ML19260C425

Second Set of Interrogatiories.Requests Further Info Re Responses to NRC Interrogatories 2,7,20 & 21 of NRC First Set of Interrogatories

ML19260C425
Person / Time
Site:	Rancho Seco
Issue date:	12/17/1979
From:	Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Castro R, Hursh G AFFILIATION NOT ASSIGNED, HURSH, G.
Shared Package
ML19260C420	List: ML19260C421 ML19260C425 ML19260C426
References
NUDOCS 7912260344
Download: ML19260C425 (3)

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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SACRAMENTO MUNICIPAL UTILITY

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Docket No. 50-312 (SP)

DISTRICT

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(Rancho Seco Nuclear Generating Station)

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SECOND SET OF NRC STAFF INTERROGATORIES TO GARY HilRSH AND RICHARD CASTRO Pursuant to 10 CFR % 2.740b the following interrogatories are directed to Gary Hursh and Richard Castro (Hursh-Castro).

Each interrogatory not objected to is to be answered separately and fully in writing under oath or affirmation by individuals having personal knowledge of the answers. Pursu-ant to the agreement of the parties and the Licensing Board's " Order Relative to Proposed New Schedule" of December 4,1979 final requests for discovery are to be served by December 17, 1979 and final responses to be served by January 17, 1980.

Pursuant to 5 2.740(e), these interrogatories should be supplemented as required by the above-referenced rule.

Interrogatory 22 This interrogatory seeks infonnation concerning " Answers of Gary Hursh and Richard Castro to First Set of NRC Staff Interrogatories" (Answers), specifi-cally the answer to Interrogatory No. 2.

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Provide the reasons for the Castro-Hursh allegation that "...there is a question as to whether the actions taken by the Licensee as reflected in its letter of April 27, 1979, are sufficient and adequate for tho safe operation of Rancho Seco".

Provide this same infonnation for each Interrogatory response where your response to Interrogatory No. 2 is referenced, i.e.,

Nos. 3, 4, 5 and 6.

Interrogatory 23 This interrogatory seeks infomation with respect to the Castro-Hursh Answers relative to Interrogatory No. 7.

Provide the reasons for the Castro-Hursh allegation that "... questions still remain as to the sufficiency and adequacy of such modifications." Provide this same infonnation for each Interragatory response where your response to Interrogatory No. 71s referenced, i.e., Nos. 8, 9 and 10.

Interrogatory 24 This interrogatory seeks infomation with respect to Castro Hursh Answers relative to Interrogatory No. 20 A.

With reference to the "... unsolicited telephone call which Petitioner Hursh received from someone who stated that the psychological testing at Racho Seco was inadequate.", identify the time, date and place at which the call was received, and identify by name, job position and address the per-son (s) with whom Mr. Hursh spoke.

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B.

Provide in detail the complete substance of this telephone conversation.

C.

Identify all notes, documents, tapes or other recorded infomation which Castro-Hursh have in their possession or have knowledge of which relate to this telephone conversation.

Interroaatory 25 This interrogatory seeks information with respect to the Castro-Hursh Answers relative to Interrogatory No. 21.

a.

With reference to the "... unsolicited conversations which Petitioner Hursh had with an unlicensed operator at Rancho Seco who stated that the training for said employees was inadequate.", identify the time, date and place at which the conversations took place and identify by name, and address the person with whom Mr. Hursh spoke.

B.

Provide in detail the complete substance of these conversations.

C.

Identify all notes, documents, tapes or other recorded information which Castro-Hursh have in their possession or have knowledge of which relate to these conversations.

Respectfully submitted,

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Richard K. Hoefling Counsel for NRC Staff Dated at Bethesda, Maryland this 17th day of December, 1979 jfjg