Interrogatories & Document Requests Submitted to NRC by Citizens Energy Forum.Requests Info Re Contentions 1,2 & 5, Radioactive Emissions & Corrosion & Thermal Effects. Certificates of Svc EnclML19224D710 |
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North Anna |
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Issue date: |
05/31/1979 |
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From: |
Kroot I CITIZENS ENERGY FORUM |
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To: |
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References |
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NUDOCS 7907160156 |
Download: ML19224D710 (5) |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20112B1381985-03-12012 March 1985 Response to Applicant Request for Production of Documents & Interrogatories.Related Correspondence ML20112B1301985-03-12012 March 1985 Response to NRC Staff Interrogatories & Request for Production of Documents.Related Correspondence ML20114B7691985-01-24024 January 1985 Responds to Concerned Citizens of Louisa County Request for Production of Util Interrogatories.Certificate of Svc Encl. Related Correspondence ML20101D0341984-12-15015 December 1984 Request for Production & Interrogatories to Util Re Spent Fuel Pool.Certificate of Svc Encl.Related Correspondence ML20101D0371984-12-15015 December 1984 Motion Requesting ASLB to Direct NRC to Respond to Interrogatories & Request for Production Re Spent Fuel Pool. Related Correspondence ML20101D0421984-12-15015 December 1984 Request for Production & Interrogatories to NRC Re Spent Fuel Pool.Certificate of Svc Encl.Related Correspondence ML20101A2261984-12-14014 December 1984 Requests Production of Documents & Interrogatories to Concerned Citizens of Louisa County Re Consolidated Contention I.Certificate of Svc Encl.Related Correspondence ML20023D0931983-05-16016 May 1983 Response to Request for Production of Documents.Production Will Be Permitted Subj to Encl Stipulation of Confidentiality.Certificate of Svc Encl ML20076D0581983-05-16016 May 1983 Response to Interrogatories & Request for Documents. Certificate of Svc Encl.Related Correspondence ML20073R1901983-04-29029 April 1983 First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl ML20069K0151983-04-22022 April 1983 Request for Production of Documents ML19225C8351979-06-20020 June 1979 Responds to Citizens Energy Forum 790601 Interrogatories & Document Requests.Drawings of New Spent Fuel Pool Racks Are Proprietary.Submits Info Re Thermal Effects,Radioactive Emissions & Corrosion ML19225C8311979-06-20020 June 1979 Responds to Potomac Alliance 790601 Interrogatories & Document Requests.Names & Areas of Expertise of Proposed Witnesses Can Be Found in Util 790620 Response to Citizens Energy Forum Interrogatories & Document Requests ML19246B7851979-06-11011 June 1979 Answers Submitted by Citizens Energy Forum to Util 790517 Interrogatories & Document Requests.Submits Info on Contentions Re Thermal Effects,Radioactive Emissions,Spent Fuel Pool & Corrosion.Certificate of Svc Encl ML19246B4011979-06-0606 June 1979 Answers Submitted by Potomac Alliance to Util Interrogatories & Document Requests Re Contentions on Radioactive Emissions,Missile Accidents & Matl Integrity. Notice of Appearance of LS Lempert on Behalf of Intervenors ML19246B5811979-06-0101 June 1979 Interrogatories & Document Requests Submitted to VEPCO by Citizens Energy Forum.Requests Info Re Thermal Effects, Radioactive Emissions & Corrosion.Certificate of Svc Encl ML19225A0831979-06-0101 June 1979 Interrogatories & Document Requests for NRC Submitted by Potomac Alliance.Requests Info on Spent Fuel Pool Re Alternatives,Tornado Damage,Turbine Missile Damage,Defective Fuel Rods & Changes in NRC Requirements ML19225A0901979-06-0101 June 1979 Interrogatories & Document Requests to Util Submitted by Potomac Alliance.Requests Info on Spent Fuel Pool Re Diagram,Const Progress,Transfer of Fuel,Alternatives to Proposed Mod & Logistics of Handling Spent Fuel ML19224D7101979-05-31031 May 1979 Interrogatories & Document Requests Submitted to NRC by Citizens Energy Forum.Requests Info Re Contentions 1,2 & 5, Radioactive Emissions & Corrosion & Thermal Effects. Certificates of Svc Encl ML19224C8141979-05-30030 May 1979 Responses to NRC Interrogatories & Document Requests.Answers Contentions 3,4,6 & 7,re Missile Accidents,Matl Integrity, Occupational Exposure & Alternatives.Certificate of Svc Encl ML19241B2531979-05-29029 May 1979 Responds to NRC 790502 Interrogatories & Document Requests, Submitted by Citizens Energy Forum.Forwards Info Re Contentions 1,2 & 5,thermal Effects,Radioactive Emissions & Corrosion.Certificate of Svc Encl ML19241B1391979-05-17017 May 1979 Interrogatories & Document Requests for Intervenor Citizens Energy Forum Submitted by Util.Contentions Were Stated in ASLB 790421 Order.Certificate of Svc Encl ML19224D6541979-05-17017 May 1979 Interrogatories & Document Request Submitted to Intervenor Potomac Alliance by Util.Contentions Were Stated in ASLB 790421 Order.Certificate of Svc Encl ML19270G9511979-05-0404 May 1979 Response to 790407 & 10 Interrogatories & Document Requests from Intervenor G Arnold Re Pumphouse Settlement. Supporting Documentation Encl ML19270G9491979-05-0404 May 1979 Forwards Response to 790407 & 10 Interrogatories & Document Requests from Intervenor G Arnold.Objects to Some Questions & Requests That Are Irrelevant to Pumphouse Settlement.Certificate of Svc Encl 1985-03-12
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20148M6511997-06-18018 June 1997 Comment Opposing Proposed Suppl to Bulletin 96-001 That Would Request Licensees to Take Action to Ensure Continued Operability of Control Rods L-95-045, Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors1995-10-19019 October 1995 Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors ML20080M1121995-02-27027 February 1995 Comment Re Proposed Suppl 5 to GL 88-20 IPEEE for Severe Accident Vulnerabilities. Proposed GL Suppl Should Indicate That Licensees Can Use Llnl Hazard Results of NUREG-1488 Re Revised Hazard Estimates Instead of NUREG/CR-5250 ML20073M0751994-09-23023 September 1994 Comment on Proposed Rules 10CFR30,40,70 & 72 Re Clarification of Decommissioning Funding Requirements. Permitting Access to Funds Only on Semiannual Basis Seems Unnecessarily Restrictive ML20069L5291994-06-13013 June 1994 Comment Supporting Proposed Rulemaking 50-60 Re Petition for Rulemaking & Changes to 10CFR50.54 ML20029D8251994-04-29029 April 1994 Comment Supporting Elimination of Proposed 5-yr Implementation Schedule & Believes That Current Programs Adequate to Maintain Containment Integrity ML20044G1971993-05-24024 May 1993 Comment Supporting Draft Insp Procedure Re Commercial Grade Procurement & Dedication ML20044E5721993-05-19019 May 1993 Comment Supporting Proposed Generic Ltr for Relocation of TS Tables on Instrument Response Time Limits ML20044D3271993-05-0707 May 1993 Comment Opposing Proposed GL Availability & Adequacy of Design Bases Info ML20125B6141992-12-0303 December 1992 Exemption from Requirements of 10CFR50,app a Re GDC-2 & 10CFR50.49 Re Environ Qualification of Electric Equipment Important to Safety for Nuclear Power Plants ML20095J6881992-04-23023 April 1992 Comment Opposing Draft Reg Guide DG-1022, Emergency Planning & Preparedness for Nuclear Power Plants ML20077R5161991-08-14014 August 1991 Comment Supporting Petition for Rulemaking PRM-20-20 Re Reduced Total Effective Dose Equivalent to Individual Members of Public from 0.5 Rem (5 Msv) to 0.1 Rem (1 Msv) ML20235N8531989-02-14014 February 1989 Comment Supporting Chapter 1 Re Policy Statement on Exemptions Below Regulatory Concern.Policy Development for Criteria for Release of Radioactive Matl Needed for Development of Consistent Waste Mgt Practices ML20235P3311989-02-0808 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20236P5851987-11-0909 November 1987 Transcript of 871109 Briefing in Washington,Dc Re Facility Steam Generator Tube Rupture Event.Pp 1-56.Supporting Documentation Encl ML20138N5311985-11-0101 November 1985 Memorandum & Order Affirming ASLB 850903 Initial Decision Authorizing Director of NRR to Issue License Amend for North Anna to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry Power Station.Served on 851101 ML20133K7171985-10-18018 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133K6801985-10-18018 October 1985 Forwards Notice of Withdrawal of Appearance in Proceeding. Requests Svc List Be Revised to Include Client Under Listed Address.W/O Encl ML20133F4241985-10-0909 October 1985 Order Stating That ASLB 850903 Initial Decision Authorizing NRR to Amend OL to Permit Receipt & Storage of Spent Fuel Should Not Be Deemed Final,Pending Further Order. Served on 851009 ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N6981985-09-0303 September 1985 Initial Decision LBP-85-34 Authorizing NRR to Issue Amends to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Initial Decision Effective Immediately.Served on 850904 ML20134N4381985-09-0303 September 1985 Order Granting Licensee 850621 Request to Correct Transcript.Proposed Transcript Corrections & Certificate of Svc Encl.Served on 850904 ML20129K1251985-07-18018 July 1985 Brief in Support of NRC 850718 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing Issuance of Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129K1281985-07-18018 July 1985 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing NRR to Issue Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129F8231985-07-12012 July 1985 Reply Opposing Concerned Citizens of Louisa County post- Hearing Brief.Licensee Proposed Findings of Sabotage & Human Error Not Addressed.Challenge of NRC EIS Conclusion Unnecessary.Certificate of Svc Encl ML20209F0021985-07-0808 July 1985 Post-hearing Brief Re Issues Raised at ASLB 850521 & 22 Evidentiary Hearings.Nrc Required by NEPA to Evaluate Alternative of Constructing & Operating Dry Cask Storage Facility,But Failed to Perform Even Cursory Review ML20209F2041985-07-0808 July 1985 Proposed Findings of Fact & Conclusions of Law Re Application for Amend to Ol,Authorizing Licensee to Ship 500 Spent Nuclear Fuel Assemblies from Surry Power Station to North Anna Station.Certificate of Svc Encl ML20128H0791985-07-0808 July 1985 Order Granting Concerned Citizens of Louisa County 850627 Motion for 7-day Extension Until 850708 to File Proposed Findings of Fact & Conclusions of Law.Served on 850708 ML20128G9471985-06-27027 June 1985 Motion for Extension of 850701 Deadline to File Proposed Findings of Fact & Conclusions of Law.Addl Wk Required Due to Addl Legal Duties.Certificate of Svc Encl ML20127F0511985-06-21021 June 1985 Proposed Findings of Fact & Conclusions of Law Re Util 820713 Application to Amend Ol,Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.Unsigned,Undated Order & Certificate of Svc Encl ML20127F0451985-06-21021 June 1985 Post-hearing Brief Requesting Board Find in Util Favor Re Proposed OL Amend Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.No Basis from Sabotage or Human Error Considerations for Denying Proposed Amend ML20128A7731985-05-22022 May 1985 Transcript of 850522 Hearing in Charlottesville,Va.Pp 313-364.Supporting Documentation Encl ML20125C4081985-05-21021 May 1985 Applicant Exhibit A-H-11,consisting of Undated,Untitled Photograph H ML20125C3601985-05-21021 May 1985 Applicant Exhibit A-B-5,consisting of Undated,Untitled Photograph B ML20125C4221985-05-21021 May 1985 Applicant Exhibit A-J-13,consisting of Undated,Untitled Photograph J ML20125C3471985-05-21021 May 1985 Applicant Exhibit A-3,consisting of SAND82-2365, Assessment of Safety of Spent Fuel Transportation in Urban Environs, Dtd June 1983 ML20125C4301985-05-21021 May 1985 Applicant Exhibit A-K-14,consisting of Undated,Untitled Photograph K ML20125C3941985-05-21021 May 1985 Applicant Exhibit A-F-9,consisting of Undated,Untitled Photograph F ML20125C4361985-05-21021 May 1985 Applicant Exhibit A-L-15,consisting of Undated,Untitled Photograph L ML20125C3101985-05-21021 May 1985 Staff Exhibit S-1,consisting of Undated Environ Assessment & Finding of Proposed No Significant Impact Re 820713 & 0820 Applications for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,allowing Receipt & Increased Storage of Spent Fuel ML20125C3411985-05-21021 May 1985 Applicant Exhibit A-2,consisting of 830915 Procedure 1-OP-4.19, Receipt & Storage of Spent Fuel TN-8L Shipping Cask Unloading & Handling Procedures ML20125C3291985-05-21021 May 1985 Staff Exhibit S-3,consisting of Forwarding NMSS Apr 1985 Environ Assessment Re 821008 Application for Authority to Construct & Operate Dry Cask ISFSI at Surry Power Station ML20125C4001985-05-21021 May 1985 Applicant Exhibit A-G-10,consisting of Undated,Untitled Photograph G ML20125C3381985-05-21021 May 1985 Applicant Exhibit A-1,consisting of 831104 Procedure OP-4.3, Shipping of Spent Fuel TN-8L Shipping Cask Loading & Handling Procedures, for Surry Power Station ML20125C3711985-05-21021 May 1985 Applicant Exhibit A-C-6,consisting of Undated,Untitled Photograph C ML20125C3791985-05-21021 May 1985 Applicant Exhibit A-D-7,consisting of Undated,Untitled Photograph D ML20125C3821985-05-21021 May 1985 Applicant Exhibit A-E-8,consisting of Undated,Untitled Photograph E ML20125C3501985-05-21021 May 1985 Applicant Exhibit A-A-4,consisting of Undated,Untitled Photograph a ML20125C3191985-05-21021 May 1985 Staff Exhibit S-2,consisting of Undated Safety Evaluation Re Increasing Spent Fuel Storage Capacity.Proposed Mods to Spent Fuel Pool & Transshipment/Storage of Spent Fuel Acceptable ML20125C4131985-05-21021 May 1985 Applicant Exhibit A-I-12,consisting of Undated,Untitled Photograph I 1997-06-18
[Table view] |
Text
@pTLD ConymoWN
" s O ewm rg" NRC PUBLIC DOCUENT tof>M
.;-, UNITED STATES OF AMERICA b igg 31973)
L3 NUCLEAR REGULisTORY COMMISSION
%,, ,w*-q gas s BEFORE THE ATOMIC S AFETY AND LICENSING BOARD _ _
'h 9~\r 4 O.In the Matter of
))Docket Nos. 50-338 SP VIRG;NIA ELECTRIC AND POWER COMPANY
)50-339 SP)(Nocth Anna Power Station,)(Proposed Amendment to Units 1 and 2)
)Operating License NPF-4)
INTERROGATORIES TO NRC STAFF FRCT.i CEF Intervenor Citisens' Energy Forum (CEF) hereby requests that the Nuclear Regulatory Commission (NhC) Staff, pursuant to 10 CFR E2 740b, answer separately and fully, in writing under oath or affirmation, the following interrogatories wi+hin 14 days of service hereof. The person answering each question should set forth his or her name and title, and should identify any other individual who fcrnishes information on which the answer to the question is based.
In addition, for each contention herein named, identify the person or persons (if any) whom the NRC staff intends to have testify on the subject matter of that issue.
State the professional qualifications of that person, and pro-vide a summary of his or her proposed testimony.
Also identify fully an}- books or other documents to be relied upon in presenting testimony on that contention.
Cont _antion 1 : Thermal Effects 1-1 What is the basis for the statement in secticn E.3 of the
, Environ ~. ental Impact Aporai. sal by tl.e Offica of Huclear
,;-_7907160 /66
' ...Reactor Reculation Relative to a Pronosed Increase in Storare Caracity of the Scent Suel Pool (hereafter re-ferred to as EIA), dated April 2,1979, that "any additional
.atmospheric effects' of its oceration such as ' fogging and
-icing are unlikely to occur offsite"?
Provide the facts and. analyses leading to such conclusion.
1-2 What is the basis for the statement in section 4 3 of the 6 EIA that "The addition of 5 6 x 10 Btu /hr to the total dis-charge from Units 1 and 2. . . would not have noticeable in-cremental effects on aquatic biota or the environment. "?
Provide the facts and analyses leading to such conclusion.
1-3 How much of the 1,905,600 gpm of water which is drawn from Lake Anna to circulate through the steam generators is~
-returned to the Lake after going through the waste heat treatment facility?
How much is lost through evaporation?
What percentage of le total water from the lake lost through evaporation will be due to the additional heat to be dis-sipated if the proposed modification is carried out?
Contention 2: Radioactive Emissions 2-1 The Safety Evaluation by the office of Nuclear Reactor Reculation Relatine to Modification of Ine Spent Puel Storace Rackr (hereafter referred to as SER), dated Jan.
29, 1979, states that "The fuel racks could slide under
.seismic conditions..." What would the effect be on the 350 310 ..in the_ pool, if these pool and racks, and'on the keff seismic conditions were to cause 2 or more. racks to slide closer together than the planned 14" center-to-center spa-cing?How far, and in what lirections, are the racks de-signed to slide under seismic conditions? 2 The SER states that "we conclude that the likelihood of a heavy load handling accident is sufficiently small so that the acceptability of the porposed modification is n ;t af-fected..." On what basis is this conclusion reached?
In what specific way was such a likelihood calculated?
%-3 Section 4.4.1 of.'the. 'EIA states that "most of the gaseous fission proddets have sh'crt half-lives and decay to insig-
'nificant levels within a few months." What are the res't'of the gas'ous fission product's,-those with' longer half-lives?
e Provide a detailed list' o'f- als gaseous fission proddct' s ex-pected -from spent fuel' assemblies to be stored in the pool.
.2-4 Section 4.4 3 of the EIA states Storing additional spent fuel assemblies should not in-crease the bulk water temperature during normal refuel-ings above the 140*F used in the design analysis.
There-fore, it is not expected that there will be any sig-nificant change in the annual release of tritium or iodine from that previously evaluated in-the FES.
.How do the bulk water temperatures relate to the expected releast of H3 or I from the spent fuel pool?
Contention
- Corrosi on
, 5-1 What will be the effect of the 40,4 heat load increase (as 350 311 ,.. -cited in the SER) on tne rate of corrosion of the zir-conium alloy cladding of the spent fuel assemblies?
What will be the effect on the corrosion rate of the stainless steel racks?
5-2 The SER states, in section 2.6, that "the additional spent fuel in the pool will increase the amount of corrosion and fission proddcts introduced into the cooling water to some extent.,." What effect on workers is postulated through maintenance of the fuel pool purification system (e.g.
changing filters) given this additional load on the puri-fication system? 3 What procedures does the NRC require or recommend for the detection of defective spent fuel storage racks?
5-4 What procedures are required or recommended by the NRC in the event of discovery of defective spent fuel storage racks?5-5 What are the costs, advantages, end disadvantages of using (a) boron panels, and (b) borated water, in spent fuel pools?
Respectfully submitted,-Irwin B. Yeoot, for CEF
.Dated this 31st day of May, 1979, in Bethesda, Maryland.
_50 LI!, , , , .'>
, , RE.LiTED COMU'5 POST)DEE CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing Interrogatories to NRC Staff from CEF has been mailed this 31st day of May, 1979, by deposit in the U.S. Mail, first class, to the following:
Secretary p.W N US Nuclear Regulatory Commission
- Washington, D.C. 20555 o02 , Attn Chief, Docketing and Service Section
ac 2 6-1 James Dougherty, Esq.
- JUN 5197.8)
-AY P.O. Box 9306 g.ao%Washington, D.C. 20005
- gt " D th Y k Michael Maupin, Esq.
- Hunton & Williams P.O. Box 1538 Richmond, Va.
23212 Steven C..Goldberg,.Esq..
Dr. Quentin J. Stober Office of the Executive Legal Fisheries Research Institute Director University of Washington US Nuclear Regulatory Commission Seattle, Wash.
98195 Washington, D.C.
20555 Atomic Safety & Licensing Board Valentine 3. Deale, Esq., Chairman Panel Atomic Safety a .d Licensing Board US Nuclear Reculatory Commission 1001 Connecticut Ave., NW Washington, D.C. 20555 Washington, D.C.
20036 Atomic Safety & Licensing Appeal Mr. Ernest Hill Board Panel Lawrence Livermore Laboratory US Nuclear Regulatory Commission University of California Washington, D.C.
20555 P.O. Box 800, I,-123 Livermore, Califormia 94550/Db77 Ir. win 3.
Kroot, for CEF
.7 ,lJ}I}O)