ML19269D504
| ML19269D504 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/14/1979 |
| From: | Bell N AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML19269D505 | List: |
| References | |
| NUDOCS 7906040165 | |
| Download: ML19269D504 (5) | |
Text
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UNITED STATES OF AMERICA
.g M g" y NUCLEAR REGULATORY COMMISSION HG' \\ fy/
g BEFORE IME ATOMIC SAFETY AND. LICENSING BO ARD s
In the Matter of
)
)
s PORTLAND GENERAL ELCTRIC
)
Docket No. 50-344 COMPANY, et al_.
)
(Control' Buildiing)
)
(Trojan Nuclear Plant)
)
CONSOLIDATED INTERVLNOPS ANSWERS TO INTERROGATORIES FROM THE NRC STAFF - SET ONE, PHASE 2 I. General Interrogatories G-1 (a y) Intervenor.has not intention at this time.
G-2 (a-y) see G-1 G-3 (a-y) see G-1 G-4 (a-y) Intervenor has no intention to present a direct case at this time.
G-5 (r. y) To date, the documents which have been filed 'with all parties have been pre-pared by the Licensee; the deficiencies present therein are described in Intervenor's responses to Licensee's first set of Interrogatories.
G-6 (a y) At this time, documents and papers include all filings by the Licensee and th NRC Staff and transcipts of a March 13, 1979 meeting of the Commissioners entitled," Discussion of Seismic Design Problems in Certain Plants".
II Interrogatories on Contentions.
Cl-1 All additical workers employed to perform the codifications.
Cl-2 (a) As Contention 1 clearly states, " Licensee has not submitted sufficient information..." to make this determination.
(b) Information nonexistent.
(c) 10 CFR 2 732 states that the burden of proof is on the " applicant or proponent of an order". Intervenor would be happy to review any information submitted by the Licensee or the NRC Staff.
Cl-3 (a) no.
see Cl-2 (a)
(b) Did not so assert.
Cl-4 The issue raised in Contention one is the possible effect of inadequate screening of personnel on the quality of the modifications,.and the security of the plant.
Cl-5 Any physical security measures such as additional fences and barriers.
2260 068 7906040 N b,
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Cl-6 " Additional workers" refers to all workers employed to peform the modifica-tions taken in conjunction with all other temporary employees at the plant site.
" General plant area" refers to common ares shared by all plant workers.
The bearing the issue of additional workers has on modifications and the plant is a security issue.,,
Cl-7 Intervenor does not understand this question.
Cl-8 (a) see Cl-2 (a)
(b) see C~t-2 (b)
(c) see Cl-2 (c)
Cl-9 (a) No (b) Did not so assert.
Cl-10 Those charged with the duty of maintcining security.
Cl-11 See Cl-6 Cl-12 (a) Intervenor asserts the possible need exists for additional securty personnel.
(b) see Cl-2 (b)
Cl-13 Temporary workers would not have any knowledge of necessary safety precautions that should be taken while working in nuclear power plants.
C1-14 Those employed to do modifications.
C1-15 see C1-13 Cl-16 (a) see Cl-2 (a)
(b) see Cl-2 (b)
(c) see Cl-2 (c)
Cl-17 (a) No (b) No assertaion made.
C1-18 Intervenor did not assert security is " inadequate". Staff would be well advised to read better and quote more accurately in the future. Other espects of securit secrutiy will be provided to the Staff.
C2-1 Those in area of modifications.
C2-2 (a) No, see Cl-2 (a)
(b) see Cl-2 (b)
(c) If Intervenor woule be provided with detailed information on presently proposed measures, she would make an intelligent assessmnet. Also see answer to PGE Interrogatory 1.a.iii.
N (d) see answer to PGE I terrogatory 1.a.ii C2-5 This welding was mentioned during a site visit, Licensee is the party to wton this question should be addressed.
2260 069
C2-6 (a) In view of the limited information Intervenor has, she cannot assert otherwise.
(b) see 'above (c) see C2-2 (a)
C2-7 Insufficient infomation exists on which to base any position including the issue of fire brigade access. In other words, fire protection measures that use flaanable protective blankets are not going to serve their protective function. PGE has not provided fire testing of such protective materials. Thus, Intervenor cannot make a judgement on the adequacy of fire protection measures. See Cl-2 (c)
Contention 2(d) refers to the existance of access for fire brigades which presumably should not be blocked from plant areas in which they might be needed.
C2-8 (a) No (b) see Cl-2 (b)
(c) see Cl-2 (c)
C2-10, C2-ll; NRC Staff itslef has generated this information.
C3-1 All potentially affected by the modifications.
C3-2 An accidnet caused by and during the modifications could lead to environ-mental conditions for which equipment is not qualidified to withstand.
C3-3 (a) No (b) see Cl-2 (b)
C3-4 Ask the Licensee C4-1 All refered to in PGE 1020.
C4-2 See PGE Interrogatories 3.e Either or both cnuld impact on the safe operation of the plant.
C4-3 (a) Contention 4 states that" Licensee has not shown...."
(b) see Cl-2 (b)
C5-1 Site visit indicated greater specificity that presented in PGE 1020 exists with regard to the steel plate. Therefore the entention.
C 5-2 No.
C5-3 No.
C7-1 Licensee has not: 1) identified equipment and cables in areas 6 modifications.
- 2) described work to be done or 3) assessed possible ways in which the latter could affect the former.
C7-2 see above.
C7-3 No.
Cll-1 To i'nstall the steel plate.
If Licensee would tell Intervenor, she would do the same for the Staff.
Cll-2 (a) Cracking, degrading the concrete or exascerbating the existing deformites and cracks.
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C11-2 (b) Those in the vicinity of the drilling or upon which the drilling would be performed.
C11-3 Information not in PGE 1020.
C17-1 It has' not been done to date unless Intervenor is terribly mistaken.
C17-2 The Staff will issue a Safety Evaluation Report. It is Intervenors be-lief that full review of Licensee's designs and analyses would better protect the public health and safety; such is neither required nor expected, nor forthcoming.
C20-1 The infomration is not contained in PGE 1020/
C20-2 All types of displacement discussed in Phase I hearings.
C20-3 No.
C20-4 I am a layperson who cannot propose the scope of the analyses beyond the fact that it is clear that the issue was only minimally addressed in PGE 1020.
Dated this day, the
/\\/ 41n !6 f' 14th'f April, 1979.
na Bell, 'pn g o
Consoldiated Intervenors 2260 071
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