analyses or calculations, including but not limited to those prepared by the Licensee or the NRC Staff, are deficient, identify the documents, books, reports, papers, studies, analyses or calculations, and identify any particular portions thereof Intervenor regards as deficient; explain the way they are defi-cient, and identify all documents, books, reports, papers, studies, analyses, calculations or expert opinions relied upon by Inter-i venor that provide support for Intervenor's claim that a defi- l ciency exists.
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II. SPECIFIC INTERROGATORIES:
A. Admitted Contention 1 (originally Amended Petition Contention 3):
- 1. Identify the specific regulatory criteria of 10 C.F.R. Part 100 that Intervenor claims will be exceeded as a result of a cask drop accident at the St. Lucie 1 spent fuel pool.
- 2. Specify how, why, and in what manner the relevant portions of 10 C.F.R. Part 100, identified above, would be ex-ceeded.
- 3. Specify how, why, and in what manner the calcula-tion of radiological consequences from a cask drop accident is not conservative including
- a. precisely what uncertainties have not been bounded, why these uncertainties must be bounded, and how these uncertainties have not been properly bounded;
- b. what Intervenor means in the bases' reference to "uncertainty in the accident progression (fuel temperature after clad oxidation and fuel relocation occurs) and the uncer-tainty in fission product decontamination" and why it is necessary to consider such uncertainties; l
- c. precisely what regulatory requirements and/or guidance, if any, Intervenor believes were not complied with in performing the calculation, why compliance was necessary, l
and why the calculation failed to meet the regulatory require-l 1
ments and/or guidance, ,
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- d. precisely what_ assumptions were not conser-vative, and how and why those assumptions were not conservative, with particular reference but not limited to assumptions concern-ing accident progression.
- 4. Identify any and all documents, books, reports,
! papers, studies, analyses, calculations, or expert opinions which Intervenor claims provide support for this contention.
B. Admitted Contention 2-(originally Amended Petition Contention 4):
- l. Identify those accidents'which Intervenor believes are "similar in nature and effect" to a cask drop accident and state how and why they are similar.
- 2. Specify how, why, and in what manner the-presence of the temporary construction crane inside the fuel handling building to facilitate the reracking could' increase the.conse-quences of "a cask drop accident or an accident similar in nature and effect."
- 3. Specify how, why, and in what manner the presence of the temporary crane would contribute "to the potential for a heavy load drop in the pool" and "inhibit the ability of the existing cranes to operate, if needed, in any recovery action."
- 4. Identify the specific regulatory criteria of 10 C.F.R. Part 100 that Intervenor claims will-be exceeded as a result of a cask drop accident at the St. Lucie 1 spent fuel pool, if any.
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- 5. Specify how, why, and in wh.at manner any and all of.the relevant portions of 10 C.F.R. Part 100, identified in
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response to interrogatory II.B.4, above, would be exceeded.
- 6. Specify in what manner, if any, the calculation of radiological consequences from "a cask drop accident.or an accident similar in nature and effect" involving the temporary construction crane is not conservative.
- 7. Identify any and all documents, books, reports, papers, studies, analyses, calculations, or expert opinions which Intervenor claims provide support for this contention.
C. Admitted Contention 3 (originally-7. mended Petition Contention 6):
- 1. Does Intervenor contend that the NRC Staff in its Safety Evaluation has not adequately analyzed, calculated or otherwise considered the "materials deterioration or failure in materials integrity" of the spent fuel pool, part of the spent fuel pool or fuel cladding? If so, identify the specific sec-i tions of the Safety Evaluation that Intervenor contends are de- y l
ficient and explain why and how these sections are deficient '
i with specific reference to increased exposure to heat and radia-tion.
- 2. Does Intervenor contend that Licensee in its Safety Analysis Report, Rev. 1 (SAR), has not adequately analyzed, cal-culated or otherwise considered the "msterials deterioration or failure in materials integrity" of the spent fuel pool, part of the spent fuel pool or fuel cladding? If so, identify the 1
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. i specific sections of Licensee's SAR that Intervenor contends are deficient and explain how these sections are deficient with specific reference to increased exposure to. heat and radiation'.
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- 3. Identify any and all documents, books, reports, papers, studies, analyses, calculations, or expert opinions which Intervenor claims provide support for this contention.
D. Admitted Contention 4 (originally Amended Petition Contention 8):
- 1. Identify how "higher heat loads and increases in water temperature . . . could cause a loss-of-cooling acci- 7 dent."
- 2. Identify the systems the "reliability or testibil-ity" of which will be "challenge [d)" due to "higher heat loads ,.
and increases in water temperature" and explain how and why they will be challenged.
- 3. Identify the "numerous documents" where the NRC Staff has stated that the "water in spent fuel pools would nor-mally be kept below 122 degrees P."
- 4. Identify the specific sections in the documents referred to in the answer to interrogatory II.D.3. where the NRC Staff has made the statement regarding the 122 degrees P.
- 5. Identify the documents and specific sections there-in where it is stated that "after the reracking, the temperature of the water would rise to 152 degrees F on a normal basis, and could reach 182 degrees F with a full core load."
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- 6. Identify the causes for delay in the delivery of "make-up emergency water," referred to in the bases, the prob-ability of delay for each cause, and the duration of delay for each cause.
- 7. Identify any and all documents, books, reports, papers, studies, analyses, calculations, or expert opinions which Intervenor claims provide support for this contention.
E. Admitted Contention 5 (originally Amended Petition Contention 9):
- 1. Does Intervenor contend tl.at the design of the cooling system and/or electrical power system fails to meet appli-cable NRC requirements? If so, identify these requirements spe-cifically, explain how and why the cooling and/or electrical power system fails to meet each such requirement, and identify all documents, books, reports, papers, studies, analyses, cal-culations or expert opinions relied upon by Intervenor that pro-vide support for Intervenor's position.
- 2. Specify how and why the electrical power system for the St. Lucie 1 spent fuel pool cooling system is vulnerable to "humidity, wear and radiation."
- 3. Identify any and all documents, books, reports, papers, studies, analyses, calculations, or expert opinions which Intervenor claims provide support for this contention.
F. Admitted Contention 6 (originally Amended Petition l
Contention ll): l l
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- 1. Define the terms "untested".and "new and unproven technology" as utilized in the contention and the stated bases for the contention.
- 2. Does Intervenor contend that the Licensee's Safety Analysis Report,'Rev. 1 (SAR), does not correctly or adequately address the issues raised by the NRC Staff concerning the use of Boroflex? If so, identify the NRC-Staff issues, the spa .ic sections of Licensee's SAR that Intervenor contends are deficient, and explain how these sections are deficient.
- 3. ldentify any and all documents, books, reports, papers, studies, analyses, calculations, or expert opinions which Intervenor claims provide support for this contention.
G. Admitted Contention 7 (originally Amended Petition f Contention 15):
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- 1. Identify the specific requirements of ANSI-N16-1975 that will not be met if the spent fuel pool capacity is ,
increased, and how and why the requirements will be violated. ,
- 2. Explain precisely how and why the "increase in ,
spent fuel capacity" will "increase the probability that a crit-icality accident will occur in the spent fuel pool."
- 3. Explain precisely how "increase in spent fuel j l
capacity" will "exceed 10 C.F.R. Part 50, A 62 criterion. ,
- 4. Identify the specific limitations of 10 C.F.R. .
Part 100 that will be exceeded by any potential radiation release from the spent fuel pool, and how, why and to what extent the i limitations will be exceeded.
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- 5. . Explain why and h'ow the "increase in the number of fuel rods stored and the fact that many of them . . . may be 4
more highly enriched and have more reactivity" will increase ,
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the possibility that a criticality accident will occur in the St. Lucie 1 spent fuel pool and "perhaps, [an] explosion."
- 6. Identify any and all documents, books, reports, papers, studies, analyses, calculations, or expert opinions which '
Intervenor claims provide support for this contention.
Dated: June 2, 1988 Respectfully submitted, '
Co-Counsel:
John T. Butler _c_
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Harold F. Reis T ~ -
STEEL HECTOR & DAVIS Michael A. Bauser 4000 Southeast Financial Center NEWMAN & HOLTZINGER, P.C. ,
Miami, FL 33131-2398 1615 L St., N.W., Ste. 1000 -
Washington, D.C. 20036 (305) 577-2939 (202) 955-6600 Counsel for:
Florida Power & Light Company i
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(
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
FLORIDA POWER AND LIGHT COMPANY ) Docket No. 50-335-OLA
)
(St. Lucie Plant, Unit No. 1) )
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "Licensee's First Set of Interrogatories to Intervenor" were served on the following by deposit in the United States mail, first class, postage prepaid and properly addressed, on the date shown below:
B. Paul Cotter, Jr., Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Glenn O. Bright 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 ,
i Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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Adjudicatory File Atomic Safety and Licensing Board Panel Docket U.S. Nuclear Regulatory Commission Washington, D.C. .20555 (Two copies)
Secretary
, U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief, Docketing and Service Section (Original plus two copies)
Benjamin H. Vogler, Esquire Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .
Mr. Campbell Rich 4626 S.E. Pilot Avenue Stuart, Florida 34997 ;
Dated this 2nd day of June, 1988.
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Michael'A. Babser~ .
Newman & Holtzinger, P.'. C 1615 L St., N.W., Suite 3000 Washington, D.C. 20036 Telephone: (202) 955-6600 '
Counsel for 4
FLORIDA POWER & LIGHT COMPANY i
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