ML19260B427

First Set of Interrogatories Directed to Friends of the Earth.Requests Reasons & Bases Re Allegations of Util Failure to Take Procedures Assuring Facility Mgt Competence

ML19260B427
Person / Time
Site:	Rancho Seco
Issue date:	11/09/1979
From:	Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	FRIENDS OF THE EARTH
Shared Package
ML19260B410	List: ML19260B409 ML19260B415 ML19260B417 ML19260B422 ML19260B427 ML19260B429
References
NUDOCS 7912100158
Download: ML19260B427 (7)

Text

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

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SACRAMENT 0 MUNICIPAL UTILITY

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Docket No. 50-312 (SP)

DISTRICT

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(Rancho Seco Nuclear Generating

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Station)

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FIRST SET OF NRC STAFF INTERR0GATORIES TO FRIENDS OF THE EARTH (F0E)

Pursuant to 10 CFR Section 2.740b, the following interrogatories are directed toF0E.M Each interrogatory not objected to is to be answered separately and fully in writing under oath or affinnation by individuals having personal knowledge of the answers.

Section 2.74Co requires interrogatories to be answered within 14 days of carvice.

Five days are added to this time under Section 2.710 when service is by mail. Accordingly, responses to these interrogatories, which were served by mail on November 9,1979, are due to be filed on November 28, 1979.

Pursuant to Section 2.740(e), these interroga-tories should be supplemented as required by the above-referenced rule.

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An "NRC Staff Request to Produce Directed to Friends of the Earth (F0E)"

is being served contemporaneously with these Staff interrogatories.

1517 339 791210o)d s :

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' Interrogatory 1 With regard to each of F0E's admitted contentions,U ro/ide the following p

information.

A.

Identify the individual (s), if any, whom F0E intends to present as witnesses in this proceeding on the subject matter of each of its admitted contentions. The identification should include the individual's name, affiliation, and a summary of the educational and professional background of that individual.

B.

Provide a reasonable description of the substance of the testimony of any witness (es) that F0E intends to have testify with regard to each of its contentions, including an identification of all documents which will be relied upon in that testimony.

Interrogatory 2 The following questions deal with F0E Contention III(a).

A.

Provide the relationship between an adequate level of safety and the need to evaluate or comment upon the 27 feedwater transients to which you refer, especially in light of the short-tenn actions required by '.iie Commis-sion with regard to the Rancho Seco facility in its Order of May 7,1979 and y

By its " Order Ruling on Scope and Contentions of October 5, 1979," the Atomic Safety and Licensing Board admitted F0E Contentions III(a), III(c),

III(d),andIII(e). The Staff's interrogatories are propounded with reference to these contentions.

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completed by the licensee as documented in the NRC Staff's evaluation of June 27, 1979.

B.

Identify all documents and studies relied upon by F0E in providing answers to this interrogatory. The identification should be specific to the portion of the document or study relied upon.

Studies shall include observa-tions, calculations, literature and other types of work, whether recorded in writing or not, which consist of an examination or analysis of a phenomenon.

C.

Identify by name and affiliation each individual who has knowledge wnich served as the basis for the answers to this interrogatory.

Interrogatory 3 The following questions deal with F0E Contention III(c).

A.

For each of the long-tenn modifications identified in the Commission's Order of May 7,1979, provide what F0E would consider to be a reasonable time for implementation of the modification and F0E's bases for that schedule.

If F0E contends that no interval of time is reasonable, please provide the basis for that position.

B.

Identify all documents and studies relied upon by F0E in providing answers to this interrogatory. The identification should be specific to the portion of the document or study relied upon.

Studies should include 1517 341

-4 observations, calaculations, literature and other types of work, whether recorded in writing or not, which consist of an examination of analysis of a phenomenon.

C.

Identify by name and affiliation each individual who has knowlege which served as the basis for the answers to this interrogatory.

Interrogatory 4 The following questions deal with F0E Contention III(d).

A.

Describe in reasonable detail the term " facility management competence" as that term is used in this contention. The description should specifically identify the " facility" referenced by name and location, and the " management" referenced by level and job function.

B.

Describe the term " competence" as used in this contention.

Identify the standards that F0E contends should be used to judge " management compe-tence" and the bases for these standards.

C.

Describe in reascnable detail the term " procedures" as that term is used in this contention.

D.

In light of Commission regulations governing technical qualifications of licensees, e.g.,10 CFR 50.57(a)(4) and 10 CFR Part 55, provide the reasons 1517 342

. supporting your allegation that "...no procedures have been taken to assure facility management competence."

E.

Identify any " procedures" not taken which you claim would lead to a level of adequate safety at the Rancho Seco facility.3/

F.

Identify all documents and studies relied upon by F0E in providing the answers to this interrogatory. The identification should be specific to the portion of the document or study relied upon.

Studies shall include observa-tioas, calculations, literature and other types of work whether recorded in writing or not which consist of an examination or antlysis of an phenomen.

G.

Identify by name and affiliation each individual who has knowledge that served as the basis for the answers to this interrogatory.

Interrogatory 5 The followir.g questions deal with F0E Contention III(e).

A.

Describe in reasonable detail the term " operator" as that term is used in this contention. The description should identify the " operator (s)"

referenced by job function.

If several classes of " operators" are meant, please identify each class and the functions or activities which the " opera-tor" in each class would be called upon to perform.

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This identification was required by the Board in its Order of October 5, 1979.

See p. 24.

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B.

Describe the term " competence" as used in this contention.

Identify the standards that F0E contends should be used to judge " operator competence" and the basis for these standards.

C.

Describe in reasonab e detail the tem " procedures" as that tem is used in this contention.

D.

In light of Commission regulations governing technical qualifications of licensees, e.g.,10 CFR 50.57(a)(4) and 10 CFR Part 55, provide the reasons supporting your allegation that "...no procedures exist or have been taken for the determination of the adequacy of operator competence."

E.

Identify those " procedures" not taken which you claim would lead to a level of adequate safety at the Rancho Seco facility.O F.

Identify all documents and studies relied upon by F0E in providing the answers to this interrogatory. The identification should be specific to the portion of the document or study relied upon.

Studies shall include observa-tions, calculations, literature and other types of work whether recorded in writing or not which consist of an examination or analysis of a phenomenon.

t 4f This information was ordered by the Board in its Order of October 5, 1979.

See p. 24 1517 344

G.

Identify by name and affiliation each individual who has knowledge which served as the basis for the answers to this interrogatory.

Respectfully submitted,

,e d / /

R1 ard K. Hoefling j

Counsel for NRC Staff L

Dated at Bethesda, Maryland this 9th day of November,1979 e