ML20210B734

Interrogatories & Request for Documents Re Contention That Util Submittals to NRC Fail to Contain Date Necessary for for Independent Verification of Claims on Consistency of Public Health & Safety & Environ.W/Certificate of Svc

ML20210B734
Person / Time
Site:	Diablo Canyon
Issue date:	09/16/1986
From:	Mcgurren H NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Sierra Club
Shared Package
ML20210B637	List: ML20210B632 ML20210B670 ML20210B734
References
OLA, NUDOCS 8609180157
Download: ML20210B734 (6)

Text

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-. .. UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

-In the Matter of )

)

PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA (Diablo Canyon Nuclear Power Plant ) (Spent Fuel Pool)

Units 1 and 2) )

NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM TliE SIERRA CLUB, SANTA LUCIA CHAPTER The NRC staff hereby requests that the Sierra Club, Santa Lucia Chapter (Sierra Club) pursuant to 10 C.F.R. II 2.740b and 2.741, an-swer separately and fully, in writing under oath or affirmation, the fol-lowing interrogatories and produce or make available for inspection and copying, all documentary material identified in responses to interrogato-ries below. Each response to the ' interrogatories below shall be under oath or affirmation of the individual (s) who contributed thereto. For all references requested in these interrogatories, identify them by author, title, date of publication and publisher if.the reference is published, and if it is not published, identify the document by the author, title, the date it was written, the qualifications of the author relevant to this pro-ceeding, and where a copy of the document may be obtained.

Sierra Club Contention I(A) It is the contention of the Sierra Club, Santa Lucia Chap-ter (Sierra Club), that the report submitted to the Nucle-ar Regulatory Commission (NRC) entitled Reracking Spent Fuel Pools Diablo Canyon Units 1 and 2 and other commu-nications between Pacific Gas and Electric Company (PG&E) and the NRC which are available to the public on g6091eo157860916 R

O ADOCK 05000275 PDR

1. the same subject (the Reports) fail to contain certain rel-

~

evant date necessary for independent verification of the claims made in the Reports regarding consistency of the proposed reracking with the protection of the public health and safety, and the environment.

In particular, the reports fall to contain data regarding:

3) the expected velocity and displacement of the spent fuel pools (pools) as a function of time in three di-mensions during the postulated Hosgri earthquake (PHE);

4) the expected maximum velocity and displacement of the racks obtained from the computer modeling of rack behavior during the PHE; 1(B). It is the contention of the Sierra Club that the Reports fail to include consideration of certain relevant conditions, l phenomena and alternatives necessary for independent verification of claims made in the Reports regarding con-sistency of the proposed reracking with public health and safety, and the environment, and with federal law.

In particular, the Reports fail to consider:

2) the resonant behavior of the spent fuel assemblies in the racks in response to the PHE and the conse-quences of such behavior;

7) alternative on-site storage facilities including:

(i) construction of new or additional storage facili-ties and/or; (ii) acquisition of modular or mobile spent nuclear fuel storage equipment, including spent nuclear fuel storage casks;

8) the use of anchors, braces, or other structural mem-f l bers to prevent rack motion and subsequent damage during the PHE;

9) the use of "boroflex" neutron absorbing material for all spent fuel racks.

l

11. It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which in-clude the following:

l (A) during the PHE, collisions between the racks and the pool walls are expected to occur resulting in:

f .

-- - (1) impact forces on the racks significantly larger .

than those estimated in the reports; (2) impact forces on the racks significantly larger than those expected to damage the racks; (3) significant permanent deformation and other damage to the racks and pool walls; (4) reduction of the spacings between fuel assemblies; (5) increase in the nuclear criticality coefficient k(eff) above 0.95; (6) release of large quantities of heat and radiation; (7) radioactive contamination of the nuclear power plant and its employees above the levels permit-ted by federal regulations; (8) radioactive contamination of the environment in the vicinity of the nuclear power plant above the levels permitted by federal regulations, and (9) radioactive contamination of humans and other living things in the vicinity of the nuclear pow-er plant above the levels permitted by federal regulations.

l (B) during the PHE, collisions between groups of racks with each other and/or with the pool walls are ex-l.

pected to occur with results similar to those de-scribed in II(A) above.

Interrogatories For each of the foregoing contentions separately:

1-la. Upon what person or persons do you rely to sub-stantiate in whole or in part your position on Contentions I and II?

b. Provide the addresses and education and professional qualifications of any persons named in your response to a. above,

c. ' Identify which of the above persons or any other person you may call as witnesses on this contention.

t 1-2. - Provide summaries of the views, positions or pro-posed testimony on Contentions I and II of all per-

. sons named in response to Interrogatory 1-1, that you intend to present as witnesses during this proceeding.

1-3. State the specific bases and references to any docu-ments upon which the persons named in response to Interrogatory No . 1-1 rely to substantiate their views regarding Contentions I and II.

1-4. With regard to Contentions I and II identify all doc-umentary or other material that you intend to use during this proceeding to support these contentions and that you may offer as exhibits on these conten-tions or refer to during your cross-examination of witnesses presented by the Licensee and/or the NRC staff.

1-5. With regard to Contention II(A)(6) identify the spe-cific source and cause of the ~ "large quantities of heat and radiation".

Respeetfully sulmitted, IcGurren Counsel for NRC Staff-Dated at Bethesda, Maryland this 16th day of Septerber,1986

e DOCKETED USNRC

-. - UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION '86 SEP 17 A10:28 BEFORE Tile ATOMIC SAFETY AND LICENSINGrBOARD r. 3 - '

00Ch: 1:mi ^ ' "

In the Matter of )

)

PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA

) (Spent Fuel Pool)

(Diablo Canyon Nuclear Power Plant )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY REGARDING CONTENTION 14", "NRC STAFF INTERROGATORIES AND RE-

_ QUEST FOR DOCUMENTS FROM SAN LUIS OBISPO MOTIIERS FOR PEACE" and "NRC STAFF INTERROGATORIES AND REOUEST FOR DOCUMENTS FROM THE SIERRA CLUB, SANTA LUCIA CHAPTER" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indi-cated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 16th. day of September,1986:

B. Paul Cotter, Jr. , Chairman Bruce Norton, Esq.

Administrative Judge Norton, Berry, French Atomic Safety and Licensing Board Panel & Perkins, P.C.

U.S. Nuclear Regulatory Commission P.O. Box 10569 Washington, D.C. 20555* Phoenix, AZ 85064 Glenn O. Bright, Esq. Nancy Culver Administrative Judge 192 Luneta Street Atomic Safety and Licensing Board Panel San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission Washington, D.C. 20555*

Mrs. Jacquelin Wheeler Dr. Jerry Harbour 2455 Leona Street Administrative Judge San Luis Obispo, CA 93401 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission l Washington, D.C. 20555*

Richard E. Blankenburg Philip A. Crane, Jr. , Esq.

Co-publisher (77 Beale Street, 31st Floor)

Wayne A. Soroyan, News Reporter P.O. BOX 7442 South County Publishing Company San Francisco, CA 94120 (94106)

P.O. Box 460 Arroyo Grande, CA 93420 / DESIGNAT ORIGINAIJ Q *[

i l

e Docketing and Service Section Mr. Lee M. Gustafson Office of the Secretary Pacific Gas and Electric Co.

U.S. Nuclear _ Regulatory Commission Suite 1100 Washington, D.C. 20555* 1726 M Street, N.W.

Washington, D.C. 20036-4502 Atomic Safety and Licensing Dr. Richard Ferguson Board Panel Vice-Chairman U.S. Nuclear Regulatory Commission Sierra Club Washington, D.C. 20555* Rocky Canyon Star Route Creston, CA 93432 Atomic Safety and Licensing Appeal Board Panel Laurie McDermott, Co-ordinator U.S. Nuclear Regulatory Commission C.O.D.E.S Washington, D.C. 20555* 731 Pacific Street Suite #42 Managing Editor San Luis Obispo, CA 93401 San Luis Obispo County Telegram-Tribune Dian M. Grueneich, Esq.

1321 Johnson Avenue Edwin F. Lowry P.O. Box 112 Grueneich & Lowry San Luis Obispo, CA 93406 345 Franklin Street San Francisco, CA 94102 s / -

Hen Vf.O %feUurrM Coun or NRC Staff

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