Outline of Areas of cross-examination,submitted Per 790329 Pretrial Order.Certificate of Svc Encl| ML19289F185 |
| Person / Time |
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| Site: |
Salem  |
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| Issue date: |
04/25/1979 |
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| From: |
Macartor J
DELAWARE, STATE OF |
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| To: |
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| References |
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| NUDOCS 7906040388 |
| Download: ML19289F185 (3) |
|
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[Table view] |
Text
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NRC PUBUC DUNITED STATES OF AMERICA NY I NUCLEAR REGULATORY COMMISSION 9
&q$& 2 Before the Atomic Safety and Licensing Board * @
w In the Matter of ) Docket No. 50-272
)
PUBLIC SERVICE ELECTRIC S GAS COMPANY) Proposed Issuance of
) Amendment to Facility (Salem Nuclear Generating Station, ) Operating License Unit 1) . ) No. DPR-70 OUTLINE OF THE AREAS OF CROSS-EXAMINATION In response to the Pretrial Order of March 29, 1979, as clarified in the conference call of April 13, 1979, which was memorialized by Lower Alloways Creek Township on April 16, 1979, the folleving outline of the areas of cross-examination is filed.
- 1. The effect on the Delaware River and Bay and its resources of any potential leakage.
- a. Any methods of detection of containment breaches.
- b. The effects of major or minor accidents.
- 2. The provisions for monitoring any change in material, particulary any material that affects criticality.
- a. The mechanical intergrity of the boran shielding.
- b. The integrity of the welds of shcating materials,
- c. Changes in material due to corrosion.
- 3. The safety factor allowed in the K eff calculation,
- a. Provisions for replacement of materials if needed.
- b. The potential for criticality under various combinations of problems.
{ ]
7906 040 328 t
N N
- 4. The containment building:
- a. Environmental monitoring of exit points in view of increased storage.
- b. The possibilities of breach of the containment building assuming various combinations of problems.
- 5. Provisions for F,round water monitoring.
- 6. The effects of accidents on the population in Delaware within a five-mile circle and a 10-mile circle of the fuel storage building.
A rough estimate of the time needed for Delaware's cross-examination is one hour.
Delaware reserves the right as an Interested State to adelress all relevant and probative points at the time of the evidentiary hearing.
Respectfully submitted, kM -
^&
June D. MacArtor Deputy Attorney General Tatnall Building P. O. Box 1401 Dover, Delaware 19901 Dated: April 25, 1979 2236 183
A
. -
,
CERTIFICATE OF SERVICE I hereby certify that copies of Delaware's Outline of the Areas of Cross-Examination have been served upon the following by deposit in the U.S. Mail this 25th day of April, 1979:
Gary L. Milhollin, Esq. , Chaiman Mark J. Wetterhahn, Esq.
Atomic Safety and Licensing Board for Troy B. Conner, Jr., Esq.
1815 Jefferson Street 17147 Pennsylvama Ave. , N. W. , Suite 1050 Madison, Wisconsin 53711 Washington, D. C. 20006 l'c. Glenn O. Pright, Member Richard Pryling, Jr., Esq.
Atcr. tic Safety and Licensing Bd. Panel Assistant Geneml Solicitor U. S. Nuclear Regulatory Ccmnission Public Service Electic S Gas Co.
Washington, D. C. 20555 80 Park Place Newark, N. J. 07101 Dr. James C. Lamb, III, Member Atomic Safety and Licensing Pd. Panel R. William Potter, Esq.
313 Woodhaven Road Assistant Deputy Public Advocate Chapel Hill, N. C. 275111 Division of Public Interest Advocacy P. O. Box 141 Chairran, Atomic Safety S Licensing Trenton, N. J. 08601 Appeal Board Panel U. S. Nuclear Regulatory Corr:nission Sandra T. Ayres, Esq.
Washington, D. C. 20555 Departrent of the Public Advocate 520 E. State Street Chaiman, Atomic Safety and Licensing Trenton, N. J. 08625 Board Panel U. S. Nuclear Regulatory Comission Mr. Alfred C. Cole an, Jr.
Washington, D. C. 20555 Mrs. Eleanor G. Colennn 35 "K" Drive Barry Smith, Esq. Pennsville, New Jersey 08070 Office of Executive Legal Director U. S. Nuclear Regulatory Commission Carl Valore, Jr., Esq.
Washington, D. C. 20555 Valore, McAllister, Aron S WestTaoreland Mainland Professional Plaza Mark L. First, Esq. P. O. Pcx 175 Deputy Attorney General Northfield, N. J. 08225 Dep1rtment of Ltw and Public Safety
- l'nviror;nental Protection Section Office of the Secretary 36 West State Street Docketing and Service Section Trenton, New Jersey 08625 U. S. Nuclear Regulatory Conmission Washington, D. C. 20555 Keith Ornsdorff, Esq.
Assistant Deputy Public Advocate Departrent of Public Advocate P. O. Fox 141 [
Trenton, New Jersey 08601 g ,
- #D k June D. MacArtor f '
Deputy Attorney General 2236 184