ML19329E993

First Set of Interrogatories Re Safety Evaluations

ML19329E993
Person / Time
Site:	Midland
Issue date:	03/22/1971
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, Saginaw Intervenor, Sierra Club
To:	Advisory Committee on Reactor Safeguards
References
NUDOCS 8006190772
Download: ML19329E993 (65)

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UUITED STATES 0F AMERICA ATOMIC EUERGY COIG1ISSION THIS DOCUMENT CONTAINS P00R QUAUTY PAGES In The Matter of -

COMSUMIRS P0F.:.R COMPAliY Docket Nos. 50-329 (MIDLAND PLAUT UNITS 1 AND 2) 50-330 FIRST SET OF IIs"IERROGATORIES 0F CERTAIN INTERVENORS

' DIRECTED TO THE ATOMIC ENERGY C0!GIISSION AND THE ADVISORY C0!&IITTEE ON REACTOR SAFEGUARDS Pursuant to part 2 of the Rules of Practice of the Atomic Energy Commission and the Atomic Safety and Licensing Board's. order permitting the serving of these interrogatories and requiring their answer, Intervenors request that the fol-lowing interrogatories be answered fully in writing and under oath by one or more representatives, members and/or employees of the Atcmic Energy Comm.4.ssion ("AEC" or " Staff") and the Advisory Committee on Reacter Safeguards ("ACRS") as the case may be who has personal knowledge thereof or is the closest to having personal knowledge thereof. If the interrogatories are answered by more than one person, whether or not he verifies all of the answers, state such person's name and title together with an identification of which. interrogatories each such person is 8006190 h ) k

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responsible for annucring. . Each of your answcrc chall be considered,1unless otherwise specifically set forth as having equal applicati n to cach of the proposed Midland Units 1 and 2.

The-Interrogatorics below are to be considered your continuing

, oblication. Accordingly, during the pendency of this proceeding, if additional information comes to your attention with respect to.one or more of these Interrogatories after you have answered these Interrogatories, then you are required to amend your answers to provide such additional information.

The words " Safety Evaluation," as used in these Interrogatories, refer t'o the Safety Evaluation Report prepared under_theJauspices of and proposed to be submitted into this hearing by the Regulatory Staff' of the Atomic Energy Commission.

Unless otherwise cet forth, the words "you" or "yours" (or words

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of similar import) shall refer to the Atomic Energy Commission, or any of its divisions, or the Regulatory Staff or the ACRS, as.the' case may be.

1.- 232. You have feceived a set of Interrogatories addressed to the applicant, Consumers Power Company. Those Interrogatories were designed to. ascertain information which

' forms <the basis for various opinions or conclusions or asser-

.tions contained within the Preliminary Safety Analysis Report for the proposed-Midland Units ("PSAR"). . Presumably you al-ready.have_ considered and have been privy to such information k

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-in the course lof your Safety Evaluation of the proposed Midland Units or, alternatively, you have not found it necessary to con-sider such information.in your Safety Evaluation. Accordingly, with respect to each Interrogatory asked of Applicant, if in

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your1 analysis resulting in your Safety Evaluation you have con-si:!ered the information which is called for by each such Inter-rogatory, then answer that Interrogatory as if specifically asked of you; alternatively, if any such Interrogatory calls for

informatisn which you have not considered in your Safety Evaluation, then you do not have to answer such Interrogatory, but- in such ' case with respect to such Interrogatory and the information it calls for, state:

(a) Does the Interrogatory and its answer relate to information-which must be considered in evaluating safety aspects of a reactor and the proposed Midland Units; and (b) ifny did you not consider such information in the course of your Safety Evaluation.

If in your ansuer you make reference to other than textual

-(exclusive of footnote) matter in the PSAR, or reference to otherfthan textual (exclusive of- footnote) matter in your.

Safety Evaluation,_then setLforth completely the text of each such reference or attach a copy.

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.-- s 233 Assuming the occurrence at the site of the pro-posed-Midland Units of'a full scale accident as examined in WASH-740. for a single unit of the size of either of the pro-posed Midland Units, :smd describing in detail, each fact, calculation and assumption upon which you base your answer, state conservatively the follouing:

(a) How much land would be contaminated and for how long a period of time; (b) How much property damage, in dollars, would occur;:

'(c) How'many pregnant women might be exposed to more than half a rem of radiation, if the acci-dent occurred in each of the years 1980, 1990 and 2000 considering population projections for each of such years; (d) How many people might be exposed to at least 25 rems of radiation if the accident occurred in each of the years 1980, 1990 and 2000, considering population projections for each of such years; (e) How many cancer and leukemia deaths might one

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such accident cause;

- (f) . Approximately how many genetic deaths and re-tarded children could result in later generations from one such accident; -

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(g) Approximately how many extra caccc of coronary heart disease and schizophrenia could result

-from~one such accident.'

-What differences:would there be to your answers if the acci-dent: occurred and the proposed Midland Units were 100 or more feet underground. Also state whether these calculations have

,everfbeen made for this docket number or another docket number with similar circumstances-and, if not, why not. If in your answer you ma'ke reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive.of footnote) matter in your Safety Evaluation, then set.forth completely the text of each such reference or attach a copy.

231!. With respect.to the substance and contents of the

' letter dated Hovember 12, 1969, addressed to Chairman Seaborg by' Joseph Hendrie of the Advisory Committee on Reactor Safe-guards, within which Mr. Hendrie called. attention to the exis-

tence of " urgent need for additional research and development"

-in safety features of the reactors already going into production,

. describe in detail, stating each fact, calculation and assumption, LwhatLare such needed. safety features and whether they are contem-plated to be'a part of the proposed Midland Units. , If they are.not,' state why not, including whether you agree with the remarks-of Mr. Hendrie. If'1q your ansuer-you make-reference to other than tex'tual (exclusive of footnote) matter in the PSAR,

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-.- -o or_ refer. enc ~e'to other than. textual (exclusive of footnote) matter-in.your Safety-Evaluation, then set forth completely'the text of each such reference or attach a copy.

235 With respect to each ACRS committee or sub-committee' meeting, and each ACRS meeting with Applicant, all with respect to the proposed Midland Units, and whether or not listed in Appendix A to the Staff Safety Evaluation T.eport, stateithe following:

(a) The names and titles of persons at each such meeting; and

_(b) The datesiand substance of what transpired at each such meeting.

Your answer may refer to a document or letter on file at the AEC Public Document Room if it -fully sets forth all the informa-tion-requested.for one or more such meetings. If in your answer you make reference to other than textual (exclusive of footnote)

-matter in'the PSAR, or reference to other than textual (ex-clusive of foo'tnote) matter in your Safety Evaluation, then -

set forth completely the text of each such reference or attach a copy..

236. With respect to the letter (and its contents)

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mentioned as Item 8 in Appendix A of the Safety Evaluation, describe the. content of each conversation, document, letter and communication which prompted the writing or resulted from the receipt of Esaid letter. If in your answer you make reference

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-to other than' textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of foot-note) matter in your Safety Evaluation, then set forth completely

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the text of each such reference or attach a copy.

237. State the name of each consulting firm, indi-vidual and-agency who was requested by you to analyze the pro-

-posed Midland Units. For each such consulting firm, individual

-and agency state what area or problem of the proposed Midland Units it analyzed'and what the results were. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (ex-clusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

238. With respect to the technical evaluation of the preliminary design of the proposed Midland Units which was done by the Division of Reactor Licensing, state for each segment or part of-the proposed preliminary design the name of the indivi-

-dual or individuals who performed the evaluation, a description of his or their evaluation and when the evaluation was done.

In addition, describe the content of each conversation, document, letter and communication which_was part of or related to each such evaluation. If in your ansuer you make reference to other

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than textual-(exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive' of footnote) matter w

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.in your Safety Evaluation, then set forth completely the text of each such-reference or attach a copy.

239 With. respect to Applicant's request for and.

the later approval of an exemption pursuant to 10 CFR 50.12 from the. provisions of 10 CFR 50.10 (b)-to permit construction of portions of'the substructure of the auxiliary building, and the tendon galleries and foundation for the containment structures, prior to the issuance of a construction permit, state what factors, if any, relating to site suitability were

. considered in granting the aforesaid exemption. If your answer is that there were no such considerations, then state whether the aforesaid exemption was granted only upon consideration of "the design of the applicable portions of the plant" as has been stated at page 3 of the $afety Evaluation. Describe the content of each conversation, document, letter and communica-tion which initiated, was part of, and resulted in the granting of.the aforesaid exemption. If in your answer you make refer-ence to other than textual (exclusive of footnote) matter in

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theLPSAR, or reference.to other than textual (exclusive of foot-note): matter in your. Safety Evaluation, then set forth completely

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the text of each such reference or attach a copy. l

-240.- With respect to the statement "The consequences of;these transients vill be calculated again when detailed plant design information is available to verify that these transients are within the capabilities of- the reactor control l w

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andLprotection systems," at pace 59 of the Safety Evaluation,

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state each. fact.and assumption which supports your belief that

a. complete analysis of the final. design insofar as transient stability is concerned, is not an important safety factor to be considered completely prior to any recommendation approving.

the proposed Midland Units. If in your answer you make refer-ence to other~than textual (exclusive of footnote) matter in the PSAR,-or reference to other than textual (exclusive of foot-note) matter in your Safety Evaluation, then set forth completely the. text of each such reference or attach a copy.

241. With respect to your statement at page 60 of the Staff Safety Evaluation that " Based on our evaluation of the information submitted by the Applicant and our evaluations of other pressurized water reactor designs at the operating license stage," describe in detail the evaluations of these other pres-surized water reactor designs insofar as you contend such evalua-tions relate to the proposed Midland Units. Include within your answer the name of each pressurized water reactor you have re-lied upon and uhether you have relied upon anything in Compliance Division Inspection Reports'regarding such other reactors and if you have, then list the dates of such inspection reports.

-If in your' answer you'make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to

.other than textual (exclusive of footnote) matter in your

. Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

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211 2 . WilhL renpect to the nLatement at par,e 60 or the Safety Evaluation that "the. consequences of these acci-dents can be controlled by limiting the permissible primary and secondary coolant system radioactivity concentrations,"

1 state:

(a) What is lowest level of possible accidental dose which is contemplated by-controlling the limiting of activity as aforesaid; (b) What level of activity concentration will achieve the dose set forth in (a) above;. and (c) Can such levels be lower than set forth in (b) and if so state why, if it is true, you do not intend to, seek to impose such lower levels.

State each fact, calculation and assumption upon which you

. base your' answer. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

243 Describe what participation, if any, you

-have had in connection with a trip in 1970 by certain persons, later to become members of Intervenor Midlear Nuclear Committee, to Oak Ridge, Tennessee. If in your answer you make reference to other than textual (exclusive of footnote) matter in the

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PSAR,.or reference to other'than textual (exclusive of foot-

, note) matter in your Safety Evaluation, then set forth com-pletely the-text of each such reference or attach a copy.

244. With respect to the refueling accident described at page 611of the Staff Safety Evaluation, describe in detail each fact, calculation and assumption by which you have de-

.termined that resultant calculated doses will be 250 rem to the thyroid and 8 rem to the whole body at the site boundary and 90 rem to the' thyroid and 3 rem to the whole body at the Outer boundary of the low population zone. If in your answer you make reference to other than textual (exclusive of foot-note) matter' in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach

-a copy.

245 With respect to the potential offsite conse-quences resulting from a rod ejection accident, describe in detail-each fact, calculation and assumption by which you have.

determined (page 63 of the Safety Evaluation) that the calcu-lated two-hour site boundary doses will be 180 rem to the thyroid and 1 rem to the whole body and that the calculated course of the accident doses at the outer boundary of the low population zone will be 70 rem to the thyroid and 1 rem to the whole body. If in your answer you make reference to other than textual 1(exclusive of footnote) matter in the PSAR, or reference

se to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth: completely the text of each

-such~ reference or attach a copy.

240. With respect to the~ potential.offsit.e consequences resulting from a LOCA, describe in detail each fact, calcu-lation and assumption upon which you state at page 65 of the Staff Safety Evaluation that potential doses at the site boundary

for.a'two-hour period will be 270 rem to the thyroid and 4 rem to the whole body and that potential doses to the low population zone for a 30-day period will be 90 rem to the thyroid and 3 rem to the whole body. If in your answer you make reference to other than t'extual (exclusive of footnote) matter in the PSAR, or reference to other than textual (excluaive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

247 With respect to your analysis of the Dow emer- ,

gency plan, which you refer to at page 70 of the Staff Safety Evaluation, describe in detail each fact, calculation and assumption by which you conclude that the dose that might be received by an employee standing one mile from the reactor during 35-minute and one-hour periods following a design basis LOCA would"be, respectively, 55 rem to the thyroid and 75 rem to the thyroid.- If in your answer you make reference to other than-textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter

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in~your Safety' Evaluation, then set forth completely the text of each such. reference or attach a copy.

240. Describe in detail each fact, calculation and assumption upon which you conclude that the population center distance determined under 10 CFR Part 100 is or would be 1 1/3 miles.. Also explain why the term " population center distance" does not appear in the PSAR. If in your answer you make re-ference to other than textual (exclusive of footnote) matter in the PSAR,-or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

249 With respect to the possible subsidence as stated at page 12 of the Safety Evaluation, what point or points of the proposed Midland Units' Class I s'tructures would experience the maximum stress? In addition, what would be the maximum stress in each of the following given such a subsidence:

(a) Pressure vessel; (b)- Containment structure; and ,

-(c) Primary coolant piping.

State each fact, calculation and assumption upon which you base your answer. If in your answer you make reference to other :than . textual -(exclusivo of footnote) matter in the PSAR, or reference.to other than textual (exclusive of footnote) matteriin your Safety Evaluation, then set forth completely the

. text of each such reference or attach a copy.

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. .. .s-250. Describe in detail-what analysis, specifying each fact, calculation and assumption thereof, was made by you concerning the probable maximum flood and its possible conse-quences to the proposed plant. During the period of construction of t'he proposed Midland Units and during your review of the Applicant's calculation of the probable maximum flood level, what changes can or are contemplated to be incorporated into the design to insure integrity of the proposed Midland Units, if error is found in flood calculations. Also, state why you wait until construction of the proposed Midland' Units is under way to " review the Applicant's calculation" and to assure yourself that "the calculational techniques have been properly employed."

If in-you

you make reference to other than textual (exclusive of. footnote) matter in the PSAR, or reference to

.other than-textual (exclusive of footnote) matter in your Safety l Evaluation, then-set forth completely the text of each such  !

reference or attach a copy. i 251.- With respect to your statement on page 15 of the-Safety Evaluation that " gamma activity of samples of fish and o.ther aquatic. life" will be taken " monthly, when possible,"

describe:in~ detail when it will be possible and when it will not be:possible'to take such samples. If in your answer you' i o

make reference to other than textual (exclusive of footnote) matter inct'he-PSAR, or reference to other than textual-(exclu-

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sive'of footnote) matter in your Safety Evaluatio n, then. set 14-R

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t forth completely the text'of each-such reference or attach

'a copy.

252. Describe in detail including each fact, calcu-lation and assumption, the statistical significance which will govern'the interpretation of the results for each of the follow-ing series of tests in the pre-operation environmental radia-tion. survey program ~as outlined at page 14 of the Staff Safety

-Evaluation: . ,

(a) Six air particulate samples weekly; (b) Six measurements weekly of radioactive iodine activity in the air; (c) Three measurements monthly of the gross beta l activity of the. waters of the Tittabawassee River and Chippewa. River; l-(d) Three measurements monthly of the tritium con-tent of the waters of Tittabawassee and Chippewa Rivers; and (e) Hine measurements monthly, when possible, of the gammc activity of samples of fish and other aquatic life.

f- If in your answer you make reference to other than textual (ex-clusive of. footnote) matter in the PSAR. or reference to other than textual (exclusive of' footnote) metter in your Safety Evaluation, then. set forth completely the text of each such

reference or attach a copy.

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t 253 ~ State in detail, including each fact, calcula-tion and assumption.by which you conclude relative to the number, type.and location of the sampling stations and the analyses performed that the radiation survey program'for the-proposed Midland Units will provide a valid basis for evaluat-ing the radiol.ogical impact of the plant on the environs by comparing the' future levels of radioactivity with preoperational levels. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

254. Describe in detail each fact and factor deter-mined from the review of the Oconee Nuclear Station Units 1, 1

2 andE3 and-the. subsequent review of the Babcock and Wilcox L

Topical Reports which formed a part or basis for your conclu-l s sion that based on such reviews (in whole or in part) the L Midland plant design is acceptable with regard to cor.e physics, l

core thermal, core hydraulic, and core mechanical design. If.

in your answer you make reference to other than textual (ex-clusive of' footnote) matter in the PSAR, or reference to

-other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each

'such reference or. attach a copy.

255 Describe in detail each " Improved means for -

prompt' detection of' fuel' clad failure" which you say in the n' ~

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Staff Evaluation is under development within the industry.

What percentage of leaking fuc1 rods can the presently con-sidered process radiation monitor detect? What increase in coolant. activity, as the system is presently designed, can occur uithout being detected. If in your answer you make'

-reference to other than textual (exclusive of footnote) matter in the P3AR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

256. Describe in detail the substance of your re-

. view and analysis stating each fact, calculation and assump-tion'thereof,of the reactor coolant system which you made to determine the adequacy of the , design of the proposed Midland

-Units to uithstand normal loads of mechanical, hydraulic and

. thermal origin, plus anticipated seismic loads from the opera-tional basis earthquake. If in your answer you make reference to other.than textual (exclusive of footnote) matter in the

. PSAR, or reference to other than textual (exclusive of foot-

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note) matter'in your Safety Evaluation, then set forth completely the text'of each such reference or attach a copy.

257. Describe in detail the substance of your review and analysis, stating each fact, calculation and assumption thereof,'of the codes, the plans for design and fabrication and the quality specified for the reactor vessels and coolant piping which formed all or part of the basis for your conclusion that I'

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'said[ items are acceptable. Include within your answer whether

" acceptable"' indicates minimum or ma*ximum' compliance with a Given standard. :DC in' your answer you make reference to other than textual'(exclusive.of footnote) matter in the PSAR, or reference'to other than textual (exclusive of footnote) matter in-your. Safety Evaluation, then set forth completely the text of each'such reference or attach a copy.

258. Describe in detail the substance of your review and analysis, stating each fact, calculation and assumption -

thereof upon which you conclude as stated at page 22 of the

' Staff Safety _ Evaluation that all internal components will be designed to withstand the loads which will result from a com-bined design basis earthquake and LOCA. If in your answer you make reference'to other than' textual (exclusive of footnote) matter in the1?SAR,.or reference to other than textual (ex-clusive -of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach

'a_ copy.

259'. Describe in detail the contents of your evalua-

' tion, stating each fact,; calculation and assumption thereof,

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upon which you conclude.that the missile penetration formulae and.misd:be protection criteria-proposed by the Applicant are

-consistantLwith established practices and AEC criteria and are g

acceptable. : Include within your answer a description of and reference-tofsaid " established. practices," a reference to

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"AEC criteria," and a definition of the word " acceptable" as you use it. If in your ansuer you dake reference to of.her th:tn textual (exclusive of footnotc) matter in the PSAR, or refor-ence to other than textual (exclusive of footnote) matter in your Safety ? valuation, then set forth completely the text of each such reference or attach a copy.

260. Define the nord " acceptable" in terms of mini-num and maximum compliance with given criteria or standards as you use that word throughout the Safety Evaluation. If in your answer you make reference to other than textual (exclu-sive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

261. State in detail each fact, calculation, and assumption upon which you base your belief (page 25 of the Staff Safety Evaluation) that the ASME Code for the In-Service Inspection of nuclear Reactor Coolant System (U-45) is equi-valent to Section XI of the ASME Boiler and Pressure Vessel Code. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or refer-ence to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

202. Uith respect to Class I (Seismic) Structures,

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' describe-in detail each fact, calculation, and assumption,

, up'on which y'ou' conclude;that the loa' ding'-criteria proposed Tby-Applicant is consistent with established practices 1cnd

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> (acceptable ias . stated on pa6e 2o of - the Staff Safety Evaluation.

.In'clude:within your answer a. description ~of and reference to said established practices. If in your answer you make re-

ference to'other.than textual (exclusive of footnote) matter-

[insthe PSAR, or reference to other than textual (exclusive of footnote) matt'er.in^your Saflety Evaluation, then set forth s

completely the text Jof each such reference or attach a copy.

263 State in detail, your review and analysis, stating

-each fact, calculation,-and assumption thereof, of the Appli-cant's considerations.of potential interaction between Class

'Ii(Ssismic) and Class II (Seismic) components and structures during_ seismic excitation to assure that-failure of a Class I

- .(Seismic) structure or component would not dmnage a Class I (Seismic); item. If in your answer-you make reference to other

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thanitextual-(exclusive of footnote) matter in the PSAR, or I_ .

reference to other thanstextual'(exclusive of. footnote) matter in' your -Sdrety -Evaluation,- then set forth completely the text sof eachisuchireference or attach a copy.

, 264. Describe'in detail.each test or experiment,

specifying?each fact,. calculation and assumption thereof,

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7 ,o :whichiyou do or intend to rely upon to' assert, if you_do,_that _

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, :the; containment: structure as designed- of- the: proposed Midland

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equivalent to those of a possibic LOCA. If in your ansuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (ex-clusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach

'a copy.

265 What are cach of the " uncertainties" in the calculated peak in the containment structure during a LOCA as you so state at page 28 of the Staff Safety Evaluation. Also state what steps you and Applicant are taking or proposing to take to resolve each'such uncertaintf and what relationship, if any, the non-resolution of each such uncertainty has to the safety of the proposed Midland Units. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (excla-sive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such r2ference~or attach'a copy.

266. Describe in detail each fact, calculation and assumption, upon which you conclude at page 29 of the Staff Safety Evaluation that "these materials and specifications are consistent with current design practice and are acceptable." l Include within your answer a description of and reference to said current design' practice. If in your answer you make re-ference to other than textual (exclusive of footnote) matter in e n

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the PSAR, or reference to other than textual (exclusive of

' footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

267. on page 34 of the Staff Safety Evaluation.

you' state that " Prior to installation of equipment for the

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emergency core. cooling system, we will require that the appli-cant verify the results of his analysis using more sophisti-cated multi-mode analytical techniques which represent the reactor coolant system by the use of several control volumes, rather than the tuo used in the present calculational tech-nique." With respect to this statement, answer the follow-ing:

(a) Describe in detail what review and analysis,

-- if any, including each fact, calculation and assumption thereof, was performed by you to evaluate the adequacy ~of the Emergency Core Cooling System (ECCS) and the adequacy of the analysis referred to and above ' quoted; (b) Why such "more sophisticated multi-mode analytical techniques" were not required prior to your evaluation resulting in the proposal of-a. construction permit; and

.(c)' What necessary changes, if any, would such "more sophisticated multi-mode analytical techniq.ues" indicate in either the operation

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of ECCS or ite design and what steps are you takinC to assure that all design optionn remain open until after the more sophisti-cated verification has taken place.

If~1n your answcr you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

268. At pace 34 of the Staff Safety Evaluation, you state that "the code used in the verification of the perform-ance of the emergency core cooling system will utilize the data available from the appropriate research and development programs". Describe in detail each fact and experimental and test result which will either add to or limit the application of the " code",-and give a description of and reference to said appropriate.research and development programs. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exc]usive of footnote) matter in your Safety Evalua-tion,.then set forth completely the text of'each such. refer-ence or attach a copy.

L269 Are there any facts, calculations and assump-Ltions other than those cited in the. Staff Safety Evaluation upon which you conclude that the applicant's preliminary design and

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the analysis effort to be performed are acceptable as you have stated on_page 34 of the Staff Safety Evaluation. If ,

so, describe in detail each other such fact, calculation and assumption. If in your answer you make. reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter'in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.-

270. Describe in detail each fact, calculation and assumption which ' formed a part of your review and analysis of the following proposed Midland Units' design limits:

(a) The ability to limit the peak clad tempera-ture to well below the clad melting tempera-

.ture; (b) The ability to limit the full clad-water reaction to less than one percent of the totax clad mass; (c) .The ability to terminate the clad temperature ,

transient before the geometry necessary for cooling is lost, and before the clad is so embrittled as to fail upon quenching; and (d) The ability to reduce the core temperature and then maintain core and coolant temperature

-levels in the subcooled condition until acci-cent recovery operations can be accomplished.

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I

. n .,-~o .- .-- , , ,.u If'in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to

- other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

'271. Describe-in detail your review and analysis, stating each fact, calculation and assumption thereof, upon which you conclude that "the spray system [to be contained in the proposed Midland Units] will be designed in such a manner that adverse pH conditions cannot develop to the ex-tent that they uill significantly affect system performance",

as stated at page 35 of the Safety Evaluation. If in your answer you make reference to,other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evalua-tion, then set forth completely the text of each such refer-ence or attach a copy.

272. Describe in detail each fact, calculation

. and assumption upon which you have predicted ~in your Safety Evaluation a " spray . removal constant" of 2.5. hours-1, as stated at page 35 of the Safety Evaluation. If dn your answer you make reference to other than textual (exclusive of foot-note) matter in the PSAR, cur reference to other than textual

-(exclusive of footnote) matter in your Safety Evaluation, then cet forth completely the text of each such reference or-

- attach'a. copy.

2 . . .-

273 Describe in detail cach fact, calculation and~

assumption, upon which you rely to c'onclude that the "Research and development. effort" which "is being conducted on the long-term stability of the alkaline sodium thiosulfate solution under. post-loss-of-coolant accident conditions, and on the material compatibility aspects of the spray solution with all exposed construction materials" (page 36 Safety evaluation) will i

be equivalently related to conditions in the proposed Midland 1

' Units and will cover completely all conditions which are neces-sary for. precise predictability. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference,to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

274. Describe in detail each fact, calculation and assumption, other than those set forth at page 36 of th'e Staff Safety Evaluation, upon which you conclude that Applicant's proposed iodine removal equipment is acceptable in view of the R & D program.yet to be completed. In addition, since you conclude that offsite doses calculated using " conservative assumptions" are within 10 CFR 100 guidelines values, state if any consideration was given to make the offsite doses as low as'engineeringly possible. If not, why not. If yes, explain in detail,such consideration and if it resulted or will result

'in an essentially zero: radioactive waste system or systems for j i

1 i

1 1

- - - , a .- . -.

the_ proposed Midland Units. If in your answer you make re-ference'to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy..

275 Describe in detail each fact, calculation, and assumption upon uhich you conclude that the capacity of the containment heat removal system proposed is " adequate" other thar your statement that the " containment heat removal systems would cause the containment pressure to drop to a low value within the first day following a loss-of-coolant accident", as

, stated at page .37 of the Safety Evaluation. If in your answer you make reference to other than textual (exclusive of foot-note) matter in the PSAR, or reference to other than textual i (exclus.,e of footnote) matter in your Safety Evaluation, l then set forth comuletely the text of each such reference or attach a copy.

276. List each acceptable method for the control of l

hydrogen other than purging to prevent " additional" thyroid and whole body doses at the outer boundary of the low population zone, subsequent to a LOCA. Include within your answer what additional doses, if any, would result from each such alter-nate system and whether you intend to require that an acceptable alternate system must result in no such additional doses and if not, why not. If in your answer you -make reference to other a

_ ,; __ . . __ . ._ :_ i-r

'than textual (cxclusive of footnotc) matter in the PSAR,.or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the. text of each such reference or attach a copy.

- 277. With respect to the " protection system",

, (page 33 Safety Evaluation) state what other criteria was used by you to_ determine the acceptability of the the " protection system" uhen.conformance to the General Design Criteria, as (published in the Federal Register on July 11, 1969, and the Proposed IEEE Criteria for ITuclear Power Plant Protection ,

I . . Systems (IEEE279) dated August 1968, was not applicable. If in your answerLyou make reference to other than textual (ex-

clusive.of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety

' Evaluation, then set forth completely the text qf each such reference or attach a copy.

278. Describe in detail-each fact calculation,.and assumption upon which you conclude that the instrumentation

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systems-which initiate and control the engineered safety features for the proposed Midiand Units are "substantially the same as those proposed and found acceptable for the Three--

-Mile ~ Island Unit 2 Plant. Include-uithin your answer a de-scription offsuch-systems.in said_Three-Mile Plant sufficient to make a comparison land state also the relevance to this pro-ceedinc_and;your-Staff Safety Report-of. making such a comparison.

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i If in your answer.you mako reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your

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Safety Evaluation, then set forth completely the text of each such reference _or attach a copy.

279 With respect to the liquid unste disposal j

systems, describe in detail uhat systems are currently avail-

-able which when used in conjunction with the presently pro-posed Midland Units Plant Waste System would result in es-sentia11y =cro radioactive gaseous and liquid effluents.

Describe in detail each fact, calculation and assumption upon

'which you base your answer. If in your answer you make re-ference to other than textual.(exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth.

completely the text of each such reference or attach a copy.

280. Why are not all the wastes which are collected from the radioactive laboratory drains, building sumps, and decontamination shower drains vacuum degassed and sent to waste holdup tanks and then filtered, demineralized and evapor-ated, storing.the demineralized water stored for later reuse.

- Describe in detail each fact, calculation, and assumption upon uhich you base your_ answer. If in your answer you make refer-ence to other.than textual (exclusive of footnote) matter in

-the PSAR, or. reference to other than textual (exclusive of 9

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footnote) matter in your* Safety. Evaluation, then set forth

- completely the text of each such reference or attach a copy.

231. With respect to the Applicant's estimated activity.of.the gaseous-andcliquid activities (as' stated on par;e 50 of- the~ Staff Safety Evaluation) which will be stored -

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inLthe'licuid : taste holdue tanks proposed to'bc located'in-

- side the reactor containments, state the dose to an individual separat'ely. at .the ' boundary of the exclusion area and low popu-I ^

1ation zone separately for- periods of two-hour's, twenty-four-

. - hours and. thirty days. Describe in deta11 Leach fact, calcu-

, lation and assumption, upon trhich you base your answer. If'

~ 1n your answer you make reference to other than textual (ex-clusive of footnote) matter in the PSAR, or reference to

. other than textual (exclusive of footnote) matter in your Safety. Evaluation,.then set forth completely the text of'each

~

y such reference or attach a copy.

.28 2. Describe in detail each study'that the Appli-I

! cant ~is performing to find a means-.of preventing: common-mode failures'in the reactor protection. system from negating-j..

scram action.and also each study that Applicant is perform-ing.to determine ~and evaluate the. consequences of failure to scrami in. the event of anticipated . transients. If in your

, . ansiter you make reference to-other than textual (exclusive 1

of footnote) matter in the'PSAR,.or-reference to other than text'ual'(exclusive.of footnote) matter in your Safety Evaluation L .

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L l then act forth completely the text of cach such referenec or attach a copy.

-283.- Describe in detail each possible way of ob-taining flexibility in the proposed Midland Units' engineer-ing design. with regard tx) (1) relief capacity of the primary systems.and (2) diverse means of reducing reactivity in corder to tolerate the consequences of a failure to scram dur-

-ing . anticipated transients. Also state each condition with respect to the proposed Midland Plant design for which you would req.uire modifications to the plant to make tolerable the consequences of failure to scram during these transients.

If in your answer you make reference to other than textual (exclusive of footnote) matter in.the PSAR, or reference to '

other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

284. Describe in detail your evaluation and analy-sis, stating each fact calculation, and assumption thereof,

~

o of the probability and consequences of "these types of events" u as stated at page 45 of the Safety Evaluation which will

. provide the basis for further review of the proposed design of the systems regarding their ability to terminate or limit the consequences of such events. If in your answer you make

' reference to other than textual (exclusive of footnote)

. matter.'in.the PSAR, or reference to other than textual (ex-clusive-of. footnote). matter in your Safety Evaluation, then

. ~ ~ . .

8 .8 .

set forth completely the text of each such reference or at-tach a copy.

285 State in detail each of the specific features

-for the installation of protection and emergency power system 5 for which Applicant will (if it will) develop more detailed criteria and procedures, all as recommended by the ACRS as stated at page 45 of the Staff Evaluation. Include within your answer when these will bd developed and why you or ACRS is not requiring (if you or ACRS is not) development prior to a construction permit. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of foot-note) matter in your Safety Evaluation, then set forth com-pletely the text of each such reference or attach a copy.

286. What level of activity will cause the liquid effluent control valve to close, thus terminating release of liquid effluent to the Tittabawassee River (page 51 of the Safety Evaluation). Will there or can there be any conditions under which the operation of this liquid effluent control i valve-will be prevented to operate. Describe each fact, calcu-lation, and assumption upon which you base your answer. If in your answer.you make reference to other than textual (exclusive of footnote) matter in th.e PSAR, or reference to other than textual (exclusive of' footnote)-matter in your Safety Evaluation, {

- then set forth completely the_ text of each such reference or attach a copy.

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287 With respect to your statement at pace 52

, . of the Safety Evaluation that "there'will be no significant -

. hazard to drinking water supplies as a consequence of normal-operation of the Midland Plant." Describe in detail each fact, calculation and assumption upon which you base your answer and give a definition of " normal operation" as you use that term. Also describe in detail arch accident at or abnormal _ operation'of the proposed plant which could result in potential: danger to drinking water and what corrective action will be taken or is being planned to be taken for each of said circumstances. If in your answer you make re-ference to other than textual (exclusive of footnote) matter

' in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the_ text of each such reference or attach a copy.

288.- With respect to temporary storage of radio-active gases, what level of radioactive content is "high" and what level of radioactivity is a level acceptable for re-lease, Ras stated at page 52 of the Safety Evaluatien, Describe

- in detail each fact, calculation and assumption upon .'hich you base your. answer. If in your answer you make reference to other. than textual (exclusive of footnote) matter in tne PSAR,

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or reference to other than textual'(exclusive of footnote) matter'in your-Safety Evaluation, then set forth completely m

.the text of each such' reference or. attach a copy.

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t 289 With respect to the Applicant's gaseous release rates Eas set forth at page 52 of thd* Safety Evaluation, what #

. willLbe the maximum: concentration at anytime (and not averaged '

+r over anyfperiod)'of radionuclides-at.the site-boundary. De-scribe in detail each fact, calculation and assumption upon-which'you: base your ansuer.' If in your answer you make re-ference to other than textual (exclusive of footnote) matter

'in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of.cach such reference or attach a copy.

t. s 290. Describe in detail each fact, calculation and assumption upon uhich you will establish the limit in the itechnica11 specifications for +he proposed Midland Units at which

discharge of gaseous e 'ffluent will'be automatically terminated.

IfLin your answer you make reference to other than textual (exclusive-of footnote) matter in the PSAR, or reference ~to

'otherithan1 textual (exclusive-of footnote) matter in your Safety Evaluation, then set forth completely the text of each >

. such reference :or attach a copy.

291. Describe in detail the physical route by which solid radioactive ~ uastes' will be removed from the proposed

~

Midland: Units site, and:also state the name'of the disposal firm and-its~-location, where the solid wastes generatedJby the i l proposed M,idlandsUnits'uill be stored and have you accounted H;or:preparedEfor.such storage?for waste:tolbeEgenerated over s -

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'the life of said Units. If in your annuer you make reference to other_than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual-(exclusive of foot-note) matter in your' Safety Evaluation, then set forth com-l' pletely the text of each such reference or attach a copy.

292. Describe each fact, calculation and assumption of your review.and analysis of the following systems of the proposed Midland Units pursuant to which you conclude that such systems will be adequate ~to perform their intended functions:

(a) The reactor coolant makeup and purification system; s (b) The chemical addition system; (c) The decay heat removal system; (d)~ The fuel pool cooling system; (e) The chield cooling system; (f) The component cooling system; (g) .The service water system; (h) The auxiliary feedwater system;

'i) The fuel handling system; (j) The instrument and service air system; l(k) The heating, ventilating and air-conditioning systems; )

(1)' The fire protection system; l

-(m) The condesate and focuater system for the I stead generators; and -

(n) The circulating water system.

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D1 addition- and for each of these systems describe cach fact,

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calculation:and assumption upon which you conclude that'"the design _ bases for these systems are the same as-those for other:recently reviewed'and approved PWR plants," and include 1 -

!- -within your answer a statement as to what relevance such other plants' systems have to this proceeding, e.g. were those 1 systems'and the systems for the proposed Midland Units:

.(a) ' Manufactured by the same venors; and (b) Constructed or installed pursuant to an identical quality assurance plan or program.

Finally, list each such other recently reviewed and approved PWR plants together with each document which formed any basis for review and approval of such other PWR plants which re-lates in anyway.to your approval or evaluation of the proposed Midland Units. If in your answer you make reference to other than textual (exclusive of footnote) matter in the'PSAR, or reference to other thin textual-(exclusive of footnote) matter

~1n your Safety' Evaluation, tren set forth completely the text of'ench such. reference or~ attach a copy.

293 Describe in. detail each fact, calculation and

~

assumption ~upon which you base your conclusion that the pro-posed Midland Units' cooling pond is' sufficient to provide

'the* cooling water needs of the. plant for 100 days without adrawing water _from the Tittabawassee River. Include within yourianswer a statement. of what are the ' expected ma::imum and-l

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minimum temperatures of the cooling pond under normal condi-tionn and.throughout the period up to and including the 100 days that water cannot be drawn from the Tittabawassco - Rivor?

If in your answer you make reference to other than textual

'(exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

294. Describe in detail the expected composition of the dredging which will be taken periodically from the.

cooling pond, including but not limited to each expected radionuclide and its concentration. State.each fact, calcu-lation'and assumption upon which you base your answer. If in your answer you make reference to other than textual (exclu-sive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or. attach a copy.

295.. Describe in detail each fact, calculation and assumption upon which you conclude (page 56 of the Safety Evaluation) -that "an adequate supply of water will be available

' both.to cool the' plant during normal operation with low river flow and to reject plant heat following plant shutdown even in thefevent of failure of the dikes.which contain the water

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in the cooling pond." If in.your answer you make reference o to other than textual (exclusive of footnote) matter in the

- PSAR,.or' reference to other than textual (exclusive of footnote) t . matter'in.your Safety Evaluation, then set forth completely

- the' text of each such reference or attach a copy.

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296. Describe in detail what will occur when the alarm that monitors the steam condensat'e from the intermediate-  !

i heat exchanger is activated, as stated at page 57 of the  !

Safety Evaluation. State each fact and assumption upon which i you. base your answer. If in your answer you make reference i ,

to -other than- textual'-(exclusive of footnote) matter in tne  :

1 PSAR, or reference to other than textual (exclusive of foot- i no'te) matter in your' Safety Evaluation, then set forth i

completely the text of each such reference or attach a copy.

297 Describe in detail each fact, calculation and assumption upon which you' conclude that Applicant, through i- itsLoperation and construction of the Big. Rock Point Plant and construction of-the Palisades Plant, (and your contact '

' withLrelevant project. personnel) demonstrated that it is technically-qualified to design and construct or have i

. designed and constructed the proposed Midland Units. If in-

- your answer you make 1 reference to other than textual (exclu-sive of footnote) matter.in the.PSAR,.or reference to other

-than . textual' (exclusive of: footnote) matter -in your Safety O

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Evaluation, then. set forth' completely the text of each such L reference:or attach a copy.

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--298. Describe in detail, stating each fact, calcu-lation_and assumption upon which you have concluded in your revieu and analysis that the Babcock & Wilcox Company and the.Bechtel-Corporation are technically qualified to design 1

and construct the proposed Midland Units, including but not limited to-each fact, calculation and assumption upon which 1

you base your favorable acceptance of the following state-ments:

(a) the Babcock & Wilcox Company is currently 4

engaged in the design, construction, and installation of 10 pressurized ws.ter nuclear steam supply systems; 4

(b) the operating experience of each plant for which Babcock & Wilcox Company had supplied-the nuclear steam supply system; (c) the Bechtel Company and Bechtel Corporation have been 2.ctively engaged in design and con-4 struction of 23 boiling water reactor and L pressurized water reactor nuclear power plants.

, If in your answer-you make~ reference to other than' textual (exclusive of' footnote) matter in the PSAR, or reference to

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other than textual' (exclusive of footnote) matter 'in your

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a Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

L 299 Separately for Applicant, Babcock & Wilson 1 and' Bechtel Corporation, state : .

4' -

(a) Has it ever been cited or questioned by your Compliance Division or any of your divisions or any part of the AEC for a

' t violation of AEC rules, regulations, estab-lished practices, or~an AEC license or its technical specifications. If so, describe each such instance of citation.or question .

and its disposition and what, if any, con-sideration each such instance was given in i

connection with your Safety Evaluation for the proposed Midland Units or your proposed issuance of a construction permit for the proposed Midland Units; (b) Is there a n y established method, procedure  ;

4 or practice which it follows or is following o which you would like amended, ceased or l

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changed, as regards the design, construction q

, or; operation, if any, of the proposed Midland Units. If 'so, describe each one in detail.

-If in your answer.you make reference to.other than textual

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l(exclusive 1of footnote) matter in the PSAR, or reference to j -other than textual (cyclu's'ive of footnote)- matter in your

' Safety Evaluation, then set forth completely the text of q -each such reference or attach-a copy..

300. ExplainLin detail the basis of and reason for

.the statement, "During construction of the facility, the

' Division of. Compliance will monitor the applicant's capa-bilities to ^ assure that .the applicant's expanding commitment to. nuclear power does not dilute the technical support organization," which appears at page 68 of the Safety.

Evaluation. If in your answer you make reference to other than; textual (exclusive of footnote) matter in the PSAR, or

. reference . to1 other than textual * (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

-301. Describe.in detail each fact, calculation and assumptibn upon .which you have concluded that the " crew size may not be acceptable" and what additional information you

~ '

-) + will - require from the - applic' ant: "regarding the ability of .the proposed shift' composition to safely handle-both normal and

' abnormal conditions:at the facility," all as set forth at

pagel68.of the Safety Evaluaticn. If in your answer you e

make'-reference to. other [than ' textual -(exclusive of' footnote)

(matter in1the PSAR, or reference to other:than textual (exclu-

. s iveLof footnote). matter-in your Safety Evaluation, then set

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'forth completely'the text of each such reference or attach a-copy.

302.' Describe in detail each of the requirements for acceptability of an operator training program. If in your ansucr you' make reference to other than textual (exclu-sive of footnote) matter in the~PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set.forth completely the text of each such

-reference or attach a copy.

303 Explain in detail your statement, " Babcock &

Wilcox Company.uill have day to day responsibility for the nuclear steam supply system," which appears at page 72 of

• the' Safety Evaluation. - Include within your answer how such

" day to day responsibility" affecto Applicant'.s overall responsibility for the desi6n and construction of the proposed Midland Units including quality assurance responsibility as setTforth in Appendix B to Part 50 of AEC Regulations. If.in your ' answer 'you make reference to other than textual (exclu- '

sivo of_ footnote) matter in the PSAR, or reference to other than -textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such referencefor_ attach'a ecpy. .

304. . Explain in' detail your statement, "B & W will also audit the7 quality assurance prograns of its suppliers as

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-appropriate," which appears. at .page' 73 of the DRL Safety

- Evaluation. Define " appropriate" as it is used, including each standard and. criteria. If in your ansuer you make reference . to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) ' matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

305 Describe in detail your review and analysis,

. stating-each fact, calculation and assumption thereof, of the Babcock & Wilcox Company program which has been initiated to study fuel clad failure nechanisms associated with a loss-of-coolant accident.that includes evaluation of existing data and " scoping" tests to obtain data on potential fuel clad failure mechanisus. If in your answer you make reference

~

to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of foot-note) matter in your Safety Evaluation, then set forth com-pletely the text of each such reference or attach a copy.

306. Describe in detail your review and analysis, stating- each fact, calculation and assumption thereof, of

the analytical-studyfor fuel clad failure-mentioned at

-page.76 of the Safety Evaluation. Also state how this analytical l study relates to the " evaluation of existing data t

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and-ccoping'testo to obtain data on potential fuc1 clad' failur nochanions" as mentioned at page 75 of the: Safety Evaluation. 'If in your' answer you-nahe reference to other s

$than textual '(exclu's ive of footnote) matter in the PSAR, or reference ~ tc other than textual (exclusive of footnote)

' natter-in your Safety Evaluation, then set forth completely the- text 'or each such reference or attach a copy. ~

.307 Describe in detail each fact, calculation and assunption uhich comprises "the further information" which has been obtained as stated by you at page 76 of the Safety Evaluation from the . data of- the Multipin tests and the FLECHT program (Full Length Energency Cooling Heat-Transfer' Test), and also describe in detail how this data

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- s or "further. information" will be used in conjunction -with

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inproved nulti-modo analytical techniques to verify the:per-ifor.r.ance of..the energency core cooling system. If in your answer you make . reference 't'o other than textual (exclusive n

of footnote) natter in the PSAR, or reference to other than .

textual (exclusive of footnote) natter in your Safety Evalu-ation, then set,forth completely the text of each such Sreference..or attach a~ copy.

a 308.. Describe in detail your review and analysis,

. stating; each fact,- calculation and assumption thereof, of the experimental. progran which has been performed by Babcock

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i a Wilcox Company to verify .the performance of the internal

!- vent' valve assemblies.- If in your answer you make reference t

to other .than textual (exclusive of footnote) matter in the I.

. PSAR, or reference to other than textual'(exclusivo of foot-note) matter in your Safety-Evaluation, then set forth com-

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pletely the text of each such reference or attach a copy.

F l 309 Describe in detail your review and analysis,

! stating each fact, calculation and assumption thereof, of i

f the Babcock & Wilcox Company tests on tube mockups of the 1

once-through steam generator, including a statement of what

_ considerations. will be necessary to

substantiate the accepta-t bility:of the design. -If in your maswer you make reference l to other-than textual (exclusive of footnote) n.atter in the PSAR, cn? reference to other than textual (exclusive of foot-note) matter in your Safety Evaluation, then set forth com-fpletely the text ~ of each such reference or attach a copy.

, 310. Describe in detail your review and analysis, statin 5 each fact, calculation and assumption thereof, of the 3

Babcock & ~Wilcox Company test on the sodium thiosulfate stability under storage and accident conditions. If in your

~

answerLyou make reference to other than textual (exclusive

.ofEfootnote). matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, "then set' forth~ completely -the text of each such reference or attachfa' copy.

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-311. Describe why substitution of charcoal filters

-i for the reagent spray system will be acceptable considering the total engineered sofquart system, and state if the substi-tution would result in different doses to an individual re-sulting from an i:HA and' an LOCA. Describe in detail each fact, calculation and assumption upon which you base your entire answer. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth com pletely the text of cach such reference or attach a copy.

312. Describe in detail your review and analysis, statin 5 each fact,. calculation and assumption thereof of the Babcock & Ullcox Conpany control rod drive test program to develop the roller-nut type drive and each area which you have identified to B & W where "more details of the tests' results should be addressed." If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR,- or. reference to other than textual (exclu-sive of footnote) matter in your Safety Evaluation, then set forth completely the text of each.such reference or attach a copy.

313. Describe in detail your review and analysis,

< stating each fact, calculation and assumption thereof of the

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_ Babcock & Wilcox Company research development program for heat transfer and fluid' flow investigations. If in your, t

answer you nake reference to other than textual (exclusive

'of: footnote) natter in the PSA2, or reference to other than textual (exclusive of footnote) natter in.your Safety Evalua-tion, then set.forth completely the text of each such reference or. attach a copy.

314. Deceribe in detail each fact, calculation and.

[ assunption comprising the " natters" which you state at page 80 of the Safety Evaluation that you shall " review . . . to assure that sufficient safety nargin is available to prevent events which could~cause departure from nucleate boiling and subse-quent fuel failures." Include within your answer each standard and criteria uhich shall govern your review. If in your answer you make- reference to other than textual (ex;1usive- of foot-note) natter in the PSAR, or reference to other than textual

. (exclusive of footnote) natter in your Safety Evaluation, then set forth completely the text of each such reference or

• attach'a copy. '

315.. Describe in detail your review and analysis, i stating each; fact, calculation and assumption thereof, of the analysis by the Babcock & Wilcox Company of the stresses and deflection of the reactor internals resulting from blowdown forces _ gn a LOCli._ If in your answer you make reference to

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f other than textual (exclusive of footnote) . matter in the PSAR, or reference to other than textual'(exclusive of footnote)

' matter in your Safety Evaluation, then set forth completely.

the text of.each such reference or attach a copy.

316. Describe in detail what aspects of a reactor system design must be completed or you insist upon being com-

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plcted before the issuance of a construction permit. If in your answer you make reference to other than textual (exclu-sive of footnote) matter in the PSAR, or reference to other than textual' (exclusive of footnote) matter in your Safety l

Evaluation, then set forth completely the text of each such reference or attach a copy.

317 . Describe in detail each fact, calculation and assumption which forms the basis for your determination that the estimated costs of production plant construction and the fuel-requirements for the first core of each unit are reasonable. .If in your answer you make reference to other than textual -(exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter-in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

318. Identify and list each standard, objective and criteria pursuant to which you evaluated the PSAR and the design and proposed construction of the proposed Midland Units. State

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-whetherLany such standard, objcetive and criteria is different' ti from.thoce used in connection ~with evaluation or review or 6

approval'of any license 'or permit for each other PUR plant

, 'which you rely upon.in any.way in connection with the Midland Safety Evaluation. :If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) 1 matter in your Safety Evaluation, then set forth completely i , the text of each such reference or attach a copy.

319 With respect to the statements that "Other problens'related to large water reactors have been identified by the Regulatory Staff and the ACRS and cited in previous ACRS reports.. .. " and "The Committee believes that resolution of

.these items = should apply equally to the Midland Plant Units 1

&2.. .. , which statements appear at page 97 of the Safety Evaluation, answer the follouing in detail:

(a) List and describe in detail each of these other problems and items; (b) -Set forth when each of these other problems and items were first identified in any ACRS

' letter or at any time by the Reculatory Staff,

'specifying each large_unter reactor as to i:hich it.related;

.(c) From'the time of the. identification of each 4

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'such problem.or. item state what research

~has been done and what results have been obtained, if any, separately by the nublear industry or~any part thereof, and/or by the Atomic Energy Commission or sponsored by it to resolve these problems or items;

=(d) Uith respect to each large water reactor as to which each such problem or item has been identified, state whether the problem or item was resolved (1) prior to construction and (ii) prior to operation of each such water reactor, and-if not, why not; (e) What-research is propcsed-to be accomplished-for each of the problems or items still un- <

resolved generally and with specific reference to the proposed Midland Units. Include within your answer a schedule of when such research toward resolution of each such problem or item -

will-be completed or is planned to be completed; and (f) .With respect to a' letter by Joseph M. Hendrie

dated the:12th day of Hovember, 1969, to Glenn T. Seaborg, relevant portions of which are as

, follows:

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"The Committee has been recently informed that overall reactor safety funding for FY 1970 and 1971 will be considerably t

below the AEC estimates of need for the i water reactor safety research program, as well as for safety research on seismic effects . . . , and on environmental effects. As a consequence, many safety research activities have not been initiated, have been slowed, or have been terminated.

The Committee reiterates its belief in the urgent need for additional research and development . . .. . . . more effort should be devoted to gaining an understanding of modes and mechanisms of fuel failure, possible propagation of fuel failure, and generation of Iona.:ly high pressures if hot fuel and coolant are mixed, and that effort should commence on gaining an understanding of the various mechanisms of potential importance in describing the course of events following

. . partial or large scale core melting, either at power or in the . . . event of a loss-of-coolant accident."

state whether funding has been a delimiting factor

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,.. in the -resolution of any of the aforesaid problems. or items and if so, why the pro-liferation of nuclear plants and approval by you of the construction of the proposed JMidland-Units has taken precedence over the resolution (for funding reasons or otherwise) ,

of each such problem or item denominated as a safety concern by'the Regulatory Staff and the-ACRS.

If:in your answer you make reference to other than textual (exclu-sive.of_ footnote) matter in the PSAR, or reference to other than

' textual (exclusive of footnote) matter in your Safety Evaluation,

.then set forth completely the te'xt of each such reference or attach a copy.

3' 2 0 . There is no Interrogatory Number 320.

321. Describe in detail each problem or item other fthan those referred to in your answer to Interrogatory No. 89

,above which are_ safety related and are not resolved because of lack of research by the nuclear industry, or by the Atomic Energy Commission or any-part thereof for lack of funds er any other reason. IfLin your answer you make reference to other than

- textual (exclusive of footnote) matter in the PSAR, or reference to1other-'than textual (ex.clusive of footnote) matter in your

- Safety l Evaluation, then set .forth completely the text of each such reference or attach a copy.

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• l 322. Do genetic considerations or factors form any part or basis in establishing or reviewing FRC Radiation Guide-lines or AEC regulations based in whole.or in part thereon, and if so, what consideration, if any, was given by the forme'r FRC and the AEC in establishing or reviewing such radiation guidelines and regulations to data concerning somatic risks from -the Court-Brown and Doll study (1965) which indicated a steep increase in cancer risk from radiation exposure. If in your answer you make reference to other than textual (exclu-sive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such

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reference or. attach a copy.

323 Describe in detail what systems and methods of rad waste handling, if any, are under development to prevent opera-tional and accidental release of Xenon, Krypton and other noble gases. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

324. Describe in detail what consideration, stating each fact, calculation and assumption thereof, was given to the possibility of building the proposed Midland Units under-

, -ground including the cost thereof. If the possibility of placing

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the Units undcrground was not considered, state why not.- If in your. answer you make reference to other than textual (exclu-sive of. footnote) matter in'the PSAR, or reference to'other than textual (exclusive ~ of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or, attach a copy.

325 Uhat limits are or will be imposed upon Dow expansion plans beyond which would require a review or evaluation 1

of such expansion upon the safety of the proposed Midland Units.

If in your answer you make reference to other than textual (exclu-sive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote ~) matter in your Safety Evaluation, then set forth completely the text of each such

. reference or attach a copy.

326. In the event _that the present insurance policies proposed to be entered into by Applicant are not entered into or are cancelled by their terms, what steps do you propose to J

take,-such as, for example, requiring Applicant to establish a sinking fund to account for third party liability losses as

. for tihich Applicant would be responsible in the event of a major accident _ during the design, constructicn or operating phase of the proposed Midland Units. If in yo'.'r answer you make reference to other than textual (exclusive of footnote) matter '

in the PSAR., or reference to other than textual (exclusive of

4 g  % v footnote)' matter in your Safety Evaluation, then'ce't forth completely the text of each 'such reference or attach ~ a copy.

327 Is it your opinion that the Applicant has described the principal architectural and engineering criteria for the desi6n of the propoaed Midland Units. If so, then list each such principal architectural and engineering criterion.

If in your answer yo.1 make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive.of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

328. Is it your opinion t' hat the Applicant has identified the major features or components incorporated in the design of the prcpoced Midland Units for the protection of health and safety of the public. If it is, then list each such major feature or component. If in your answer you make reference to other than textual (exclusive of footnote) matter-in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

329 Is it your opinion that there are further technical or. design informaticn3 which are required to com-plete a safety analysis of the propoced Midland Units. If so, then. list and describe in detail all;such furfher technical or

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-design-informationn. In aihlltion., u t.:t'Le wi th c. ::pec L Li., en. h

'such category of further technical or design infornation whether Tits completion can reasonably be left for later consideration and if.it isiyour opinion that it can, then state each fact, calculation and assumption upon which you base your opinion.

If-in your answer you make reference to other than textual-(exclusive of. footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth ccmpletely the text of each such reference or~ attach a copy.

330- Is it your opinion'that there are safety features or_ components ~ with respect to the proposed Midland Units which require.further research and development prior to design?

' If so, then. describe each such safety feature or component and with respect to each one, state the following:

(a) lias the research and development adequately been described by the Applicant -and, if so, provide a reference of such description; and (b) If it has been described, has the Appliaant identified a'research and development. program reasonably. designed to resolve safety quest?.ons associated with such features and 'omponents c and, if:so, for each such safety feature or component with respect-to its research and-development

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F p rot <,rnm , nt.ttle . each I':te, L , c: Letil n L i oli nit <l assumption'upon which you conclude that it is

" reasonably designed to resolve any safety questlons associated thercuith."

If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other. than textual (exclusive of footnote) matter in your Safety Evaluation, then set forth completely the text of each such reference or attach a copy.

331. Describe in detail what cooperative effort by the AEC, the nuclear industry and the utilities is in progress to improve-the collection of data needed to evaluate the reliability and causes for failure of safety-related systems 11n nuclear plants. In addition, state whether such efforts have been or will be used with respect to the proposed Midland Un its and whether the suggestions regarding the improvement r

of data collection set forth in the Report to the Atomic Energy

. Commission on the Reactor Licensing Program by an internal study group headed by Harold G. Mangelsdorf in June 1969, have been orfare planned to be implemented as regards the proposed

- Midland-Units. If in your ansuer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or

- reference to other than tcxtual (exclusive of footnote) matter

. in:your Safety Evaluation, then set forth completely the text ofr each such reference or attach a ccpy.

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JU'.. ;11 f.li : i ::pe t 1. t.o y ditr .re.y1. u of' I li, : f'e ! y .y..!<i:tn i

of the' proIi oned I!idland Units and other pressur.1ned watee reactors and the development of techniques for comparative and quantitative evaluation of risks which was suggested.in

. the Report to the_ Atomic Energy Commission of the Reactor Lice:' sing Program by the Internal Otudy Group headed by Harold G. Mangelsdorf in June 1969, describe in detail, stating each

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fact, calculatf.on and assumption thereof, what you have done or plan to do concerning each of the following:

(a) Making comparisons mnong alternate safety systems in light of technological differences among pressurized water reactors concerning a system for a given purpose and their components; (b )' Making measurements of the relative protection provided against several postulated accidents to help decide which should receive the most attention; (c) Deciding if the problems caused by additional complexity from adding a safety system outweigh the advantages of that system; (d) Measuring on a uniform basis the relative gain in safety provided by an additional safety feature; (e) Extrapolating from experience with small acci-dents to quantitative judgments regarding

_58-

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t potential serious accidents; (f) Identifying potential failure modes; (g) Developing information on failure rates of equipment and probabilities of postulated accidents; and (h) Establishing levels of risk resulting from operation of. nuclear power plants.

If in your. answer you make reference to other'than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluacion, then set forth completely the text

- of each such reference or attach a copy.

333 state, regarding the proposed Midland Units,

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your opinion as to whether there will or will not be cracking, bulging, bowing, disintegration or other defamation of the fuel rods during blowdown, heating and cooling in a LOCA with the emergency core c olins system operating, describing each fact, calculation, assumption and analysis upon which you base your opinion. Include within your answer whether the occur-

-I-rence of any such cracking, bulging, bowing, etc. Will inter-fere-with the effective operation of the emergency core cool-ing system, also including each fact, calculation, assumption and analysis upon which you base your answer. If your answer is.

l that there.will or might.be interference with the emergency i l

core cooling system, state uhether there exists an' alternate 1 1

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. design offthe emergency core cooling system or any other system to mitigate or prevent such interference. State each

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fact, calculation and assumption upon which you base your answer,_and if'such ansuer is based upon experimental data, describeindetalicuche$perimentsandtheresultsthereof.

Also state if such experiments were performed on a signifi-cant scale in uhich successful operation has been demonstrated.

If in your answer you make reference to other than textual

. (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your SafetyLEvaluation, then set forth completely the text of each such reference or attach a copy.

334. Describe in detail, stating each fact, calcula-tion and assumption, what experimental verification supported by analysis you have obtained at all temperatures related to a'LOCA'to verify that the situation is controllable. If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to other than textual (exclusive of footnote) matter in your Safety Evaluation, 60-J v

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e then set forth completely the text of each such reference or attach a copy.

335 Unless-otherwise covered by your answers to these' Interrogatories (and if so covered,'specify the answers),

state in detail the following:

-(a) The names, titles and positions of each person whom you presently plan to call upon to intro-duce oral or written testimony upon your behalf-in the course of the pending hearing; (b) The area or areas which will be the subject of each such person's testimony; and (c) A description of each document or writing (as that term is defined in Interrogatory No. 337 below) which you intend to introduce in the course of the pending hearing in support of your position or positions.

If in your answer you make reference to other than textual (exclusive of footnote) matter in the PSAR, or reference to -

other than textual (exclusive of footnote) matter in your Safety

. Evaluation, then set forth completely the text of each such reference or attach a copy.

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336. Separately for Applicant, Dow Chemical Company,

.Dou-Corning Company or-any subsidiary of Dow Chemical or Dow-Cornin.

i Babc6ck'& Wilcox Company and Bechtel CorpordTion, state if-they

-have ever been cited for or investigated about a violation or.

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I alleged violation, at any time, of the Atomic Encrgy Act, any

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of its rules, regulations or order , an Atomic Energy Commission license or any of its technical specifications or the rule, order, decree, regulation of any state or other federal agen'cy or official having any manner of ~ jurisdiction over any of their operations which are' the subject of an Atomic Energy Commission license or other Atomic Energy Commission jurisdiction. If so, then:

(a) Describe in detail each instance of each such citation or investigation; (b) List and identify in sufficient detail a des-cription of eadi writing as defined in Inter-rogatory No. 337 below which is in your possession or control.with respect to each such citation or investigation; (c) State and describe the resolution, if any, of each such citation or investigation; and.

(d) State what steps you have taken to prevent cir-cumstances which led to each such citation or investigation from occurring again or occurring at the proposed Midland Units.

If in your-answer you make reference to other than textual (exclusive of. footnote) matter in the PSAR, cr reference to other than textual (exclusive of footnote) matter in yent Safety'Evalua-ion, then set forth completely the text of each

-such reference or attach a copy. .

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t 337. . List and describe in sufficient detail so that it can be identified, each document which is in your possession or uhder your control which relates to, refers to or concerns

-any-of_the following:

(a) Your participation in any way in the designing, constructing or operating.of the proposed Mid-land Units; (b) 'Your evaluation of the proposed Midland Units regarding its siting, its designing, its con-

= struction, its safety or its proposed operation; (c) Financial aspects of.the building, designing or constructing of the proposed Midland Units, including but not limited to the sale of pro-J-

' cessed steam, to anyone, for industrial purposes;  !

(d) Your decision to approve of a participation in  !

I any way in-the designing, constructing or secur- )

ing of a construction permit for the propos,ed l Midland Units; and (e) Any Interrogatory or answer to-any Interrogatory filed herein.

As.used within these Interrogatories, the word " writings" or -

words of similar import.shall-include al1~ written, typed,

printed and photostated natter, including photographs, duplicate 63-1 l

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. . . . /- % . 4A l l-writings an to which you may claim priv.'.lege in order t. hat. l l

opportunity for argument thereon may be had. '

Saginaw Valley Nuclear Study Group Citizens Committee for the Environ- i mental Protection of Michigan l Sierra Club  !

United Auto Workers of America l Trout Unlimited .

West Michigan Environmental  !

Action Council, Inc.

Environmental Law Society of the University of Michigan Law Students' By Q -

!(lILMT Myroti3./ Cherry, their'attor

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h Dated: . March 22, 1971.

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4 originals, carbon copies, Thermofax copies, photoctatic copics and other copies thereof, including drafts thereof, in your possession, custody or control, written, made, delivered or received at any time up to and including March 22, 1971, including, without limiting the generality of the definition, all correspondence, telegrams, memoranda, minutes of meetings, client memoranda, account cards, leases, documents of title, receipts, cancelled checks, bank statements, records of tele-phone calls, summaries'of meetings, agreements, contracts and notes, whether formal or informal.

At~your option, depending upon convenience to all other parties thereof, instead of answering this Interrogatory you may choose to follow either the suggestion made in a let-ter by Myron Cherry to all counsel dated March 8,. 1971, or the more formal method of depositions under oath. If you do not so choose by notice to us within ten days after receipt of these Interrogatories, you shall be required to answer this Interrogatory.

Finally, this Interrogatory or any other alternative methods of. identifying relevant writi.ngs are not intended to call:for writings which are subject to a valid privilege; however, you'shall be required to describe generally the a-Y <-- y