ML19225A042
| ML19225A042 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/24/1979 |
| From: | Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| OTHR-790524, NUDOCS 7907170242 | |
| Download: ML19225A042 (4) | |
Text
05/24/79 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h~.C PUBLIC DOCU.\\ENT ROOM BEFORE THE ATOMIC SAFETY A';D LICENSING APPEAL BOARD In the Matter of p
g VIRGINIA ELECTRIC AND POWER
)
Docket Nos. 50-338 OL 77 g
COMPANY
)
50-339 OL us"*C f'[ g Y 3 0 N #
0 (North Anna Nuclear Power Statio-Units 1 and 2)
)
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NRC STAFF DISCOVERY TO INTER /ENOR ARNOLD C'
N The following interrogatories and requests for production of documents are being submitted by the Staff to Mrs. Arnold in accordance with the Board's Memorandum and Order dated April 9, 1979.
For each response to the interrog-atories and requests listed below, identify the person (s) who prepared or substantially contributed to the response.
The questions and tequests per-tain to both the turbine missile and service water pumphousa settlement issues raised by the Appeal Board. Accordingly, please separate your answers to each question or request to indicate which issue the information relates to.
1.
Identify the person (s) that you intend to use as witnesses in this proceeding, and provide their professional qualifications.
2.
Provide su=maries of the views and positions, and the bases for them, of the named individuals in response to the first question on the follcwing matters:
a)
Whether VEPCO and the Staff have adequate warning of significant settlement of the North Anna Units 1 and 2 service water pumphouse with the proposed monitoring and reporting requirements and settle-ment limits as described in the "NRC Staff Testi-many Regarding Pumphouse Settlement", Section B.6, which was submitted to the Appeal Board on May 4, 1979.
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U 56 79071702 J/2 g
b)
Whether the dewatering system is adequate to accept-ably minimize the possibility of rapid settlement of the service water pumphouse; c)
Whether the Staff, in its " Testimony Regarding Turoine Missiles" in this proceeding, dated April 27, 1979, properly evaluated the probability:
1) of turbine failure and generation of
- uissiles, 2) of a turbine missile striking a safety related target; and 3) that a miscile strike penetrates one or more barriers and causes unacceptable damage.
3.
Identify by author, title,.date of publication and publisher (if any), all books, documents, papers and noces/ letters that you in-tend to employ or rely upon in presenting your direct case, or in conducting your cross-examination of prospective NRC Staff witnesses.
4.
Provide a copy of the items indicated in response to question 3 above which are not publicly availabic.
5.
Identify any books, documents, papers or notes / letters that were written, contributed to, or received by the person (s) named in response to question 1 above which are related to the issues of turbine missiles or settlement of the North Anna Units 1&2 service water pumphouse.
6.
Provide a copy of the items indicated in response to question 5 above which are not publicly available.
If any of the person (s) wrote, received, or contributed to any of these documents as an employee of the AEC/NRC, you need not provide copies of these documents.
7.
Specify any parts of the NRC Staff's prefiled testimony in this proceeding which you contend are deficient and explain why they are deficient.
Respectfully submitted, h & E.
m Daniel T. Swanson Counsel for NRC Staff Dated at Bethesda, Maryland this 24th day of May, 1979 9
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~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
)
)
VIRGINIA ELECTRIC AND POWER COMPANY
)
Docket Nos. 50-338 OL
)
50-339 OL (North Anna Nuclear Power Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICF I hereby certify that copies of "FRC STAFF DISCOVERY TO INTERVENOR ARNOLD" 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, through deposit in the Nuclear Regulatory Commission's internal mail system, this 24th day of May, 1979:
Alan S. Rosenthal, Esq., Chairman
- Dr. Paul W. Purdom, Director Atomic Safety and Licensing Appeal Environmental Studies Institute Board Drexel University U.S. Nuclear Regulatory Commission 32nd & Chestnut Streets Washington, DC 20555 Philadelphia, PA 19104 Dr. John Buck
- Mr. R. B. Briggs Atomic Safety and Licensing Appeal 110 Evans Lane Board Oak Ridge, TN 37830 U.S. Nuclear Regulatory Commission Washington, DC 20555 Michael W. Maupin, Esq.
Hunton & Williams Michael C. Farrar, Esq.*
P. O. Box 1535 Atomic Safety and Licensing Appeal Richmond, VA 23212 Board U.S. Nuclear Regulatory Commission Richard Foster, Esq.
Washington, DC 20555 1908 A Lewis Mountain Road Charlottesville, VA 22903 Ellyn R. Weiss, Esq.
Sheldon, Harmon, Roisman Mr. James M. Torson
& Weiss 501 Leroy 1725 I Street, N.W.
Socorro, NM 87801 Suite 506 Washington, DC 20006 Mrs. James C. Arnold Bc t-1951 Chariuttesville, VA 22903 i
. William H. Rodgers, Jr., Esq.
Mr. Dean P. Agee Georgetown University Law Center Executive Secretary 600 New Jersey Avenue, N.W.
Board of Supervisors Washington, DC 20001 Louisa Courthouse Louisa, VA 23090 Dr. Kenneth A. McCollom Assistant Dean Atomic Safety and Licensing Board College of Engineering Panel
- Oklahoma State University U.S. Nuclear Regulatory Commission Stillwater, OK 74074 Washington, DC 20555 Anthony Gambardella, Esq.
Atomic Safety and Licensing Appeal Office of the Attorney General Panel (5)*
11 South 12th Street Room 308 U.S. Nuclear Regulatory Commission Richmond, VA 23219 Washington, DC 20555 Mrs. June Allen Dncketing and Service Section (4)*
412 Owens Drive Office of the Secretary Huntsville, AL 35801 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mrs. Margaret Dietrich Route 2, Box 568 Gordonsville, VA 22042 h& E,
=,-s Daniel T. Swanson Counsel for NRC Staff 9
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