ML17338B176
| ML17338B176 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/14/1979 |
| From: | Goldberg S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7910170586 | |
| Download: ML17338B176 (30) | |
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py UNITED STAT F AM RICA NUCLEAR REGULATORY COMMISSION 9/14/79 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of FLORIDA POWER AND LIGHT COMPANY (Turkey Point Nuclear Generating Unit Nos.
3 and 4)
Docket Nos. 50-
. 50-251
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{Proposed Amendments to Facility Operating Licenses to Permit
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Steam Generator Repair)
-sr, e 4 )r ~- w NRC STAFF INTERROGATORIES TO, AND RE(VEST FOR THE PRODUCTION OF DOCUMENTS 'FROM, INTERVENOR MARK P.
ONCAVAGE The Nuclear Regulatory Commission (NRC) Staff hereby requests that Intervenor I
Mark P.
Oncavage (Intervenor), pursuant to 10 CFR 02.740(b),
ansWer separately and fully, in writing under oath. or affirmation, the following interrogatories.;-
within 14 days after service hereof.
For each response-to the interrogatories listed below, identify the person or.i>>.
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persons who prepared, or substantially contributed to t5e preparation of, the response.
The interrogatories attached. are to be considered the Intervenor's continuing, obligation.
Accordingly, if, after he has answered these interrogatories, additional information comes to his attention with respect to one. or more of the answers, the answers should be amended in a timely manner to provide such additional information.-
The 'NRC Staff fur theV.requests that the Intervenor; pursuant to 10 CFR 52.741,,provige:.-
copies of, or make available for Staff inspection and copying, the documents designa-ted by him in response to certain of the accompanying interrogatories within 30 days after service thereof.
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Contention 1
l-l a.
.State whether you intend.to call any person or persons as witnesses in this -'proceeding in support of Contention.l..
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'ties 0 ll b.
Provide the names, addresses,
.educational background, and. pro-fessional qualifications.of'any persons named above..
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'1-2 Provide summaries of the views, positions, or proposed testimony on contention 1 of all persons named in response to Interrogatory No. 1-1
'that,you intend to present during this. proceeding:
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~ W. ~~a 1-.3 Identify by author,.title, date of publication and publisher, all books, documents, and papers that you intend to employ or rely upon in presenting your direct.'case.
on Contention:l and provide copies of, or make availabla..
for Staff inspection and copying, these-.items.
-;1-4 Identify by author, title, date of publication and publ.isher, all books; documents oi papers that you intend to employ or rely upon in conducting;..
your'ross-examination of prospective NRC Staff witnesses testifying in
. connection with Contention 1.
'""'" """"1-5" """Ifthe representations<made-in Contention -l.are based. in whole~or-in..'pant~re r~s~o m any.documents prepared by theApplicant;or, )RCStaff whi,ch you:,contend<
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.are deficient, specify which documents, and, the particular portions thereof; you regard as deficient and explain why they are deficient.
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1-6 What specific requirements of NEPA does Intervenor suggest. in. contention
.'J require preparation of an environmental impact statement (EIS) in the instant action7 1-7 What specific requirements of 10 CFR Part 50 does Intervenor suggest require;.
preparation of an EISA 1='8 What specific requirements of 10 CFR Part'.51., does Intervenor, suggest require-preparation of an EISA 1-9.
What does the phrase "with particular reference: to 10 CFR 50.90" mean as-".
utilized in Contention 17 1-.10 Does Intervenor contend that'n EIS must"be prepared in this action. 'If
-so, please articulate the factual bases for such contention.
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1-.11,Explain. the meaning of subpart (a) to Contention l.
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0 Contention 2
2-1 a.
State whether you.intend to call any person or persons as witnesses in this proceeding in support of Contention 2.
.b.
Provide the names addresses, educational-background, and pro-fessional qual.ifications of any persons named above.
2-2 Provide summaries of the views,. positions, or,proposed testimony on Contention.-2,of all=persons named in response to Interrogatory No. 2-1 that you intend to present during this proceeding.
2-3 Identify by. author, title, date of publication and publ'isher,.all.books,
" '-" -"-"documents"".and'papers that-you intend-:to..employ or rely.upon in.presenting....,
=-" ~jo6radirecR~case"on'Conten't'ion"2"an'd-provide,:copies of, or make -available;.p--.-. of, for Staff inspection and copying, these items,.
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~--- -2A.-*-.~ Identify-by-author, title, date;of;publication and publisher, all books,.....
documents':or.
pppers that you intend to employ. or rely upon in conducting:,>
your cross-examination of prospective NRC Staff witnesses.testifying in connection with Contention 2.
2-5 If the're'presentations made in Contention
.2 are based in whole or in part
~" f ~"'="on~any-do'comments-prepared by the'-"Appl'i'can'5 or:NRC Staff, which 'you contend-v~-. ~".off are deficient, specify which documents, an the, particular portions therepf,-,,
you regard as deficient and explain why they are deficient.
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2-6 Mhat specific provisions of 10 CFR Pact 20 arealluded to in Contention 2.
2-7 What specific provisions of NEPA are alluded to in Contention 2?
2-8 What specific provisibns of the FWPCA are alluded to in Contention 27 2-9 Does Intervenor'ontend that the proposed "repairs" will not comply with the above-referenced provisions.
If so, please articulate the precise:.
activities complained of and the, bases for such contention.
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S Contention 3
3-1 a.
State whether you intend to call any person or persons as witnesses in this p'roceeding in support of Contention 3.
- b.
Provide the names, addresses, educational background, and pro-fessional qualifications of any persons named above.
3-2 Provide summaries of the views, positions, or proposed testimony on Contention 3 of all persons named in response to Interrogatory No. 3-1 that you intend to present during this proceeding.
3>>3 Identify by author, title, date of publication and publisher, all books,
'documents, and papers that you intend to employ or rely upon in presenting
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='your=@rect"Case on'Contention 3 and provide copies of-, or-make available, co;.,o=.;,
for Staff inspection and copying, these items.
3-4 Identify by author, title, date of publication and publisher, all books,
- documents-or"-papers that you intend to employ or rely upon in conductigq;.-=
your corss-examination of prospective NRC Staff witnesses testifying in connection with Contention 3.
3-5 If the representations made in Contention 3 are based in whole or in.part
":on'a'ng~ ddcuMQnts prepare'd by the Applica'nt< or NRC Staff which you..qqnteqdor
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are deficient, specify which documents, and the particular portions thereof, you regard as deficient and explain why they are deficient.
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7 3-6 What specific requirements of 10 CFR Part 20 are, alluded to in Contention 3'?
What specifib'iequirements of 10 CFR Part)50.are alluded to in Contention,3'?,>
3-8 What specific requirements of '10 CFR Part 51 are alluded to in Contention,37.
'3'-'9": 'hat specific"requirements of 10 CFR Part"il00-areialluded to in Contentiog,3$,.
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I 3-10 What specific requirements of NEPA are alluded to in Contention 37 3-11 What specific requirements of 'FWPCA are alluded to in Contention 37 Specify what handling, processing';"storing or:discharging of primary coolant" is alluded to in Contention 3.
3-.13 Does Intervenor contend that the "handling, processing, storing or.discharging
'" """""M'.)ri7oary"c'oo'lant",, as"explained ia response-to "interrogatory 3-12;-wi'll--. -"
not conform to'h'e several provisions spec'ified in response, to interrogatories 3-7 through 3-1.1 above?
If so, please articulate the bases for such contention.
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Contention 4
a.. State whether you intend to call any person or persons as witnesses in this -proceeding in support of Contentioq:-4.;
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b.
Provide the names, addresses, educational background, and pro-fessional: qualifications-of any persons named above.
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. 4-2 Provide summaries of the views, positions,, or proposed testimony on Contention 4 of all persons named in response in Interrogatory No. 4-1=
that you intend'to present during this proceeding.
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S<<<<>>+f' Identify by author, title, date of publication and publisher; all books, documents, and papers that you intend to employ or rely upon in-presenting
- your~.diect use on Contention 4.and,.provide copjesuot, ormake pyaj3able for Staff inspection and copying, these items.
4 4 Identify by author, title, date of publication and publisher, all books, documents or>>gapers that you intend to-'employ or rely upon in,conducting,,
your cross-examination of prospective NRC Staff. witnesses testifying in connection with Contention 4.
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-""> ">'4'-5 "<'~~'IPCh r@rerentations cade in Contentiorr~~4=are~basedsin wholeoor~<in;part:.~e casey
~.-.~..~a~i-"<<..-.one'any>> documents.prepared by. the-Applicang~ar.;NRC.-Staff, whicheyouncootend ;
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$ aI are deficient, specify which documents, and the particular portions thereof, you regard as deficient and explain why they are deficient.
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4-6 What specific requirements of 10 CFR Part 20 are alluded to in Contention 4?
4-7 What specific requirements of 10 CFR Part 50 are alluded to in Contention 4?
4-8 What specific requirements of 10 CFR Part 51 are alluded to in Contention 4?
4-9 What specific requirements of NEPA are al]pded~to-in Pontention 4?
4-10 What specific'equirements of FWPCA are alluded to in Contention 4?
I 4'-l.l Specify what "discharge of untreated laundry waste water" is alluded to in Contention 4 and the perceived source thereof?
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.4-12 Does Intervenor contend that the "discharge of untreated laundry waste water";.as.-explained in response:to-interrogatory 4-31, will not.comply,,
with the several provisions specified in response to interrogatories 4-7 through 4-10 above?
If so, please. articulate. the bases for such contention.
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P Contention 5
5-1 a.
State whether you =intend to call any person or persons:
as witnesses in this proceeding in support of Contention 5.
b.
Provide the names, addresses, educational background, and pro-fessional qualifications of any persons named above.
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- Provide'summaries
'of the 'views, positions, -or proposed, testimony-on Contention 5
of all persons named in response to Interrogatory No. 5-1 that you intend to present during this proceeding.
5-3 Identify by huthor, title; date of publication and publisher, all books; documeiits; and"papers that you intend to employ, or,rely upon. in.presenting-your diiect case on Contention 5 and provide copies.of, or make availa,le, for Staff'nspection and copying, these items.
5-4
" fdentify"'by"author, titl'e', d'ate of 'pUb i%cation and publisher; all-books documents or'apers that you intend to emp"l'oy or rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in connection with Contention 5.
5-5 If the representations made in Contention 5 are based in whole or in part on any documents prepared by the Applicant or NRC Staff which you contend
"'r'e 'dhfkiYrf5<<s'pecify which documents =-and;tge.particular, portions -thereof-->
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you regard as deficient and explain why they are deficient.
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5-6 What specific requirements of 10 CFR Part 20 are alluded to in Contention 57
" 5-7 What specific. requirements of 10 CFR Part 51 are, alluded to in Contentiop 57 5-8 What specific requirements of NEPA are alluded go in Contention
- 5. 9 -.-.What is the basis for the supposition -in Contention
$,-.,that transient workers with.unknown radiation histories vgi31..:4e.uti3izg in the proposed action7 5=10 Does Intervenor contend that the postulated"utilization of transient workers,.
will not comply with the several provisions specified in response to
'interrogatories 5-6. through 5-.8?""'- lf-so;- please articulate the bases,. >> -,,
for such contention.
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- 12 Contention 6
6-1 a.
State whether you intend to call any person or persons as witnesses, in this proceeding in support of Contention b.
Provide the names, addresses, educational background, and pro-fessional qualifications of any persons named above.
. 6-'2 Provide summaries of the;views, positions,or.-proposed testiqony=qg,..,,.;-=.,;
Contention 6 of all persons named in response to Interrogatory No.
6-1 that you intend to present during this proceeding.
6-3
="Identify-by-author, title, date of publication and publisher, all books,
"'- '" '"d'ocuments",-'and papers that you"intend=4o"employ"or-rely upon in.presentiog-
'your di'rect~se on Contention 6
and provide copies of, or make avai1able for Staff anspection and copying, these items...
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""'" '""" 6-*4""'Tderitifg~author, title,~ date-of-'publioation-and-pub1isherq all:books-.-,..,,.;
"documents or'-'papers that you intend 'to-employ or rely upon in conducting,.;
your cross-examination of prospective NRC-Staff witnesses testifying in connection with Contention 6..
6-5 If the representations made in Contention 6
are based in whole or in part
"" on. any 8ocumen'ts prepared by the Applicant or NRC Staff which-you;conteod.;..;;,,.:,.,
" '-"'--"-'."""'"are~fi'cient, "specify-which-documents-and the-particular pqr4jogs,iheqyof.
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you regard as deficient and explain why they are deficient.
ty.-
Operating Licenses to Permit Steam Generator Repair)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES TO, AND RE(}VEST FOR THE PRODUCTION OF DOCUMENTS FROM, INTERVENOR MARK.P.
ONCAVAGE" in the..:
'above-captiorled proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated.by an asterisk, through
~ ->:deposit <<inuthe Nuclear Regulatory;Coranission.'s internal.mail system, this 14th day of September, 1979:
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'*Elizabeth S; Bowers, Esq.,
Chairman Atomic Safety and Licensing Board Panel
- -- "-'- =-.'."'U." S.. '-N 'c".lefr'e ulatory Comttti.s'0io'n'.
~-- Washington, D.C.
20555
- --:- - -4r. David 8. Hall
.Atomic.Safety and Licensing Board Panel U.'S. Nu'cle'ar Regulatory Commiss'ion, Washington, D.C.
20555
- Dr..Oscar H. Paris
" Atomic"EaTAj"and Licensing'oardahel:"
'-':='J;"--S-:-IfucTea~ Regulatory Commiss'ion-'
'" 'Wash,i'ng'ton, "D'.C.
20555
+Atomic Safety and Licensing Board Panel U.S. Nuclear. Regulatory Commission;;:;
, Washington, D.C.
20555
+Atomic -Safety and Licensing ~"'---'- "
Appeal Boar d Panel ta'o.". c.
L U.S. nuclear Regulatory Commis&on Washington, D.C.
20555.
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comis&om Washington, D.C.
20555 Nr. Nark P.
Oncavage 12200 S.
W. 110th Avenue
'iami, Florida 33176 Harold F. Reis, Esq.
N'a~>- '!q.ro4enst~3g,'ewman,
- Reis, Axelrad Im Toll 1025 Connecticut
- Avenue, N.W.
Washington, D.C.
20036
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Norman'. Coll, Esq.
- Steel, Hector tw Davis Southeast First National Bank Building
.:,Miami, Florida 33131 Vil~~V)
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Martin H. Hodder, Esq.
1131 N.E. 86th Street Miami, Florida 33138 Bruce S.
- Rogow, Esq.
Nova Law School 3301 College Avenue Ft. Lauderdale, Florida 33314
-o>
teven C.
Go erg Counsel for NRC Staff
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