ML19269D670
| ML19269D670 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/15/1979 |
| From: | Gray J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19269D671 | List: |
| References | |
| NUDOCS 7906110206 | |
| Download: ML19269D670 (6) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING-BOARD In the Matter of
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PORTLAND GENERAL ELECTRIC COMPANY, ET AL. )
Docket Nos. 50-344
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(Control Building)
(Trojan Nuclear Plant)
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CERTIFICATE CF SERVICE I hereby certify that copies of "NRC STAFF.'S SEC0f!D SET OF It1 TERR 0 GAT 0 RIES ON PHASE II TO EUGENE ROSOLIE AtiD THE C0ALITION FOR SAFE POUEP," and "f1RC STAFF'S SECOMD SET OF INTERROGMORIES Off PHASE II TO CONSOLIDATED INTERVEtiORS" above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 15th day of
!!ay,1979 :
Marshall E. Miller, Esq., Chairman
- Richard M. Sandvik, Esq.
Atomic Safety and Licensing Board Frank W. Ostrander, Jr.
U.S. Nuclear Regulatory Commission Counsel for Oregon Dept. of Washington, DC 20555
. Energy 500 Pacific Building Dr. Kenneth A. McCollom, Dean 520 S.W. Yamhill Division of Engineering, Portland, OR 97204 Architecture & Technology Oklahoma State University Maurice Axelrad, Esq.,
Stillwater, OK 74074 Lowenstein, Newman, Reis, 8
Axelrad & Toll Dr. Hugh C. Paxton Suite 1214 1229 41st Street 1025 Connecticut Avenue, N.W.
Los Alamos, NM 87544 Washington, DC 20036 Mr. John A. Kullberg Mr. David B. McCoy Route One 348 Hussey Lane Box 250Q Grants Pass, OR 97526 Sauvie Island, OR 97231 Ms. C. Gail Parson Columbia Environmental Council 800 S.W. Green //6 203 S. 1st Street Portland, OR 97206 St. Helens, OR 97051 2256 005 79061102 O E C
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H. H. Phillips, Esq.
Alan S. Rosenthal, Esq.*
Vice President, arate Atomic Safety and Licensing Appeal Counsel and Eer
- .ry Board Portland General ciectric Company U.S. Nuclear Regulatory Commission 121 S.W. Salmon Street Washington, DC 20555 Portland, OR 97204 Dr. John H. Buck
- William W. Kinsey Atomic Safety and Licensing Appeal 1002 N. E. Holladay Board Portland, OR 97232 U.S. Nuclear Regulatory Commission Washington, DC 20555 Ms. Nina Bell 728 S. E. 26th Atomic Safety and Licensing Board Portland, OR 97214 Panel
- U.S. Nuclear Regulatory Commission Mr. Stephen M. Willingham Washington, DC 23555 555 N. Tomahawk Drive Portland, Oregon 97217 Atomic Safety and Licensing Appeal Panel (5)*
Mr. Eugene Rosolie U.S. Nuclear Regulatory Commission Coalition for Safe Power Washington, DC 20555 215 SE 9th Avenue Portland, OR 97214 Docketing and Service Section_ (4)*
Office of the Secretary Dr. W. Reed Johnson
- U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, DC 20555 Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 4
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[foseph/ R. Gray
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g/Coungel for NRC Staff 2256 006
05/15/79 L
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMt1ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket No. 50-344 PORTLAND GENERAL ELECTRIC COMPANY, )
(Control Building)
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(Trojan Nuclear Plant)
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NRC STAFF'S SECOND SET OF INTERROGATORIES ON PHASE II TO EUGENE ROSOLIE AND THE C0ALITION FOR SAFE PO'JER The Nuclear Regulatory Commission (NRC) Staff hereby requests that Eugene Rosolie and the Coalition for Safe Power (Intervenor), pursuant to 10 CFR s2.740b, answer separately and fully, in writing under oath or affirmation, the following interrogatories within 14 days after service hereof.
For each response to the interrogatories listed below, identify the person on 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 Rosolie.
The NRC Staff further requests that the Intervenor, pursuant to 10 CFR 52.741, provide copies of, or make available for Staff inspection and copying, any documents referred to by the Intervenor in response to the accompanying interrogatories.
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Interrogatories Related to Scecific Contentions The following interrogatories relate to your conter.tions as modified and admitted by the Licensing Board in its Prehearing Conference Order of April 12,1979. Since the first set of interrogatories filed by the Staff on March 9,1979 covered each contention submitted by you, the numbering of the interrogatories in this second set will begin where the first set of interrogatories ended.
Contention 16 C16-4.
In response to the Staff's interrogatory C16;3 you stated that, in your view, there are r.o plans, apart from shut down, that, as a practical matter, could protect safety-rela +ed equip 5ent during the modifications.
You. indicate that the reasons for your position in this regard are "the numerous errors that have occurred in the past at the Trojan plant and other nuclear power plants."
In this regard, (a) Specifically identify the " numerous errors" at Trojan and other plants to which you refer 1:1 response to Staff interrogatory C16-3.
(b)
Indicate the relationship between the errors identified in (a) and measures taken to protect safety-related equipment frca the effects of construction work.
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(c) State specifically the reasons why, in your view, each of the errors identified in (a) will prevent the formulation and effective implementation of measures to protect safety-related equipment during the modifications at Trojan, Contention 20 C20-4.
In response to Staff interrogatory C20-1, in which you were asked to describe the " existing cracks referred to in conten-tion 20, you stated that " existing cracks are those cracks
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which can be seen in the Control Building watl where the holes are to be drilled and the plate is to be placed." Did you
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actually observe the cracks referred to? If so, indicate the size, depth and approximate location (elevation and location at that elevation) of the cracks which you observed.
Contention 22 s
C22-4.
In response to Staff interrogatory C22-3, you state that the. _. _
basis for your assertion that the effects of the modification on building deflection is underestimated is that the gap between the Control and Turbine Buildings will be reduced by placement of the steel plate between those buildings.
Apart from your concern about the reduction in the gap because of the placement of the steel plate, do you contend that the modifications will adversely affect the actual deflections (i.e., physical move-s
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If so, state specifically how the deflections will
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be aff ected by the modifications and why".
Respectfully submitted, w A k.Jw J ep R. Gray Counsel for NRC Sta f Dated at Cathesda, Maryland thisl5th day of May,1979 e
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