ML19263D537
| ML19263D537 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/09/1979 |
| From: | Gray J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7904090349 | |
| Download: ML19263D537 (53) | |
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.;UCLEAR RLGULATORY CO.1:J1SSION b\\N ahy BEFORE TliE ATO..HC SAFbTY AND LICENSING DOARD N ' G In the !!atter of
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PORTL Ai4D ( W..;i R AI ELECTRIC
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Docket.Nos 50-344 CO!.!PAnY, ET AL
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(Control Builcling)
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(Trojan c'uclear P1 mt)
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CLRTIFICATE OF SERVICE _
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I hereby certify that "NRC STAFF INTERROGATORIES TO, AND REQUEST FOR TILE PRODUGflON OF DOCUMENTS FROM, INTERVENOR EUGENE ROSOLIE AND COALITION FOR SAFE POWER" and "NRC STAFF INTERh0GATORIES TO, AND RFQUEST FOR TllE PRODUC-TION OF DOCUMENTS FROM, CONSOLIDATED INEERVENOR NINA BELL", both in the above-captioned proceeding have been :;erved on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regul a tory Comiai ss ion 's internal mail "ystem, this 9th day of March, l') 79 :
11rshall L hiiller, Esq., Chairman
- John H. Socolofsky Atomic Safety and Licensing Board Robert \\i. Johnson L1.S. Nuclear Regula tor y Commission Oregon Department of Enero,y and V.
shin g ton, D. C. 20555 Oregon Public Utility Commissioner Department of Justice Dr. Eenneth A. 'dcCollom, Dean State Office Building Divi.sion of Engineering,
Saltm, Oregon Arenitecture & Technology Oklahoma State University Robert Lowen.,tein, Eng.
Stillwater, Oklahoma 74074 Lowenstein, Newman, his
& Axeirad Dr. Ilugh C. Paxton Suite 1214 1229-41st Street 1025 Connecticut Avenue, N E.
1.02 Aimaos,r,ew 'exico 87514 Washington, D. C 20036
- .f r. John A. l'ullberg
'ar. David B. :cCoy Route One 348 Ilussey Lane Box 250Q Grants Pa u, Oregon 97526 Sauvie Island, Oreg;on 9/231 Ms. C. Gail Parson 800 S. W Green #6 Partland, Occ can 97206 70 04 99 9 3ej c; V
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- 11. l!. Phillips, E aq.
Ala n S. ".c o en th al, E ng.
Vice President, Corporate Atomic Safety and Licensing Coun cl and S< cretary Appeal Board Portland General F.lectric Company U.S. I uclear Regulat< >ry Conanission 121 S.W. Salmon Street W.whing ton, D. C 20555 P, e tiand, Oregon 97204 Dr John II. Buck un W, Ginsey Atomic S: fety and Licensing J: a.' N. E llolladay Appeal noard Portland, Oregon 97232 U.S. Nuclear Regnlatory Comi.n, non Washington, D. C. 20555
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Ms. Nina Dell 728 S. E. 26th Dr. W Reed Johru;on Portland, Oregon 9/214 Atomic Safety and Licen.;ing Appeal Board Mr. Stephen M. Willingham U.S. Nuclear Regulatory Conuniusion 555 N. Tomahawk Drive
'.Va sh in g ton, D. C. 20555 Portland, Oc( gon 97217 Atomic Safety and Licensing Mr. Eugene Rosolic Board Panel
- Coalition for Safe Power U.S. Nuclear Regulatory Commission 215 SE 9th Avenue O shington, D. C.
20555 Portland, Oregon 97214 Atomic Safety and Licensing Ms. Elizabeth Scott Appeal Panel (5)*
Columbia Environmental Council U.S. Nuclear Regualtory Conunission P. O. Box 611 Washington, D. C. 20555 St. Iielens, Oregon 97051 Ducketing and Service Section (3)*
Office of the Secretary U.S. Nuclear Regualtory Connaission Washington, D. C.
20555 Joseph R. Gray Counsel for NRC Staff
03/09/79 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PORTLAND GENERAL ELECTRIC COMPANY, )
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(Control Building)
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(Trojan Nuclear Plant)
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NRC STAFF INTERROGATORIES TO, AND REQUEST FOR THE PRODUCTION OF DOCUMENTS FROM, INTERVENOR EUGENE ROSOLIE AND COALITION FOR SAFE POWER The Nuclear Regulatory Commission (NRC) Staff hereby requests that Intervenor Eugene Rosolle and Coalition for Safe Power, pursuant to 10 CFR 62.740b, answer separately and fully, in writing under oath or affirmation, the following interrogatories within 14 days after service hereof.
For each response to the interregatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of the response, if in fact, the response was prepared in whole or in part by someone other than Eugene Rosolle.
The NRC Staff further requests that the Intervenor, pursuant to 10 CFR B2.741, provide copics of, or make available for Staff inspection and copying, the documents designated by the Intervenor in response to certain of the accompanying interrogatories within 30 days after service thereof.
I.
General Interrocatories1/
G-1. State whether or not you intend to call any person or persons as witnesses in this proceeding in support of (a) Contention 1 (n) Contention 14 (b) Contention 2 (o)
Contention 15 (c) Contention 3 (p)
Contention 16 (d) Contention 4 (q) Contention 17 (c) Contention 5 (r) Contention 18 (f) Contention 6 (s) Contention 19 (g) Contention 7 (t) Contention 20 (h) Contention 8 (u)
Contention 21 (i) Contention 9 (v) Contention 22 (j) Contention 10 (w) Contention 23 (k) Contention 11 (x)
Contention 24 (1) Contention 12 (y)
Contention 25 (m) Contention 13 (z)
Contention 26 and provide the names, addresses, educational background, and
, professional qualifications of those persons you intend to call.
G-2. Indicate whether those persons identified in response to Interrog-atory No. G-1 in support of (a) Contention 1 (n) Contention 14 (b) Contention 2 (o) Contention 15 (c) Contention 3 (p) Contention 16 (d)
Contention 4 (q) Contention 17 (e) Contention 5 (r) Contention 18 (f)
Contention 6 (s) Contention 19 (g)
Contention 7 (t) Contention 20 (h)
Contention 8 (u) Contention 21 (i)
Contention 9 (v) Contention 22 (j) Contention l'0 (w) Contention 23 (k) Contention 11 (x) Contention 24 (1)
Contention 12 (y) Contention 25 (m)
Contention 13 (z) Contention 26 will appear voluntarily or under subpoena.
-1/ Interrogatories in this section should be answered with respect to each contention. The contentions referred to are those set forth in
" Contentions of Intervenors, Eugene Rosolie, pro se, and Coalition for Safe Power" dated February 26, 1979.
' t G-3. Provide summaries of the views, positions, or proposed testimony on (a)
Contention 1 (n)
Contention 14 (b)
Contention 2 (o)
Contention 15 (c)
Contention 3 (p)
Contention 16 (d) Contention 4 (q)
Contention 17 (c)
Contention 5 (r)
Contention 18 (f)
Contention 6 (s)
Contention 19 (g)
Contention 7 (t)
Contention 20 (h)
Contention 8 (u)
Contention 21 (1)
Contention 9 (v)
Contention 22 (j)
Contention 10 (w)
Contention 23 (k)
Contention 11 (x)
Contention 24 (1)
Contention 12 (y)
Contention 25 (m)
Contention 13 (z) Contention 26 of all persons named in response to Interrogatory No. G-1 that you intend to present during this proceeding.
C-4. Identify by author, title, date of publication and' publisher, all books, documents, and papers that you intend to employ or rely upon in presenting your direct case on (a)
Contention 1 (n) Contention 14 (b)
Contention 2 (o) Contention 15 (c)
Contention 3 (p) Contention 16 (d) Contention 4 (q) Contention 17 (e)
Contention 5 (r) Contention 18 (f) Contention 6 (s) Contention 19 (g)
Contention 7 (t) Contention 20 (h)
Contention 8 (u) Contention 21 (i) Contention 9 (v) Contention 22 (j)
Contention 10 (w)
Contention 23 (k)
Contention 11 (x)
Contention 24 (1)
Contention 12 (y)
Contention 25 (m)
Contention 13 (z)
Contention 26 and provide copies of, or make available for Staff inspection and copying, these items.
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G-5. If the representations made in (a)
Contention 1 (n)
Contention 14 (b) Contention 2 (o) Contention 15 (c)
Contention 3 (p) Contention 16 (d)
Contention 4 (q) Contention 17 (e)
Contention 5 (r)
Contention 18 (f)
Contention 6 (s)
Contention 19 (g) Contention 7 (t)
Contention 20 (h) Contention 8 (u)
Contention 21 (1) Contention 9 (v)
Contention 22 (j) Contention 10 (w)
Contention 23 (k) Contention 11 (x)
Contention 24 (1) Contention 12 (y)
Contention 25 (m) Contention 13 (z)
Contention 26 are based in whole or in part on any documents prepared by the Licensee or NRC Staff which you contend are deficient, specify which documents, and the particular portions thereof, you regard as deficient and explain why they are deficient.
G-6. Identify by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in connection with (a) Contention 1 (n) Contention 14 (b) Contention 2 (o) Contention 15 (c) Contention 3 (p) Contention 16 (d) Contention 4 (q) Contention 17 (e) Contention 5 (r)
Contention 18 (f) Contention 6' (s)
Contention 19 (g) Contention 7 (t)
Contention 20 (h) Contention 8 (u)
Contention 21 (1) Contention 9 (v)
Contention 22 (j) Contention 10 (w)
Contention 23 (k) Contention 11 (x)
Contention 24 (1) Contention 12
-(y)
Contention 25 (m) Contentior 1.3 (z)
Contention 26
, i II.
Questions Related to Specific Contentions Contention 1 Cl-1.
State your understanding of the terms "scismic capacity",
" Absolute Sum Value technique" and " Square Root of The Sums Squared" as those terms are used in Contention 1.
Cl-2.
Do you assert in Contention 1 that the seismic capacity of the Control Building Complex, before the performance of the modifications which are the subject of this proceeding, should have been determined by the Absolute Sum Value technique rather than by the Square Root of the Sums Squared?
If so, state specifically and in detail the basis for that assertion.
If you have no basis for such assertion, so indicate.
Cl-3.
Do you assert in Contention 1 that the seismic capacity of the Control Building Complex, after the performance of the modifi-cations which are the subject of this proceeding, should be determined by the Absolute Sum Value technique rather than by the Square Root of the Sums Souared?
If so, state specifi-cally and in detail the basis for tt a assertion.
If you have no basis for such assertion, so indicate.
Contention 2 C2-1.
State your understanding of the term " cost-benefit analysis" as that term is used in Contention 2.
C2-2.
Do you assert in Contention 2 that a cost-benefit analysis should be done by the Licensee or NRC Staff to determine whether permanent shutdown of the Trojan facility is an option to the proposed modifications and continued operation?
If e o, state specifically and in detail basis for that assertion.
If you have no basis for such assertion, so indicate.
_ Contention 3 C3-1.
Describe specifically the " Plant Staff" referred to in Contention 3.
C3-2.
Stato specifically the Technical Specifications referred to in Contention 3.
C3-3.
Do you assert in contention 3 that " Plant Staff" review of the proposed modifications is inadequate to assure that no violations of the Technical Specifications will occur, while the modifications are being carried out?
If so, state specifi-cally and in detail:
(a)
The basis for your assertion.
If you have no basis, so state.
(b)
The review that you would consider to be adequate and the basis for your position in this regard.
C3-4.
Do you assert in Contention 3 that " Plant Staff" review of the modifications will be inadequate to assure that no violations of the Technical Specifications will occur, after the modifi-cations are completed?
If so, state specifically and in detail:
(a) The basis for your assertion.
If you have no basis so state.
(b) The review that you would consider to be adequate and the basis for your position in this regard.
Contention 4 C4-1.
State specifically the Technical Specifications referred to in Contention 4.
C4-2.
Do you assert in Contention 4 that NRC Staff review af the pro-posed modifichtions is inadequate to assure that no violations of Technical Specifications will occur while the modifications are being carried out?
If so, state specifically and in detail:
(a) The basis for your assertion.
If you have no basis, so state.
(b) The review that you would consider to be adequate and the basis for your position in this regard.
C4-3.
Do you assert in Contention 4 that NRC Staff review of the modifications is inadequate to assure that no violations of Technical Specifications will occur after the modifications are completed?
If so, state specifically and in detail:
(a) The basis for your assertion.
If you have no basis, so state.
(b) The review that you would consider to be adequate and the basis for your position in this regard.
' s.
Contention 5 C5-1.
State specifically the "NRC Staff inspection procedures" referred to in Contention 5.
C5-2.
State specifically the meaning of the term " safe operation" in Contention 5(a).
C5-3.
Do you assert in Contention 5(a) that NRC Staff " inspection procedures" are inadequate to assure " safe operation" of the Trojan plant before the modifications are begun?
If so, state specifically and in detail the basis for that assertion and indicate the type of inspection that you_ would consider adequate and the basis for your position in this regard.
If you have no basis for such assertion, so indicate.
C5-4.
Do you assert in Contention 5(a) that NRC Staff " inspection procedures" are inadequate to assure " safe operation" of the Trojan plan'. while the modifications are being carried out?
If so, state specifically and in detail the basis for such assertion and indicate the type of inspection that you would consider adequate and the basis for your position in this regard.
If you have no basis for such assertion, so state.
C5-5.
State specifically the meaning of the term " proper completion" in Contention 5(b).
C5-6.
State specifically the basis for your assertion in Contention 5(b) that NRC Staf f Inspectier. procedures are inadequate to
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assure proper completion of the modifications?
If you have no basis for such assertion, so state.
Also, describe speci-fically and in detail the type of inspection procedures that you would consider adequate and the basis for your position in this regard.
Contention 6 C6-1.
State specifically the meaning of the word " Commission" as used in Conten*1on 6.
(i.e., NRC Management, licads of Offices, or the Commissioners).
C6-2.
State specifically the " serious safety issues" referred to in Contention 6.
C6-3.
State specifically and in detail the basis for your assertion in Contention 6 that the NRC Staff will not inform the Com-mission or the public of serious safety issues concerning the operation of the Trojan plant.
If you have no basis, so state.
Ale state specifically and in detail:
(a) the type of information regarding " serious safety issues" at Trojan which the NRC Staff should provfde to "the Commission" and the public and the basis for your position in this regard.
(b) the manner in which the modifications have any bearing on, or might' affect, the alleged
" serious safety issues concerning the operation of the Trojan plant."
_ 10 _
Contention 7 C7-1.
State specifically your understanding of the term " health effects" as that term is used in Contention 7.
C7-2.
Do you assert in Contention 7 that the Licensee and the NRC Staff cannot obtain the necessary information to evaluate any
" health effects" on workers performing the modifications?
If so, state specifically and in detail the basis for that assertion and indicate the type of information which you consider necessary to evaluate the " health effects" on workers performing the modifications and the basis for your position in this regard.
If you have no basis for such assertion, so indicate.
C7-3.
Do you assert in Contention 7 that the Licensee and the NRC Staff will not obtain the necessary information to evaluate any " health effects" on workers performing the modifications?
If so, state specifically and in detail the basis for that assertion.
If you have no basis for such assertion, so indicate.
C7-4.
State specifically and in detail the basis for your assertion in Contention 7 that the Licensee and the NRC Staff have not evaluated the " health affects" on workers performing the modifications.
If you have no basis, so state.
Also, state specifically and in detail the type of evaluation which you believe both the Licensee and NRC Staff should perform regard-ing the " health effects" on workers performing the modifi-cations, and the basis for your position in this regard.
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C9-2.
Describe the " increased risk of accident" that is referred to in Contention 9.
C9-3.
State specifically what is meant by the phrase " equal to and exceeding 10 CFR 100" as used in Contention 9.
C9-4.
Do you assert in Contention 9 that there will be an " increased risk of accident" at Trojan during the modification work that would lead to a release of radiation " equal to and exceeding 10 CFR 100" if Trojan operates during such work?
If so, state specifically and in detail the basis for such assertion.
If you have no basis, so indicate.
C9-5.
Do you assert in Contention 9 that neither the Licensee nor the NRC Staff would inform the " general public" of the alleged
" increased risk of accident" at Trojan during the modification work that would lead to releases of radiation " equal to and exceeding 10 CFR 100" if Trojan operates during such work? If so, state specifically and in detail:
(a) The basis for your assertion.
If you have no basis, so state.
(b) The type of information that you believe the Licensee and NRC Staff should provide the " general public" concerning any alleged
" increased risk of accident" at Trojan during the modification work that would lead to releases of radiation " equal to and exceeding 10 CFR 100" if Trojan operates during such work.
Also state the basis for your position in this regard.
If there is no basis, so indicate.
Contention 10 C10-1.
State specifically what is meant by the term " proper material purchase" as it is used in Contention 10(a).
C10-2.
Do you assert in Contention 10(a) that the NRC Staff is required to have quality assurance programs related to
" proper material purchase"?
If so, state specifically and in detail the basis for that assertion and indicate the type of NRC Staff quality assurance program related to " proper material purchase" you consider adequate and the basis for your position in that regard.
If you have no basis for such assertion, so indicate.
C10-3.
State specifically and in detail the basis for your assertion in Contention 10(a) that the quality assurance programs of PGE, Bechtel, contractors, subcontractors, and NRC Staff are inadequate to assure " proper material purchase" If you have no basis, so indicate. Also state specifically and in detail:
(a) The type of quality assurance programs re-lated to " proper material purchase" you would consider adequate and the basis for your position in this regard.
(b)
State the manner in which the adequacy of any " quality assurance programs of PGE, Bechtel, contractors, subcontractors, and NRC Staff" related to " proper material purchase" has any bearing on or might affect the modifications which are the subject of this proceeding.
C10-4.
State specifically what is meant by the term " proper completion of rnodifications" as that term is used in Contention 10(b).
C10-5.
Do you assert in Contention 10(b) that the NRC Staff is required to have quality assurance programs to assure " proper completion of modifications"?
If so, state specifically and in detail the basis for that assertion and indicate the type of NRC Staff quality assurance programs which you would consider adequate to assure " proper completion of medifications", and the basis for your position in that regard.
If you have no basis for such assertion, so state.
C10-6.. Stat e upecifically and in detail the basit. for your assertion in Contention 10(b) that the quality assurance programs of PGE, liecht el, cont rac tors, subcontractors and NRC Staff are inadequate to assure " proper completion of modifications".
If you have no basis, so utate.
Also state specifically and in detail the type of quality assurance programs of PGE, llechtel, contractors, subcontractors, and NRC Staff which you would consider adequate to assure " proper completion of modi-fications," and the basis for your position in this regard.
Contention 11 Cll-1.
State specifically wl)t it meant by t he term " review procedures" as it is used in Contention 11.
C11-2.
Define specifically the term " safe operation"as it is used in Contention 11.
Cll-3.
State specifically and in detail the basis for your assertion in Contention 11 that the inspection and " review prcedures" of NRC Staff are inadequate to assure " safe operation" of the Trojan plant while the modification work is being done.
If you have no basis, so state.
Also, describe specifically and in detail the inspection and " review procedures" of the NRC Staff which you would consider adequate to assure " safe operation" of the plant while modification work is being done, and the basis for your position in this regard.
Contention 12 C12-1.
Identify the person or organization which you believe should be provided information by the Licensee which shows that the plant can be operated during modification work without "an undue risk to the public health and safety."
C12-2.
State specifically your understanding of the term "an undue risk to the public health and safety" as that term is used in Contention 12.
C12-3.
State specifically and in detail the basis for your assertion in Contention 12 that the Licensee has not provided infor-mation which shows that the plant can be operated during modification work without "an undue risk to the public health and safety".
If you have no basis, so state.
Also state specifically and in detail the type of information which you believe the Licensee should provide which will show that the plant can be operated during modification work without "an undue risk to the public health and safety," and the basis for your position in this regard.
Contention 13 C13-1.
Define the term " operate in a safe condition" as that term is used in Contention 13.
C13-2.
State specifically and in detail the basis for your assertion in Contention 13 that the plant cannot " operate in a safe condition" while the modification work is being done.
If there is no basis for such assertion, so indicate.
Contention 14 C1s-l.
State specifically what is meant by the term "assestment" [ sic]
as that term is used in Contention 14.
C14-2.
Define the term "added risk" as that term is used in Contention 14.
C14-3.
Identify specifically the " safety-related equipment" referred to in Contention 14. '
C14-4.
State sr.ecifically and in detail the basis for your assertion in Contention 14 that the Licensee has performed no "assestment" (sic], or "an inadequate "assestment" [ sic] of "added risk to the safety-related equipment".
If you have no basis, so state.
Also state specifically and in detail:
(a) The "assestment" [ sic] by the Licensee of added " risk to safety-related equipment" which you would consider adequate, and the basis for your position in this regard.
(b) The manner in which the modifications will affect, or have any bearing on the "added risk to safety-related equipment," identi-fled above.
Contention 15 C15-1.
State specifically what is meant by the term " safe operation" as that term is used in Contention 15.
C15-2.
State specifically and in detail the basis for your assertion in Contention 15 that the Licensee has not identified "all safety equipment or equipment needed for safe operation of the plant that would be affected by proposed modifications".
If there is no basis, so state.
Contention 16 C16-1.
State specifically what is meant by the term "all safety equipment" as that term is used in Contention 16.
C16-2.
State specifically what is nicant by the term " equipment for safe operation during modification work."
C16-3.
State specifically and in detail tiie basis for your assertion in Contention 16 that the " Licensee has not made any plans to protect all safety equipment and equipment for safe operation
during the modification work."
Ii you have no basis, so state.
Also describe specifically and in detail the plans to protect "all safety equipment and equipment for safe operation during modification work" which you believe the Licensee should devise and/or implement, and state the basis for your position in this regard.
Contention 17 C17-1.
Describe what is meant by the term " plant operators" as that term'is used in Contention 17.
C17-2.
State specifically what is meant by the phrase " respond to any emergency properly" as that phrase is used in Contention 17.
Cli-3.
State specifically your understanding of the phrase " undue risk to the public health and safety" as that phrase is used in Contention 17.
C17-4.
State specifically and in detail the basis for your assertion in Contention 17 that performance of " modification work will hamper the ability of plant operators to respond to any eter-gency properly and thus pose an undue risk to the public health and safety." If you have no basis, so state.
Also describe specifically and in detail the type of response to "any emer-gency" which you consider proper and the basis for your position in this regard.
Contention 18 C18-1.
State specifically the " security measures" ref vred to in Con-tention 18, or if you are referring to no specific security measures, define what is meant by that phrase.
C18-2.
Do you assert in Contention 18 that the Licensee's provisions for security are inadequate?
If so, state specifically and in detail the basis, for that assertion and indicate the type of
" security measures" that you consider adequate and the basis for your position in this regard.
If you have no basis for such assertion, so indicate.
C18-3.
Do you assert in Contention 18 that the implementation of the licensee's provisions for security is inadequate?
If so, state specifically and in detail the basis for that assertion.
If you have no basis for such assertion, so indicate.
C18-4.
State specifically the manner in which the modifications have any bearing on, or might affect the adequacy of " security measures" at the Trojan Plant.
Contention 19 C19-1.
State specifically your understanding of the phrase " method of seismic qualification" as that phrase is used in Contention 19.
C19-2.
Identify specifically the " safety related equipment" referred to in Contention 19.
C19-3.
State specifically and in detail:
(a) The basis for your assertion in Contention 19 that the Licensee's " method of seismic qualification of safety related equipment is inadequate to qualify such equipment."
If you have no basis, so indicate.
(b) The " method of seismic qualiffcation of safety related equipment" which you consider adequate to qualify such equipment and the basis for your positioa in that regard.
(c) The manner in 1hich the modifications will have any bearing on, or might relate to the adequacy of the licensee's " method of seismic qualification of safety related equipment."
Contention 20 C20-1.
Describe specifically the " existing cracks" referred to in Con-tention 20.
C20-2.
Do you assert in Contention 20 that while the modifications are being carried out, the drilling in the Control Building walls will affect " existing cracks"?
If so, state specifically and in detail the basis for that assertion, if you have no basis for such assertion, so indicate.
C20-3.
Do you assert in Contention 20 that before work on the modifi-cations begins, the Licensee is required to assess "the effects of drilling in Control Building wails on existing cracks"? If so, state specifically and in detail:
(a) The basis for that assertion.
If you have no basis, so state.
(b) The type of assessment which you believe the Lic;nsee should perform relating to
" effects of drilling in Control Building walls on existing cracks."
Contention 21 C21-1.
State speci.2cally what is meant by the phrase " operated safely" as it is used in Contention 21.
C21-2.
State specifically and in detail:
(a) The basis for your assertion in Contention 21 that the plant cannot be " operated safely while new Emergency Diesel Generator com-bustion air supply is installed.# If you have no basis, so state.
(b) The manner in which this assertion relates to the modifications.
, Contention 22 C22-1.
State specifically your understanding of the term " building deflection" as that term is used in Contention 22.
C22-2.
Do you assert in Contention 22 that the proposed modifications will affect " building deflection" between the Control Building and the Turbine Building? If so, state specifically and in detail the basis for your assertion'.
If you have no basis, so indicate.
C22-3.
State specifically and in detail the basis for your assertion in Contention 22 that the Licensee underestimates the effect of the proposed modifications on " building deflection" between the Control Building and the Turbine Building.
If you have no basis, so indicate.
Contention 23 C23-1.
What is meant by the term " financial interest" as that term is used in Contention 23?
C23-2.
What is meant by the term " proper performance" as that term is used in Contention 23?
C23-3.
Identify specifically the " work" referred to in Contention 23.
C23-4.
State specifically and in detail the basis for your assertion in Contention 23 that"Bechtel's financial interest will not allow for proper performance of work".
If you have no basis, so state.
Contention 24 C24-1.
What is meant by the term " financial interest in allowing plant operation" as that phrase is used in Contention 24?
C24-2.
Describe specifically the " safety risks" referred to in Con-tention 24.
C24-3.
State specifically and in detail:
(a) The basis for your' assertion in Con-tention 24 that the " Licensee's financial interest in allowing plant operation will not allow an adequate assest (sic} by Licensee of safety risks."
If you have no basis, so indicate.
(b) The assessment of safety risks which you consider adequate, and the basis for your position in this regard.
(c) The manner in which the modifications affect, or have any bearing on the " safety risks" referred to above.
Contention 25 C25-1.
State specifically and in detail the basis for your assertion in Coatention 25 that the " plant is not needed during the period of modifications".
If you have no basis, so state.
C25-2.
State specifically and in detail how the major issue to be considered in Phase II of the Control Building proceeding (whether the scope and timeliness of the modifications required by the 11ay 26,1978 Order to bring the facility into substantial compliance with the license arc adequate from a safety stand-point) relates to the question of whether or not the Trojan plant is needed during the period of modifications.
Contention 26 C26-1.
State specifically and in detail:
(a) The basis for your assertions in Contention 26.
If you have no basis, so state.
(b) The manner in which the assertions made in Contention 26 relate to the proposed modi-fications.
Respectfully submitted, Atct (14Y 0 UbM<W Marjorie B. Ulman Counsel for NRC Staff Dated at Bethesda, Maryland this 9th day of March, 1979 O
s UNITED STATES OF fJ1 ERICA NUCLEAR REGULATORY C0",MISS10r BEFORE THE ATOMIC SAFETY AND LICENS,NL OARD In the Matter of
)
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Docket I!o. 50-344 PORTLAND GENERAL ELECTRIC COliPANY, )
(Control Building)
_E f_ A_ _L_.
)
(Trojan !!uclear Plant)
)
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NRC STAFF INTERROGATORIES TO, AND REQUEST FOR' Tile PPODUCTION OF DOCUMENTS FROM, CONSOLIDATED INTERVENOR NINA BFLL The Nuclear Regulatory Cowission (NRC) Staf f hereby reque..s that Consolidated Intervenor Nina Bell, pursuant to 10 CFR 52.740b, answer separately and fully, in writing under oath or af finnation, the following interrogatories within 14 days after service hereof.
For each response to the interrogatories listed selow, identify the person or persons who prepared, or substantially contributed to the preparation of the response, if, in fact, the response was prepared in whole or in part by someone other than Nina Bell.
The NRC Staff further requests that the Intervenor, pursuant to 10 CFR 52.741, provide cooies of, or nake available for Staff inspection and copying, the documents designated by the Intervenor in response to cer-tair of the accompanying interrogatories.
'2-General Interroga to r_ies_ 3 /
I.
G-1.
State whether or not you intend to call any person or persons as witnesses in this proceeding in support of (a) Contention 1 (j ) Contention 10 (s) Contention 19 (b) Contention 2 (k) Contention 11 (t)
Contention 20 (c)
Contention 3 (1)
Contention 12 (u) Contention 21 (d) Contention 4 (m) Contention 13 (v) Contention 72 (e) Contention 5 (n) Contention 14 (w) Contention 23 g
(f) Contuntion 6 (o) Contention 15 (x)
Contention 24 (g) Contention 7 (p)
Contention 16 (y), Contention 25 (h) Contention 8 (q)
Contention 17 (i) Contentjon 9 (r) Contention 18 and provide the naiaes, addresses, educational background, and professional qualifications of those persons you intend to call.
G-2.
Indicate whether thor,e persons identified in response to Interrogatory No. G-1 in support of (a) Contention 1 (j)
Contention 10 (s)
Contention 19 (b)
Contention 2 (k) Contention 11 (t) Contention 20 (c)
Contention 3 (1) Contention 12 (u)
Contention 21 (d) Contention 4 (m) Contention 13 (v) Contention 22 (e) Contention 5 (n) Contention 14 (w)
Cc,tention 23 (f) Contention 6 (o) Contention 15 (x)
Co,tention 24 (g) Contention 7 (p)
Contention 16 (y)
Contention 25 (h) Contention 8 (q) Contention 17 (i)
Contention 9 (r) Contention 18 will appear voluntarily or under subpocna.
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Interrogatorilis in this section should be answered uith respect to each contention.
The contentions referred to are those set forth in " Consolidated Intervenors' Contentions for Phase 2 Hearings,"
dated February 26, 1979.
G-3.
Provide sumaries of the views, positions, or proposed testinony on (a) Contention 1 (j )
Contention 10 (s
Contention 19 (b) Contention 2 (k)
Contention 11 (t
Contention 20 (c) Contention 3 (1) Contention 12 (u
Contention 21 (d) Contention 4 (m) Contention 13 (v) Contention 22 (e) Contention 5 (n)
Contention 14 (w)
Contention 23 (f)
Contention 6 (o)
Contention 15 (x) Contentinn 24
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(g) Contention 7 (p)
Contention 16 (y) Contention 25 I
(h) Contention 8 (q)
Contention 17 (i) Contention 9 (r) Contention 18 of all persons named in response to Interrogatory No. G-1 that you intend to present during this proceeding.
G-4.
Identify by author, title, date of publication and publisher, all books, documents, and papers that you intend to employ or rely upon in presenting your direct case on (a) Contention 1 (j)
Contention 10 (s)
Contention 19 (b) Contention 2 (k) Contention 11 (t) Contention 20 (c) Contention 3 (1) Contention 12 (u)
Contention 21 (d) Contention 4 (m) Contention 13 (v)
Contention 22 (e) Contention 5 (n) Contention 14 (w)
Contention 23 (f) Contention 6 (o) Contention 15 (x) Contention 24 (g) Contention 7 (p) Contention 16 (y)
Contention 25 (h) Contention 8 (q) Contention 17 (i) Contention 9 (r)
Contention 18 and provia copies of, or make available for Staff inspec-tion ed copying, these items.
G-5.
If the epresentations nade in (a
Contention 1 j) Contention 10 (s) Contention 19 (b
Contention 2 k) Contention 11 (t) Contention 20 (c
Contention 3 1)
Contention 12 (u) Contention 21 (d) Contention 4 (m)
Contention 13 (v) Contention 22 (e) Contention 5 (n)
Contention 14 (w)
Contention 23 (f) Contention 6 (o)
Contention 15 (x) Contention 24 (g) Contention 7 (p)
Contention 16 (y)
Contention 75 (h) Contention 8 (q) Contention 1/
(i) Contention 9 (r) Contention 18 l
are based in whole or in part on any docunehts prepared by the Licensee or NRC Staf f which you contend are deficient, speci fy which documents, and the particular portions thereof, you regard as deficient and explain why they are deficient.
G-6.
Identify by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in conductinj your cross-examination of prospective NRC Staff witnesses testifying in connection with (a) Contention 1 (j)
Contention 10 (s)
Contention 19 (b) Contention 2 (k) Contention 11 (t)
Contention 20 (c) Contention 3 (1)
Contention 12 (u)
Contention 21 (d) Contention 4 (m) Contention 13 (v) Contention 22 (e)
Contention 5 (n) Contention 14 (w)
Contention 23 (f) Contention 6 (o)
Contention 15 (x)
Contention 24 Contention 7 (p) Contention 16 (y)
Contention 25 (g))
(h Contention 8 (q) Contention 17 (i)
Contention 9 (r) Contention 18
.5-II.
Questions Pela ted to Speci fic Contentions Contention 1 Cl-1.
State specifically the " personnel" referred to in Conten-tion 1(a).
Cl-2.
(a)
Do you assert in Contention 1(a) that the licensee's provisions for screening of personnel are inadequate?
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(b)
State specifically and in detail the basis for Contention 1(a).
If you have no basis, so state.
(c)
Indicate the type of screening that you consider adequate and state the basis for your position in this rega rd.
Cl-3.
(a) Do you assert in Contention 1(a) that the implementa-tion of the licensee's provisions for screening of personnel is inadequate?
(b) State specifically and in detail the basis for your assertion.
If you have no basis for such assertion, so indicate.
Cl-4 State specifically the manner in which the modifications have any bearing on, or might affect, the screening of pe rsonnel.
Cl-5.
State specifically the " physical security measures" referred to in Contention 1(b), or, if you are referring to no specific physical security neasures, define what is neant by that phrase.
Cl-6.
Identi fy the " additional workers" for the " general plant" referred to in Contention 1(b) and indicate the ranner in
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which the workers thus identified have any b' earing on or relationship to the nodifications which are the subject of this proceeJing.
Cl-7.
State specifically the manner in which the modifications have any bearing on, or might affect the physical security neasures necessary to accunmodate the additional workers for the nodification.
Cl-8.
(a) Do you assert in Contention 1(b) that the licensee's provisions for physical security measures are inadequate?
(b)
State specifically and in detail the basis for Contention 1(b).
If you have no basis for your assertion, so state.
,7-(c)
Indicate the physical securi ty i,easu res tha t yo_u_
conside adequate and the basis for your position in this rega rd.
Cl-9.
(a)
Do you assert in Contention 1(b) that the implementa-tion of the licensee's physical security measures is inadequate?
I (b)
State specifically and in detail the basis for your assertion.
If you have no basis for such assertion, so indicate.
Cl-10.
Dafine " security personnel" as that tenn is used in Contention 1(c).
Cl-ll.
Define " general plant vicinity" as that tenn is used in Contention 1(c).
Cl-12.
(a) Do you assert in Contention 1(c) that, because of the modifications, additional security personnel will be required for some or all work shif ts, for the " general plant vicinity," and/or for "high-security areas"?
(b)
State specifically and in detail the basis for Contention 1(c).
If you have no basis for such assertion, so state.
Cl-13.
Describe the " training for workers" that is referred to in Contention 1(d).
Cl-14.
What " workers" are being referred to in Contention 1(d)?
Cl-lS.
State specifically and in detail what is meant by
" training... in the areas of plant equipnent" and state
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why that has any bearing on or relationship 'to the pro-posed raoJi fications.
Cl-16.
(a)
Do you assert in Contention 1(d) that the licensee's prov.slons with regard to the security-related training of workers is inadequate?
(b)
State specifically and in detail the basis for Contention 1(d).
If you have no basis, so state.
(c)
Indicate what security-related training measures you consider cdequate and the basis for your position in this regard.
Cl-17.
(a) Do you assert in Contention 1(d) that the implementa-tion of the licensee's provisions with regard to security-related training of workers is inadequate?
9 (b)
State specifically and in detail the basis for your assertion.
If you have no basis, so state.
Cl-18.
Contention I states that it pertains to four iteins set forth in parts (a) through (d) but that it is "not limited to" those four i tems.
State specifically the other aspects of " security at the Trojan plant during modifications" I
which you contend are " inadequate" and set f' orth specifically and in detail the basis for your assertions in this regard and the nanner in which such alleged inalfequacies relate to the nodifications.
Contention 2 C2-1.
Specifically identify the " cable penetrations" referred to in Contention 2(a).
C2-2.
(a)
Do you assert in Contention 2(a) that, during the modifications, fire protection for the cable penetra-tions identified above will be inadequate?
(b)
State specifically and in detail the basis for Contention 2(a).
If you have no basis, so state.
(c)
State specifically and in detail the fire protection measures you would consider to be adequate and the basis for your position in this regard.
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(d) State speci fically and in detail the manner in which the modification will af fect the risk of fire with respect to the " cable penetrations" ident.ified above.
C2-3.
State your understanding of the " Single Failure Criterion" as that tenn is used in Contention 2(b).
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C2-4.
(a)
Do you assert in Contention 2(b) that the fire protec-tion provisions "at the Trojan plant during the nodifications" will not ir.eet "the Single failure Criterion of 10 CFR Part 50, App. A"?
(b) State specifically and in detail the basis for Contention 2(b).
If you have no basis, so state.
(c)
Describe the fire protection measures you consider necessary to iaeet the " Single Failure Criteritn" and state the basis for your position in this rejard.
(d) Describe the relationship between the Control Building modifications and Single Failure Criterion with regard to fire protection and indicate how the nodifi-cations inight affect the single failure criterion with regard to fire protection.
C2-5.
Specifically identify the welding "in the Cable Spreading Room" referred to in Contention 2(c).
Also, specifically identify any other welding that Contention 2(c) is intended to enco:apass.
C2-6.
(a)
Do you assert in Contention P(c) that fire protection with regard to welding related to the modifications is inadequate?
(b)
State specifically and in detail the basis for Contention 2(c).
If you have no basis, so state.
(c) Describe the fire protection measures with regard to welding related to the laodifications that you_ consider to be adequate and state the basis for your position in this regard.
C2-7.
Identify the areas of the facility you are referring to with regard to the statement on " fire brigade access exits" in Contention 2(d) and indicate why " fire brigade access exits" in those areas might be af fected by the modi fica tions.
C2-8.
(a)
Do you assert in Contention 2(d) that fire brigade access during and/or after the modifications will be inadequate?
(b)
State specifically and in detail the basis for Contention 2(d).
If you havc no basis, so state.
(c) Describe what measures you_ believe should be taken to provide adequate fire brigade access and state the basis for your position in this reoard.
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C2-9.
What is neant by "one division" as that tend is used in Contention 2(e)?
C2-10.
Do you assert in Contention 2(e) that existing fire pro-tection provisions are inadequate to prevent a fire from af fecting both parts of redundant systems necessary for safe shutdown?
If so:
(a)
State specifically and in detail the basis for your assertion.
If you have no basis, so state.
(b) State what.neasures you, believe should t,a taken to prevent a fire from affecting both parts of redundant systems necessary for safe shutdown.
(c) What bearing do the modifications have en fire protec-tion provisions which will prevent a tire from affecting both parts of redundant systems necessary for safe shutdown?
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C2-11.
Do you assert in Contention 2(e) that existing fire protec-tion provisions are inadequate to prevent a fire from af fecting one systr,n of redundant sys tems necessary for safe shutdown, thereby renoving redundancy?
If so:
(a) State specifically and in detail the basis for your assertion.
If you have no basis, so state.
(b)
State what reasures you, believe should be taken to prevent a fire from removing redundancy in systems requi red for sa fe shutdown.
(c) State the location of fires which you claim would "irradicate redundancy in sa fe shutdown capabili ty. "
(d) 'Jhat bearing do the modifications have on fire protec-tion provisions which will prevent a fire from removing redundancy in systems required for safe shutdown?
Contention 3 C3-1.
What " safety-related equipment" is referred to in Contention 3?
C3-2.
What relationship do the modi fications have to the " environ-mental qualification of safety-related equipment identified in response to interrogatory C3-1 and how will the codifica-tions affect environmental qualifications?
C3-3.
(a) Do you assert in Contention 3 that safety-related equipment is not now environnentally and seismically qualified and will not be so qualified during and after the modifications?
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(b)
State specifically and in detail the basis for your assertion in Contention 3.
If you have no basis, so state.
C3-4.
What relationship do the codifications have to the seismic qualification of safety-related equipment and how will the modi fications af fect seismic qualifications?
Contention 4 C4-1.
Identify the structures referred to in the phrase "exten-sive removal of structures" used in Contention 4.
C4-2.
What is meant by " impair the ability of the plant and its operators to operate safely"? Does "impai r" mean " prevent" or does it mean "make more dif ficult"?
C4-3.
(a) Do you assert in Contention 4 that the nodifications will impair the ability of the plant and operators to operate safely?
(b) State specifically and in detail the basis for Contention 4.
If you have no basis, so state.
I Contention 5 C5-1.
State specifically and in detail the basis for Contention 5.
If you have no basis, so ' tate.
s C5-2.
Do you assert in Contention 5 that the proposed design, construction and placement of the steel plate is defec-tive?
If so, state specifically and in detail the basis for such assertion.
If you have no basis, so state.
C5-3.
Do you assert in Contention 5 that the design, construc-tion and placement of the steel plate will jeopardize safe operation during and after the installation?
If so:
(a) State specifically and in detail the basis for your assertion.
(b) Describe the manner in which safe operation will thus be jeopardized during installation, and after installation.
Contention 6 C6-1.
State specifically and in detail the basis for Contention 6.
If you have no basis, so state.
C6-2.
Do you assert in Contention 6 that the licensee and its contractors and subcontractors do not have adequate quality assurance programs for the modifications?
If so, state i
specifically and in detail the basis for thi's assertion.
If you have no basis, so state.
C6-3.
Describe the measures which you believe are necessary to make the quality assurance program of the licensee, its contractors and subcontractors adequate for the nodifica-tion work.
C6-4.
What is meant by "quali ty assurance neasures... by the fiRC Staff" as that phrase is used in Contention 67 Contention 7 C7-1.
State specifically and in detail the basis for Contention 7.
If you have no basis, so state.
C 7-2.
Identify the " safety-related equipment and cables" referred to in Contention 7.
C 7-3.
Do you assert in Contention 7 that the nodifications will adversely affect the integrity of safety-related equipment and cables while the modifications are underway?
If so, state specifically and in detail the basis for such asser-tion.
If you have no basis, so state.
Identify the nanner in which the nodifications will ar versely affect safety-related equipment and cables.
I
_ Cont _ention 8 C8-1.
b' hat is meant by "an adverse affect on the design and construction of the modifications" as that phrase is used in Contention 87 Give exanples of the types of " adverse affects" you intend this contention to encompass.
_ Contention 9 C9-1.
Identify the " parties" referred to in Contention 9 and describe the " vested ' ~ erests" you assert will lead to an inadeauate assessment of whether shutdown is necessary during modifications.
Contention 10 C10-1.
Describe the relationship between the regional need for Trojan power and the Control Building modifications which are the subject of Phase II of this proceeding.
State the manner in t.hich the proposed nodifications will affect the regional need for Trojan power.
C10-2.
What region is referred to in the phrase " regional need" as that phrase is used in Contention 10?
C10-3.
State specifically and in detail the basis for your
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assertion that "there is no regional need fo'r electricity generated by the Trojan plant."
Contention 11 C11-1.
What " drilling" is referred to in Contention 11? State the location and size and number of holes.
C11-2.
As to the " effects of drilling" referred to in Contention 11:
(a) Describe the " effects" you had in mind when you formulated this contention.
(b)
Identify the structures and equipment that you believe would be effected.
C11-3.
State specifically and in detail the basis for your assertion that the assessment of the effects of drilling is inadequate.
If you have no basis, so state.
Indicate the additional evaluations you believe to be necessary to make the assess:nent of drilling ef fects adequate.
Contention 12 C12-1.
What is the substantive dif ference between Contention 12 and Contention 47 C12-2.
State specifically and in detail the basis for Contention 12.
If you have no basis, so state.
C12-3.
(a)
Do you assert in Contention 12 that the perfonnance of modifications will adversely affect the safety of concurrent operation?
If so, state why.
(b) What infonnation on the affect of modifications on operation do you assert is missing?
Contention 13 C13-1.
State specifically and in detail the basis for Contention 13.
If you have no basis, so state.
C13-2.
(a)
Do you assert in Contention 13 that the modifica-tions, once completed, will not substantially restore the desired and intended margins with regard to seismic capability as required by the NRC's Order for Modification of License of May 26,19/8?
If so, state specifically and in detail the basis for your assertion.
If you have no ba',is, so state.
(b) Do you assert in Contention 13 that even if the r:odi-fications restore the desired and intended margins with regard to seismic capability as rdquired by the May 26,19/8 Order, such seismic capability is insuf ficient to give reasonable assurance of protec-tion of the public health and safety?
If so, state specifically and in detail the basis for such asser-tion.
If you have no basis, so state.
C13-3.
What additional infonnation do you assert is necessary "to provide reasonable assurance that modifications will protect the public health and safety?"
Contention 14 C14-1.
State specifically and in detail the basis for Contention 14.
If you have no basis, so state.
Cl4-2.
What is meant by " sufficient conservatisms in the strength of the Complex" as that phrase is used in Contention 14?
In your answer, explain whether you are referring to the Control Building complex in its present unnodified state, during nodifications or after modifications have been completed.
Cl4-3.
What additional infonration do you_ believe is necessary to provide " reasonable assurance that there remain sufficient conservatisms in the strength of the Complex."
Contention 15 C15-1.
Uhat is the substantive difference between Contention 15 and Contention 6?
C15-2.
State specifically and in detail the basis for Contention 15.
If you have no basis, so state.
C15-3.
Is the " proper quality assurance and inspection" referred to in Contention 15 that related to the nodification?
If not, describe the work Contention 15 is intended to encom-pass and indicate why such work may properly be considered in Phase II of this proceeding.
C15-4.
What additional information do ygg[ believe is necessary to provide " reasonable assurance that proper quality assur-ance and inspection will be implemented?"
Contention 16 C16-1.
State specifically and in detail the basis for Contention 16.
If you have no basis, so state.
C16-2.
Identify the sources of radiation referred to in Conten-tion 16.
l C16-3.
Do you assert in Contention 16 that workers 'will suffer genetic and biological damage from radiation they were exposed to while perfonaing the modifications?
C16-4(a)
Is it your understanding that the licensee must comply with the provisions of 10 CFR Part 20 with regard to occupational exposures?
(b)
Do you assert that 10 CFR Part 20 does not provide adequate radiation protection for workers? If so, state specifically and in detail the basis for your assertion in this regard.
C16-5 What protective measures do yjg[ believe are necessary to provide " reasonable assurance that workers will not suffer genetic or biological damage from radiation while perform-ing modi fications?"
Contenti_on 17 C17-1.
State specifically and in detail the basis for Contention 17.
If you have no basis, so state.
C17-2.
State your understanding of the analysis and review of the proposed modifications to be undertaken by the fiRC Staff.
What additional nalysis and review by the Staff do you believe to be necessary?
Contention 18 C18-1.
State specifically and in detail the basis for Contention 18.
If you have no basis, so state.
C18-2.
What is meant by " supervision over workers" as that phrase is used in Contention 18?
C18-3.
What measures do you believe to be necessary to assure that " adequate supervision over workers will be naintained during construction and modifications?"
Contention 19 C19-1.
State specifically and in detail the basis for Contention 19.
If you have no basis, so state.
Contention 20 C20-1.
State specifically and in detail the basis for Contention 20.
If you have no basis, so state.
C20-2.
Describe the "effect of the steel plate on displacement in the Complex" which you refer to in Contention 20.
Are you referring to building-to-building displacement, inters to ry
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displacement or so;ne other kind of displacement?
C20-3.
Do you assert in Contention 20 that the steel plate will have an adverse effect on displacements within the complex?
If so, why?
C20-4.
What additional analyses, beyond that submitted thus far by the licensee with respect to the modifications, do you believe to be necessary to canpletely analyze the effect of the steel plate on displacement in the complex?
Contention 21 C21-1.
What is meant by " woefully inadequate" as that phrase is used in Contention 21? State specifically and in detail the basis for Contention 21.
If you have no basis, so state.
Contention 22 C22-1.
State specifically and in detail the basis for your asser-tion in Contention 22 that:
(a)
"NRC Staff inspection nethods are inadequate;"
(b)
"NRC Staff... personnel are inadequate;"
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(c)
"NRC Staf f... record-keeping" i s inadequa te.
As to each, if you have no basis, so state.
C22-2.
You state that NRC Staff " inspection methods" are inade-quate.
Identify the inspection methods referred to and describe for what purpose they are inadequate.
C22-3.
You state that NRC Staff " personnel" are inadequate.
Identify in general tenas the personnel referred to and describe for what purpose they are inadequate.
C22-4.
You state that NRC Staf f " record-keeping" in inadequate.
Identify the records and record-keeping practices referred to and describe for what purpose they are inadequate.
. a C22-5.
What is the relationship between the "NRC Staf f inspection methods, personnel and record-keeping" referred to in Contention 22 and the Control Building nodifications which are the subject of Phase II of this proceeding?
Contention 23 C23-1.
State specifically and in detail the basis for Contention I
23.
If you have no basis, so state.
C23-2.
Describe the " bolt placement" referred t'o in Contention 23.
C23-3.
What are your safety concerns with regard to bolt place-ment - i.e. what structures, systems, components, opera-tions or processes do you contend will be made unsafe because of bolt placement?
Contention 24, C24-1.
State specifically and in detail the basis for Contention 24.
If you have no basis, so state.
C24-2.
What do you mean by " risk assessment study?"
C24-3.
Is the " risk assessment study" referred to in Contention 24 the " Reactor Safety Study", WASH-1400?
If so, identify
any documents, studies, safety evaluations and/or analyses and particular parts thereof in which WASH-1400 was relied upon to justify operation of the Trojan plant.
C24-4.
Identify any documents, studies, safety evaluations and/or analyses and particular parts thereof in.;hich a risk dssessment study is relied upon to justify operation of k
Trojan until modifications are completed.
C24-5.
What is the relationship between the " risk assessnent study" referred to in Contention 24 and the modifications which are the subject of Phase II of this proceeding?
Contention 25 C25-1.
State specifically and in detail the basis for Contention 25.
If you have no basis, so state.
C25-2.
What is the relationship between the alleged lack of a
" method, facility or repository for the pemanent disposal of radioactive waste" and the modifications which are the subject of Phase II of this proceeding?
Respectfully submitted,
,5&[
k osep R. Gray
Counsel for NRC Staf Dated at Bethesda, Maryland this 9th day of March, 1979