ML19210E928
| ML19210E928 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/03/1979 |
| From: | Axelrad M LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, PORTLAND GENERAL ELECTRIC CO. |
| To: | Bell N, Rosolie E CONSOLIDATED INTERVENORS, NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| References | |
| NUDOCS 7912130257 | |
| Download: ML19210E928 (7) | |
Text
.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AUD LICENSIUG BOARD In the Matter of
)
)
Docket 50-344 PORTLAND GENERAL ELECTRIC COMPANY,
)
et al.
)
(Control Building Proceeding
)
(Trojan Nuclear Plant)
)
LICEMSEE'S RESPONSES TO INTERVENORS' INTERROGATORIES DATED NOVEMBER 14. 1979 Licensee objects to Interrogatories 1 - 4 served November 14, 1979, by Eugene Rosolie, pro se and Coalition for Safe Power, and Nina Bell, pro s_e,and Consolidated Intervenors (Intervenors) for the reasons set forth below:
Interrogatory 1
" Portland General' Electric, on August 31, 1979, submitted a report in response to IE-Bulletin No. 79-14.
Supply the following information on matters mentioned in that report:
a)
List the 'approximately 50 DCNs'.
The list should include the following information; build-ing location, elevation, tag no.,
- systen, function, size (if piping), and line/150 No.
b)
Supply copies of all 50 MRs c)
List all isometrics found to be in nonconformance d)
Supply detailed information on the two noncon-formances, the Containment Spray System and the Auxiliary Feedwater System.
The information should include the items outlined in (a) of this interrogatory.'
1550 268 7912130
Interrogatory 2
" Supply the complete report on [ sic] response to IE-Bulletin No. 79-14 which was to be submitted on September 28, 1979."
Interrogatory 3
" Supply all previous reviews on the seismic qualification of HCB-14-1 and B train donc prior to occurence [ sic]
date reported in LER 79-13."
Objection to Interrogatories 1, 2 and 3 Licensee objects to Interrogatories 1, 2 and 3.
At the prehearing conference on March 29, 1979, the Licensing Board admitted 18 of Intervenors' contentions as issues in this proceeding.
By its order 1! dated October 17, 1979, the Board dismissed all the previously-admitted contentions of Nina Bell and Consolidated Intervenors.
Order, p.
3.
The Board, in that same order, explicitly ruled that Intervenors were " bound by the admitted contentions of CFSP..."
Id.
Thus, the scope of Inter-venors' discovery in this proceeding is limited to those specified contentions.2/
In Interrogatories 1 and 2, Intervenors seek information with respect to Licensee's responses to the Nuclear Regulatory Commission's IE Bulletin 79-14.
IE Bulletin 1/
" Order Regarding Staff's Motion For Reconsideration Of Consolidation of Intervenors, and Motions Directed To Intervenors' Responses To Discovery."
2/ Those contentions are:
CFSP Nos.
3, 4,
12, 13, 15, 16, 17, 20, and 22.
1550 269 79-14, entitled " Seismic Analyses for As-Built Safety-Related Piping Systems" (supplied to the Board and parties by NRC Staff letter dated July 2, 1979), requested Licensee, as well as all other holders of MRC operating licenses, to verify that analytical input data for seismic analysis of safety-related piping systems conforms to the actually-installed piping system configuration at Trojan.
None of Intervenors' contentions in issue in this proceeding relate in any way to the information sought in Interrogatories 1 and 2.
Interrogatory 3 seeks information with respect to reviews conducted prior to August 7, 1979, of seismic qualification of certain equipment in the Plant discussed in the response to IE Bulletin 79-14.
None of Intervenors' contentions in issue in this proceeding relate in any way to the infor-mation sought in Interrogatory 3.
Thus, the information sought in Interrogatories 1, 2 and 3 is not relevant to the subject matter of any of the Intervenors' contentions and is not calculated to lead to the discovery of admissible evidence, as required by 10 CFR 2.740 (b) (1).
1550 270 Interrogatory 4 "On November 8, 1979, it was reported that numerous guards at the Trojan site were arrested on drug charges.
Supply the following information in connection with this incident:
a)
When did PGE inform the 'RC of the situation?
Supply all documents, if any, sent to the NRC.
b)
Were drugs stored on-site?
If yes give location.
c)
Explain how PGE became aware of the drug problem and when.
d)
If drugs were stored on-site explain how such drugs were able to enter the site.
e)
What procedures are used to assure that construc-tion workers entering the site are not carrying drugs on-site or using drugs while performering
[ sic] their duties?
f)
Is it Licensee's position that guards on-duty under the influence of drugs donot [ sic] pose a security risk?
If yes please explain in detail.
g)
Is it Licensce's position that construction workers under the influence of drugs do not pose a quality assurence [ sic] risk?
If [ sic] Explain answer in detail.
h)
Is it Licensee's position that the use and sell-ing of drugs on the Trojan site does not violate any NRC regulations?
Explain answer in detail, i)
Ic it Licensee's position that drugs could not be used in an act of sabotage?
Explain answer in detail."
Objection to Interrogatory 4 Licensee objects to Interrogatory 4, in which Intervenors seek information with respect to the recent arrest for drug-related offenses by some guards employed at the Trojan site.
None of the Intervenors' contentions 1550 271 admitted by the Board as issues in this proceeding relate in any way to the information sought in Interrogatory 4.
Thus the information sought by Interrogatory 4 is not relevant to the subject matter of Intervenors' contentions, nor is it calculated to lead to the discovery of admissible evidence, as required by 10 CFR 2.740 (b) (1).
1550 272
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket 50-344 PORTLAND GENERIsL ELECTRIC COMPANY, )
_e t _a l.
)
(Control Building Proceeding)
)
(Trojan Muclear Plant)
)
CERTIFICATE OF SERVICE I hereby certify that on December 3, 1979, " Licensee's Responses to Intervenors' Interrogatories Dated November 14, 1979" has been served upon the persons listed below by depositing copies thereof in the United States mail with proper postage affixed for first class mail.
Marshall E. Miller, Esq., Chairman Joseph R.
Gray, Esq.
Atomic Safety and Licensing Board Counsel for NRC Staff U.S.
Nuclear Regulatory Commission U.S.
Nuclear Regulatory Hashington, D.C.
20555 Commission Washington, D.C.
20555 Dr. Kenneth A. McCollom, Dean Division of Engineering, Ronald W.
Johnson, Esq.
Architecture and Technology Corporate Attorney Oklahoma State University Portland General Electric Cc Stillwater, Oklahoma 74074 121 S. W.
Salmon Street Portland, OR 97204 Dr. Hugh C.
Paxton 1229 - 41st Str.eet Frank,W. Ostrander, Jr., Esc Los Alamos, New Mexico 97544 Assistant Attorney General State of Oregon Atomic Safety and Licensing Board Department of Justice Panel 500 Pacific Building U.S.
Nuclear Regulatory Commission 520 S. W. Yamhill Washington, D.C.
20555 Portland, Oregon 97204 Atomic Safety and Licensing Appeal William Kinsey, Esq.
Panel Bonneville Power Admin.
U.S.
Nuclear Regulatory Commission P.O. Box 3621 Washington, D.C.
20555 Portland, Oregon 97208 Docketing and Service Section (3)
Ms. Nina Bell Office of the Secretary 728 S.E.
26th Avenue U.S.
Nuclear Regulatory Commission Portland, Oregon 97214 Washington, D.C.
20555 1550 273
CERTIFICATE OF SERVICE Mr. John A. Kullberg Mr. Eugene Rosolic Route 1, Box 2500 Coalition for Safe Power Sauvie Island, Oregon 97231 215 S.E. 9th Avenue Portland, Oregon 97214 Mr. David B. McCoy 348 Hussey Lane Columbia County Courthouse Grants Pass, Oregon 97526 Law Library Circuit Court Room Ms. C. Gail Parson St. Helens, Oregon 97051 P.
O. Box 2992 Kodiak, Alaska 99615
\\w d-
-Maurice Axelrad
,%%(
i wm
- Lowenstein, Newman, Reis, Axelrad & Toll 1025 Connecticut Ave.,1:U Suite 1214 Washington, D.C.
20036 Dated:
December 3, 1979 1550 274