ML19225A454
| ML19225A454 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/08/1979 |
| From: | Rachel Johnson PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19225A455 | List: |
| References | |
| NUDOCS 7907190366 | |
| Download: ML19225A454 (18) | |
Text
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UNITED STATES OF AMERICA Q
NUCLEAR REGULAIORY COMMISSION e
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s BEFORE THE ATOMIC SAFETY AND LICENSING BOARD b
4 In the Matter of
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Docket 50-344 FORILAND GENERAL ELECTRIC COMPANY,
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et a1
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(Control Building Proceeding)
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(Trojen Nuclear Plant)
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CERTIFICATE OF SERVICE I hereby certify that en May 9, 1979:
- 1) Licensee's Second Set of Interrogatories to Eugene Rosalie, pro se, and Coalition for Safe Power; and Nina Bell, pro se, and Consolidated Intervenors;
- 2) Affidavits of Service of John H. Beovich on Nina Bell and Eugene Rosolic;
- 3) Licensee's letter dated May 9, 1979 with a list of Requests for Design Change related to the modifications described in PGE-1020;
- 4) Licensee's letter to Ms. Nina Bell dated May 8, 1979 with attached fire test data; and
- 5) Licensee's letter dated May 2, 1979 to the Director of Nuclear Reactor Regulation with,information for the NRC security reviewers; have been served upon the persons listed below by depositing copies thereof in the United States mail with proper pos'. ige affixsd for first class mail, except as noted by asterisk (*) below indicating personal service of Item 1 as attested to by Item 2.
Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Ccesission Washington, D. C.
20555 Washington, D. C.
20555 Dr. Kenneth A. McCollom, Dean Atonic Safety and Licensing Appeal Division of Engineering, Panel Architecture and Technology U. S. Nuclear Regulatory Commissica Oklahoma State University Washington, D. C.
20555 Stillwater, Oklahoma 74074 Docketing and Service Section (3)
Dr. Hugh C. Paxton Office of the Secretary 1229 - 41st Street U. S. Nuclear Regulatory Co= mission Los Alamos, New Mexico 87544 Washington, D. C.
20555 a
420 090 907 903e/o
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t CERTIFICATE OF SERVICE Joseph R. Gray, Esq.
- Ms. Nina Bell Counsel for NRC Staff 728 S. E. 26th Avenue U. S. Nuclear Regulatory Commission Portland, Oregon 97214 Washington, D. C.
20555 Mr. John A. Kullberg Lowenstein, New=an, ' eis, Axelrad &
Route 1, Box 250Q Toll Sauvie Island, Oregon 97231 1025 Connecticut Ave., N. W.
Suite 1214 Mr. David B. McCoy Washington, D. C.
20036 348 Hussey Lane Gratxs Pass, Oregon 97526 Richard M. Sandvik, Esq.
Assistant Attorney General Ms. C. Gail Parson State of Oregon P. O. Box 2992 Department of Justice Kodiak, Alaska 99615 500 Pacific Building 520 5. W. Yamhill
- Mr. Eugene Rosolle Portland, Oregon 97204 Coalition for Safe Power 215 S. E. 9th Avenue William Kinsey, Esq.
Portland, Oregon 97214 Bonneville Power Administration P. O. Box 3621 Columbia County Courthouse Portland, Oregon 97208 Law Library Circuit Court Room St. Helens, Oregon 97051 Ai
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Ronald W. Jcgnson Corporate Attorney Portland General Electric Company Dated: May 9, 1979 hQf 4kk66.27311
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gjS gT UNITED STATES OF AMERICA 1
NUCLEAR REGULiTORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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4 In the Matter of
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Docket 50-344 PORTLAND GENERAL ELECTRIC COMPANY, )
et al
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(Control Building Proceeding)
)
(Trojan Nuclear Power Plant)
)
LICENSEE'S SECOND SET OF INTERROGATORIES TO EUGENE ROSOLIE, PRO SE, AhD COALITION FOR SAFE POWER; AND NINA BELL, PRO SE, AND CONSOLIDATED INTERVENORS I
'IO EUGENE ROSOLIE, PRO SE, AND COALITION FOR SAFE POWER Interrogatory 13 This Interrogatory relates to your Contention 3 and to your responses to Licensee's Interrogatory 1:
(a) Licensee's letcer to you dated April 20, 1979 provided the additional information which you requested at the prehearing conference (TR 3181-3182) with respect to review by the Plant S taf f.
In light of that information, please state whether you still allege that Plant Staff review of the modifications is inadequate "in that the Plant S taf f will no t be able to determine whether or not a Technical Specification will be violated".
(b) If your answer to (a) is yes, please answer (c) and (d) below.
If your answer to (a) is r',
please answer (e) below.
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(c) In your response to Licensee's Interrogatory 1(c) you stated that the bases for your allegations were "LER's and testirony given at Phase I hearings of this proceeding".
(i) Please identify, by number and date, each LER on which you rely as the basis for your allegations; (ii) Please identify, by witness and transcript page, each part of the testimony given during Phase I of the hearings on which you rely as the basis for your allegations; (iii) For each item identified in (1) and (ii) above, state why you believe it provides a basis for your allegations.
(d) Do you allege that there are particular circumstances regarding the modification program which will =ake it difficult to determine whether Technical Specifications might be violated? If your answer is yes, please indicate the nature of those circumstances and how they will affect the Plant Staff review.
Please provide the bases for your respoase.
(e) Please state whether Contention 3 is withdrawn.
If not:
(1) Explain why you think Plant Staff review will be inadequate; (ii) Specify the type and scope of review that you believe would be adequate; (iii) If the bases for your response are those quoted in (c) above, please answer (c)(1),
(ii) 2nd (iii). Lb 09}
Interrogatory 14 This Interrogatory relates to your Contentions 12 and 13 and your responses to Licensee's Interrogatory 5 and Staff's Interrogatories C12 and Cl3:
(a) With respect to your response to Licensee's Interroga-tory 5(d):
(i) Specifically identify each item of information obtained during your site visit which leads you to each of the conclusions you expressed in your responses to 5(a), (b) and (c).
(ii) Ideutify the source of each item of informa-tion specified in (i) above.
(b) With respect to your Contention 12 and your response to Staff's Interrogatory C12-3, identify each NRC regulatica which you contend has not been met.
State the bases for your belief that each has not be en =e t.
(c) With respect to your Contention 13 and your response to Staff's Interrogatory Cl3-1, identify each of the NRC regulations which you contend cannot be set.
State "he bases for your belief that each cannot be met.
Interrogatory 15 This Interrogatory relates to your Contentions 15 and 16 and your response to Licensee's Interrogatory 7 and Staff's Interrogatories CIS and C16:
(a) What is the basis for your assertion that "At this time we do not believe that there are any plans which are practical outside of keeping the Plant in the ild shutdown"? 420 094
(b) If the basis for that response is lack of information supplied by Licensee:
(1) Will the information which you state should be provided in your response to Licensee's Interrogatory 7 be suf ficient to =eet your conce rn?
(ii) If no t, please specify additional information which you believe is necessary to make an adequate showing.
(iii) Please explain why you believe any information specified in (ii) above is necessary.
(iv) Please provide the bases for your responses to (i) through (iii) above.
(c) With respect to your response to Licensee's Interroga-tory 7(c):
(1) Specifically identify each item of information obtained during ycur site visit which leads you to each of the conclusions you expressed in your responses to 7(a) and (b).
(ii) Identify the source of each ites of informa-tion specified in (1) above.
(d) With respect to your responses to Staff 's Int erroga-tories C15-2 and C16-3:
(1) Specifically identify each ites of informa-tion obtained during your site visit which leads you to each of the conclusions expressed in your responses to Staff 's Interrogator-les C15-1, C16-1 and C16~2.
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Identi_'y the source of each ites of infor=a-tion specified in (1) above.
Interrogatory 16 This Interrogatory relates to your Contention 17 and your responses to Licensee's Interrogatory 8(e) and Staff's Interrogatory C17-4:
(a) Specifically identify each item of infor=ation obtained during your site visit which leads you to each of the conclusicas you expressed in your responses to Licensee's Interrogatories 8(a), (b), (c) and (d).
(b) Specifically identify each item of information obtained during your site visit which leads you to each of the conclusions you expressed in your responses to Staff's Interrogatories C1/-1, C17-2 and C17-3 (c) Identify the source of each item ef information specified in (a) and (b) above.
Interrogatory 17 This Interrogatory relates to your Contention 20 and your response to Licensee 's Interrogatory 10(d):
(a) Specifically identify each item of infor=ation obtained during your site visit which leads you to the conclusions you expressed in your responses to Licensee's Interroga-tories 10(a), (b) and (c).
(b) Identify the source of each ites of information specified in (a) above.
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(a) Specifically identify each item of information obtained during your site visit which leads you to each of the conclusions you expressed in response to Licensee's Interrogatories 12(a), (b) and (c).
(b) Identify the source of each item of information specified in (a) a'sovo.
(c) Please identify, by witness and transcript page, "the testi=ony given at Phase I hearings" referred to in your response to Licensee's Interrogatory 12(d).
II IO NINA BELL, PRO SE, AND CONSOLIDATED INTERVENORS Interrogatory 15 This Interrogatory relates to your Contention 2 and your responses to Licensee's Interrogatory 1 and Staff's Interrogatory C2-5:
(a) With respect to your responses to Licensee's Interroga-tories 1(a)(1) and 1(a)(ii):
(1) Specifically identify each item of information obtained during your site visit which leads you to conclude that all cable penetrations in the area of sodifications are subject to a higher potential for fire. Yd.0 077
(ii) Identify the source of each item of informa-tion specified in (1) above.
(iii) Specifically identify each item of informatica obtained during your site visit which leads you to the conclusions you expressed in response to Licensee's Interrogatory 1(a)(ii).
(iv) Identify the source of each item of infor=a-tion specified in (iii) above.
(b) With respect to the " general information" which you state forms the bases for your responses to Licensee's Inter-rogatory 1(a)(iii):
(1) Specifically identify each item of " general inf or=ation" which leads you to each conclu-sion you expressed in response to Licensee's Interrogatory 1(a)(iii).
(ii) Explain how each item of " general information" provides the basis for each conclusion.
(iii) Identify the source of each item of " general information" specified in response to (i) g a bove.
(c) This relates to your responses to Licensee's Interroga-tory 1(c) and Staff's Interrogatory C2-5.
You state that the basis for your belief that welding will be required in the cable spreading room is " site visit":
(1) Specifically identify each ites of infor=ation obtained during your " site visit" which leads you to believe that any welding necessary to the modification program will take place in the cable spreading room.
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(ii) Identify the source of each item of informa-tion specified in (a) above.
(iii) Apart from any alleged welding in the cable spreading room, specifically identify any other welding which you intend to be encom-passed in Contention 2(c).
(iv) With respect to any welding identified in (iii) above:
(1) Describe specifically why you bel teve fire protection will be in dequate, and (2) Provide the bases for your response to Subpart (1).
(e) With respect to your response to Licensee's Interroga-tory 1(d)(iv):
(1) Specifically identify each item of information obtained during your site visit which leads you to each of the conclusicas you expressed in your responses to 1(d)(1), (ii) and (iii).
(ii) Identify the source of each item of informa-tion specified in (1) above.
Interrogatory 16 This Interrogatory relates to your Contention 3 and your response to Licensee's Interrogatory 2(c):
(a) Specifically identify each item of information obtained during your site visit which leads you to the conclusions
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you expressed in your responses to Licensee's Interroga-tories 2(a) and (b).
(b) Identify the source of each item of information specified in (a) above.
Interrogatory 17 This Interrogatory relates to your Contention 4 and your response to Licensee's Inc.errogatory 3(g):
a) Specifically identify each item of information obtained during your site visit which leads you to the conclusions you expressed in your responses to Licensee's Interroga-tories 3(a) and 3(c).
(b) Identify the source of each item of information specified in (a) above.
(c) With respect to the " general information" which you state forms the bases for your responses to Licensee's Interrogatory 3:
(1) Specifically identify each item of " general Laformation" which leads you to each conclu-sion you expressed in response to Licensee 's Interrogatory 3.
(ii) Explain how each item of " general information" provides the basis for each conclusion.
(iii) Identify the source of each item of " general information" specified in response to (1) above.
20 100.
Interrogatory 18 This Interrogatory relates to your Contention 5.
In your response to Licencee's Interrogatory 4 you stated that, in your view, to make the necessary showing Licensee must provide "more specific analyses of the effect of equipment failure and a postulated accident sequence in case of gross failure of equipment":
(a) With respect to ycur term "effect of equipment failure":
(1) Specifically identify each piece of " equip-ment" whose failure you believe should be analyzed, and as to each such piece of equip-ment specifically identify what would consti-tute a " failure" and what "effect" of a
" failure" should be analyzed.
(iij Specifically explain why you believe that each "eff ect" identified under (1) above should be more specifically analyzed.
(b) With respect to your term " gross failure of equipment":
(1) Specifically identify each piece of equipment whose " gross failure" should be analyzed, and as to each such piece of equipment speci-fically identify what would constitute a
" gross failure" and what "effect" of such a
" gross failure" should be analyzed.
(ii) Specifically explain why you believe that each "eff ect" identified under (1) above should be more specifically analyzed.
(c) With respect to your term " postulated accident sequence": 420 101
(1) Specifically identify each " accident" you believe should be " postulated", as well as the
" sequence" you believe should be analyzed.
(ii) Specifically identify each piece of equipnent you believe would be affected by each "postu-laced accident sequence", as well as the effects that you believe should be analyzed.
(iii) Specifically explain why you believe that each accident or effect identified under (i) or (ii) above should be more specifically analyzed.
(d) With respect to your responses to Licensee's Interroga-tory 4(c) and Staff's Interrogatory C5-1:
(1) Specifically identify each ites of information obtained during your site visit which leads you to the conclusions you expressed in your responses to Licensee's Interrogatories 4(a) and (b) and Staff's Interrogatory C5-1.
(ii) Identify the source of each item of infor a-tion specified in (i) above.
Interrogatory 19 This interrogatory relates to your Contention 7 and your responses to Licensee's Interrogatory 6:
(a) In your response to Licensea's Interrogatory 6(c) you allege an inability by Licensee to " troubleshoot". You claim that allegation is supported by "NRC reports and letters written to PCE from the Oregon Department of Energy". 420 102
(1) Please identify each NRC report and letter from the Oregon Depart =ent of Energy on which you rely as the basis for your allegation.
(ii) For each item identified in (i) above, state why you believe it provides a basis for your allegations.
(b) With respect to your response to Licensee's Interroga-tory 6(e):
(1) Specifically identify each item of information obtained during your site visit which leads you to the conclusions you expressed in your responses to Licensee's Interrogatories 6(a) and (b).
(ii) Identify the source of each item of informa-tion specified in (1) above.
Interrogatory 20 This Interrogatory relates to your Contention 11 and responses to Licensee's Interrogatory 7:
(a) With respect to your response to Licensee's Interroga-tory 7(a):
(i) Identify each of the ' suggested practices" which you believe may not be advisable.
(ii) State, with specificity, why you believe each of these " suggested practices" =ay not be advisable.
(iii) State the bases for your belief.
420 103.
(b) With respect to your response to Licensee's Interroga-tory 7(b):
(1) Identify each of the "conclusory statements" in Section 5.3.4 of PCE-1020 which you believe needs further analysis.
(ii) State, with specificity, why you believe each of these "conclusory statements" needs further analysis.
(iii) State the bases for your belief.
(c) With respect to your response to Licensee 's Interroga-tory 7(c):
(1) Specifically identify each ites of information obtained during your site visit that leads you to the conclusions you expressed in your responses to Licensee's Interrogatories 7(a) and (b).
(ii) Identify the source of each item of informa-tion specified in (i) above.
Interrogatory 21 This Interrogatory relates to your Contention 12 and to your response to Licensee's Interrogatory 8:
(a) With respect to your allegation that Licensee has not provided "sufficiently detailed design and work plans":
(1) Identify the " detailed design" that Licensee has provided which you believe is not "sufficiently detailed". 420 104
(ii) Explain why you believe that design is not "sufficiently detailed".
(iii) Specify the scope of infor=ation which you believe is neceisary to =ake the items identi-fled in (1) above "suf ficiently detailed",
and explain why you believe that information is necessary.
(iv) If you believe that any additional " design and work plans" should be provided, specify the scope of information that should be included in such additional items and explain why you believe that iaformation is necessary.
(b) With respect to your cliegation that " Licensee has not sufficiently analyzed the potential safety hazards of modification work":
(1) Identify specifically each " potential safety hazard" which you believe has not been sufficiently analyzed.
(ii) Explain why you believe that Licensee has not "sufficiently analyzed" each of those " hazards".
(iii) Specify the analysis for each of those " hazards" which you believe is necessary to be " sufficient".
(iv) Explain, with respect to each hazard you have identified, why you believe such an analysis is necessary.
(c) With respect to your allegation that Licensee has not done a "ccmplete analysis of the effect of the modifications on the structural integrity of the complex":
420 105 (i) Identify each "effect of the codification on the structural integrity of the complex" which you believe has not been completely analy:ed.
(ii) Explain for each of those effects why you believe Licensee's analysis is not complete.
(iii) Specify the scope of the analysis for each of those effects which you believe would be
" complete".
(iv) Explain, with respect to each hazard you have identified, why you believe such an analysis is necessary.
Interrogatory 22 This Interrogatory relates to your Contention 20 and your responses to Licensee's Interrogatory 13 and Staff's Interrogatory C20:
(a) Please explain in detail how your responses given to Licensee's Interrogatories 8(a) and (b) relate to the subject matter of your Contention 20.
(b) Identify each "effect of the steel plate on displacement in the complex" which you believe has not been completely analy;ed.
(c) Explain for each of those effects why you believe the Licensee's an'. lysis is not complete.
(d) Specify the scope of the analysis for each of these effects which you believe would be " complete".
(e) Please identify, with specific citations to the Phase I record, "all types of displacement discussed in Phase 1 420 106
hearings", as referred to in your response to Staff 's Interrogatory C20-2.
(f) If you are not able to identify the s Jop. of analysis you contend is necessary to address your contention, please explain how you reach your conclusion that the " Issue was only mi- ' ally addressed in PGE-1020" and provide the basis L _ uch conclusion.
Interrogatory 23 This Interrogatory relates to your Contention 23 (as incorporated into your Contention 5) and your response to Licensee's Interrogatory 14:
(a) Specifically identify each ites of information obtained during your site visit which leads you to believe that bolt placement is arbitrary.
(b) Identify the source of each item of infor=ation specified in (a) above.
May 8, 1979
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