ML041330367

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NRC Staff Second Supplemental Response to Bredls First Discovery Request
ML041330367
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 05/11/2004
From: Uttal S
NRC/OGC
To:
Atomic Safety and Licensing Board Panel
Byrdsong A T
References
50-413-OLA, 50-414-OLA, ASLBP 03-815-03-OLA, RAS 7747
Download: ML041330367 (5)


Text

RELATED CORRESPONDENCE May 11, 2004 RAS 7747 DOCKETED 05/12/2004 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

DUKE ENERGY CORPORATION

)

Docket Nos. 50-413-OLA, 50-414-OLA

)

(Catawba Nuclear Station, Units 1 and 2)

)

NRC STAFF SECOND SUPPLEMENTAL RESPONSE TO BREDLS FIRST DISCOVERY REQUEST __

On April 14, 2004, the staff of the Nuclear Regulatory Commission (Staff), filed a response to Blue Ridge Environmental Defense Leagues First Set of Discovery directed to the NRC Staff (BREDLs First Discovery Request), filed March 31, 2004. The NRC Staff (Staff) filed its objections to BREDLs Request on April 12, 2004. The Staff hereby reiterates and renews each of its objections to BREDLs Request set forth in the Staffs Objection. Without waiving any previously made objections to BREDLs first discovery request, the Staff hereby files this supplemental response to BREDLs First Discovery Request.

GENERAL DOCUMENT PRODUCTION REQUESTS GENERAL REQUEST NO. 2: All documents in your possession, custody or control relevant to each BREDL admitted contention, and to the extent possible, segregated by contention and separated from already produced documents.

STAFF RESPONSE: The staff provides the following additional documents in response to General Request No. 2. The following documents are publicly available at the locations listed. By providing documents in response to this request or any other portion of BREDLs Request, the Staff is not conceding that any of the answers or documents provided are material to the admitted contentions.

The Staff reserves the right to object to the introduction of any of these documents at hearing on the grounds that they are immaterial, irrelevant or outside the scope of the proceeding.

1.

Regulatory Guide 1.4, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Pressurized Water Reactors." (ML003739614) 2.

Regulatory Guide 1.77 "Assumptions Used for Evaluating a Control Rod Ejection Accident for Pressurized Water Reactors."

(ML003740279) 3.

Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors."

(ML003716792) 4.

NUREG-0800, Standard Review Plan, Chapter 15.3.3 / 15.3.4, "Reactor Coolant Pump Motor Seizure and Reactor Coolant Pump Shaft Break." nrc.gov/reading-rm/doc-collections/nuregs/staff.

5.

NUREG-0800, Standard Review Plan, Chapter 15.4.8, "Spectrum of Rod Ejection Accidents (PWR)." nrc.gov/reading-rm/doc-collections/nuregs/staff.

6.

NUREG-0800, Standard Review

Plan, Chapter 15.6.5, "Loss-of-Coolant Accidents Resulting from Spectrum of Postulated Piping Breaks Within the Reactor Coolant Pressure Boundary."

nrc.gov/reading-rm/doc-collections/nuregs/staff.

7.

SECY-94-300, "Proposed Issuance of Final NUREG-1465, "Accident Source Terms for Light-Water Nuclear Power Plants," 12/15/1994.

Public Document Room.

8.

SECY-94-302, "Source Term-Related Technical and Licensing Issues Pertaining to Evolutionary and Passive Light-Water-Reactor Designs," 12/19/1994. Public Document Room.

9.

SECY-98-154, "Results of the Revised (NUREG-1465) Source Term Rebaselining for Operating Reactors,"

6/30/1998.

www.nrc.gov/reading-rm/doc-collections/commission/secys/1998.

10.

Federal Guidance Report No. 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," EPA-520/1-88-020.

Available from the EPA.

11.

"Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," EPA-400-R-92-001. Available from the EPA.

Respectfully submitted,

/RA/

Susan L. Uttal Counsel for NRC Staff Dated in Rockville, Maryland This 11th day of May 2004.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

DUKE ENERGY CORPORATION

)

Docket Nos. 50-413-OLA

)

50-414-OLA

)

(Catawba Nuclear Station

)

Units 1 and 2)

)

CORRECTED CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF SECOND SUPPLEMENTAL RESPONSE TO BREDLS FIRST DISCOVERY REQUEST in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class; or as indicated by an asterisk (*), by deposit in the Nuclear Regulatory Commissions internal mail system; and by e-mail as indicated by a double asterisk (**), this 12th day of May, 2004.

Ann Marshall Young, Chair * **

Administrative Judge Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: AMY@nrc.gov)

Anthony J. Baratta * **

Administrative Judge Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (E-mail: AJB5@nrc.gov)

Thomas S. Elleman **

Administrative Judge Atomic Safety and Licensing Board Panel 5207 Creedmoor Rd. #101 Raleigh, NC 27612 (E-mail: elleman@eos.ncsu.edu)

Office of the Secretary * **

ATTN: Docketing and Service U.S. Nuclear Regulatory Commission Mail Stop: O-16C1 Washington, D.C. 20555 (E-mail: HEARINGDOCKET@nrc.gov)

Office of Commission Appellate Adjudication*

Mail Stop: O-16C1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Adjudicatory File*

U.S. Nuclear Regulatory Commission Mail Stop: O-16C1 Washington, DC 20555 Diane Curran, Esq. **

Harmon, Curran, Spielberg

& Eisenberg, L.L.P.

1726 M Street, N.W., Suite 600 Washington, DC 20036 (E-mail: dcurran@harmoncurran.com)

Lisa F. Vaughn, Esq **

Legal Department Mail Code - PB05E Duke Energy Corporation 426 S. Church Street (EC11X)

Charlotte, NC 28201-1006 (E-mail: lfVaughn@duke-energy.com)

David A. Repka, Esq. **

Anne W. Cottingham, Esq. **

Mark Wetterhahn, Esq. **

Winston & Strawn LLP 1400 L Street, N.W.

Washington, D.C. 20005-3502 (E-mail: drepka@winston.com acotting@winston.com)

/RA/

Antonio Fernández Counsel for NRC Staff