ML19029A860

04/25/1979 Legal Correspondence Outline of Cross-Examination of Evidence Submitted by the Nuclear Regulatory Commission

ML19029A860
Person / Time
Site:	Salem
Issue date:	04/25/1979
From:	Valore C Lower Alloways Creek Township, NJ
To:	Atomic Safety and Licensing Board Panel
References
Download: ML19029A860 (7)

Text

e RELATED C:ORRESPOl\DENC~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Docket No. 50-272 In the Matter of Proposed Issuance of Amendment PUBLIC SERVICE ELEcrRIC to Facility Operating License

& GAS CO. No. DPR-70 (Salem Nuclear Generating Station, Unit #1)

OUTLINE OF CROSS-EXAMINATION OF EVIDENCE SUBMITTED BY~THE NUCLEAR REGULATORY COMMISSION Pursuant to the Pretrial Order of March 29 1 1979 as amended, the Intervenor, Township of Lower Alloways Creek, submits the following outline of proposed cross-examination.

1. Have modifications been considered to the purification system in the event of a loss of water accident in the spent fuel pool at full capacity for storage without room for a full core discharge through 1996?

2. The basis for the statement in the Environmental Appraisal that the major portion of the radioactivity decays in the first 150 days following removal from the reactor core.

3. The basis. for the statement in the Environmental Appraisal that the proposed modification of the spent fuel pool will not change the basic land use of the spent fuel pool.

4. Whether there will be a change in the plant water consumption in the event of a loss of water accident in the spent fuel pool with the pool full without core discharge by the year 1996.

5. That the potential off-site radiological environmental impact associated with the expansion of the spent fuel storage capacity do not consider a loss of water accident in the spent fuel pool or a Class 9 accident or melt down or explosion in the reactor which would involve the spent fuel pool.

6. Has the Environmental Appraisal considered the potential radioactive release of Krypton P.9 and its daughter Strontium 89?

7. Since the NRC has calculated five years would be required to construct. an .. Independent Spent Fuel Storage Installation, (ISFSI), why hasn't the NRC staff taken a position tha;t increased capacity may not be required (given I

expected plant down time) since an ISFSI could be available prior to 264 fuel assemblies being stored in the spent fuel pool.

8. Is the five year estimate for an ISFSI by the NRC in the Environmental Appraisal realistic?

9. How many metric tons of uranium (MTU) are 264 fuel assemblies? 1 1 170 ~uel assemblies?

Page 2

10. The validity of the statement in the Environmental Appraisal that on a* short term basis, i .. e., prior to 1985, an ISFSI is not available for an alternative.

11. In evaluating alternatives in the Environmental Appraisal and the conclusion that the environmental impacts of new storage would be less than the environmental impacts of an ISFSI excludes from its consideration a serious accident involving the* reactor and spent fuel pool at full storage.

12. In considering alternatives, did the NRC consider the ¢!anger to the safety and health of the public ip.

accumulating large amounts of radioactive fuel assemblies in the.spent fuel pool in close proximity to the nuclear reactor considering the probable risks and- consequences that could be associated with those risks.

Estimated time for cross-examination - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> CREEK April 25, 1979

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.. ttUNITED STATES OF AMERICA tt NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensin In the Matter of Docket No.

PUBLIC SERVICE ELECTRIC Proposed Issuance of Amendment

& GAS CO. to Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit #1)

INTERVENOR TOWNSHIP OF LOWER ALLOWAYS CREEK OUTLINE: OF CROSS-EXAMINATION' OF EVIDENCE SUBMITTED BY THE LICENSEE*, PUBLIC-SERVICE ELECTRIC &. GAS' CO.

1. What information has the Licensee provided as to the Licensee's activities to obtain and construct an ISFSI?

2. Has the Licensee performed a real estate survey as to the available tracts of ground in dry unpopulated areas of the United. States available for an ISFSI?

.3. Has the Licensee.developed a timetable acquisition, license and/or construction of an ISFSI?

4. Has the Licensee. performed a detailed cost analysis of the ISFSI alternative as compared to the proposed action?.

Estimated time for cross-examination 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> TOWNSHIP OF LOWER ALLOWAYS CREEK I~terv --......_

April 25, 1979

~UNITED STATES OF ]\MERICA~

NUCLEAR REGUIJ\TORY COMMISSION

• Before the* Atomic s*afety and Licensing Board In the Matter of PUBLIC SERVI ~ ELECTRIC DOCKET NO.

& GAS CO. .

(Salem Generating Station Unit #1)

CE;RTIFICATE OF SERVICE I hereby certify that copies of Intervenor's Township of Lower Alloways Creek's outline of cross-examination of evidence sumitted by the licensee and NRC in the *above captioned matter have been served upon the*.attached list by deposit.iin.the United States mail at the post office* in N~rthfield, N.J., with proper postage* thereon, this

~

~ . . .

25th *day of April , 1979. . . . . * *

. CARL V~Special Nuclea Counsel tor the Intervenor, the Township of Lower Alloways Creek Dated: *, April. 25, 1979.

Gary L. Milhollin, Esq.

Chairman, Atomic Safety

& Licensing Board 1815*Jeffersb~ Street Madison, Wisconsin 53711 Glen O. Bright Member, Atomic Safety

& Licensing Board U. S. Nuclear Regulatory Commission Washington,*D. C. 20555 Dr. James c. Lamb, III Member, Atomic Safety &

Licensing Board Panel 313 Woodhaven Road Chapel Hill, N. C~: 27514

• Chairman, Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. c. 20555

• Chairman, Atomic Safety &

. Licensing Board Panel U. S. Nuclear Regulatory Commission Washingtori, D.* c. 20555 Barry Smith, Esquire .

Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington; D. c. 20555 M~rk.L~ *First, E~quire Deputy Attorney General*

Department of Law & Public Safety

• Environmental Protection Section 36 West State Street Trenton,* N.. J ..

• 08625 Mark J. Wetterhahn, Esquire

. for Troy B. Conner, Jr. , Esq.

1747 Pennsylvania Avenue, N. W.

Suite 1050

• Washington, D. C. 20006 Richard* Fryling', -Jr., Esquire*

Assistant General Solicitor Public Service Electric &

• Gas Company 80 Park Place Newark,*N. J . . 07101

Keith Ansdorff, Esquire Assistant Deputy Public Advocate Department of the Public Advocate Division of Public Interest Advocacy P. o. Box 141 Trenton, New Jersey 08601 Sandra T. Ayres, Esquire Department of the Public Advocate 520 East State Street Trenton, N. J. 08625 Mr. Alfred C. Coleman, Jr.

Mrs. Eleanor G. Coleman 35 "K" Drive Pennsville, N. J.- 08070 Office of the Secretary Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D. C. 20555 June D. MacArtor, Esquire Deputy Attorney General Tatnall Building, P. O. Box 1401 Dover, Delaware 19901