ML19263E716
| ML19263E716 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 05/01/1979 |
| From: | Roisman A National Resources Defense Council |
| To: | |
| Shared Package | |
| ML19263E717 | List: |
| References | |
| NUDOCS 7906250082 | |
| Download: ML19263E716 (4) | |
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bMITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
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Of NRC PUBLIC
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'x' UVENT y0933 In The Matter Of
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DUKE POh'ER COMPANY
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Docket No. 70-2623
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(Amendment to Materials License SNM-1773 )
for'Oconee Nuclear Station Spent Fuel
)
Transportation and Storage at McGuire
)
Nuclear Station)
)
NATURAL RESOURCES DEFENSE COUNCIL'S INTERROGATORIES TO THE NRC STAFF Pursuant to 10 CFR S 2.740 (b), Intervenor Natural Resources Defense Council (NRDC) requests that the attached interrogatories be answered fully, in writing and under oath, by one or more officers or employees of Applicant who has personal knowledge thereof or is the closest to having personal knowledge thereof, If the interrogatories are answered by more than one person, whether or not he or she verified the answers, and whether or not he or she is an officer or employee of Applicant, such person's name and title should be set forth, together with an identification of which interrogatories he or she is responsible for answering.
Each question is instructed to be answered in six parts, as follows:
2218 219 Answer to Question (A) Provide the direct answer to the question.
(B) Identify all documents and studies, and the particular parts thereof, relied upon by Applicant, I a 7 90625 LXAfl?
2 now or in the past, which serve as the basis for the answer.
In lieu thereof, at Applicant's option, a copy of each such document and study may be attached to the answer.
(C) Identify all documents and studies, and the particular parts thereof, examined but not relied i
upon by Applicant, which pertain to the subject matter questioned.
In lieu thereof, at Applicant's option, a copy of each such document and study may be attached to the answer.
(D) Identify by name and affiliation each Applicant employee or consultant that has the expert knowledge required to support the answer to the question.
(E) Explain whether Applicant is presently engaged in or intends to engage in any further research or work which may affect Applicant's answer.
Identify such research or work.
(F) Identify the expert (s), if any, whom Applicant intends to have testify on the subject matter questioned.
State the qualifications of each such expert.
The Interrogatories attached are to be considered your continuih6I,'obligatio a.
Accordingly, if, after you ha<e answered these Interrogatories, additional information comes to your. attention with respect to one or more of your answers, then you are required ;o amend your answers to provide such additional information.
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3 The request to answer in detail or explain or justify or give references should be interpreted to mean provide more than mere reference to source and summaries of conclu-sions.
Actual reproduction of critical portions of the source should be provided and the bases for conculsions should be explained.
While PSAR and E.R.. references are helpful, they are'not normally source but merely summary.
The request for detail should be interpreted in light of the practical objective of avoiding lengthy cross-examination.
The more data produced now, the less that will have to be elicited in further discovery and cross-examination.
2218 221 e
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4 The following questions reference the April 18, 1979, Weekly Information Report, covering the week ending April 13, 1979.
1.
In enclosure D to the identified Information Report, on page 2, reference is made to the discussion between visiting representatives of FRG and the Division of Safeguards with respect to transportation of spent reactor fuel and research related to sabotage vulnerability of spent fuel shipping casks.
Please provide a complete synopsis of the following:
a.
the people who attended b.
the specific areas discussed c.
the documents which supported or were referenced in any way by persons present at the discussions d.I the idn<Ntes of the meetings, or other n ces taken at the meetings e.
any other information in the possession of the Staf: that relates to the identified subject of discussion.
2.
On page 3 of the same enclosure, reference is made to an order to show cause respecting possible defects in casks for shipping nuclear spent fuel, one of which is apparently owned by the Duke Power Company.
With respect to the order to show cause and the cask owned by the Duke Power Company, provide answers to the following:
a.
What was the basis for the shcw cause order?
b.
Had Duke Power Company indicated in this proceeding that it was intending to use the cask in question for the 2218 222
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purpose of shipping spen' suel between Oconee and Mcd.: ire?
c.
What, if any, impact does the defect have on the timing of the Duke Power Company's proposal to transship the spent fuel between Oconee and McGuire?
d.
What additional information is there in the possession of the Stcff relating to possible defects in the casks which would be used by Duke Power Company for the transshipment of spent fuel between Oconee and McGuire or casks of similar design?
With respect to all documents identified in the questions and answers above, please produce for copying those documents or provide copies of those documents to the undersigned.
Respectfully submitted, d
Anthony d isman j
Natural Resources Defense Council 917-15th Street, N.W.
Washington, D.C.
20005 (202)737-5000 Dated:
May 1, 1979 2218 223 i'a 0'31 7906250