ML19269D676
| ML19269D676 | |
| 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 7906110210 | |
| Download: ML19269D676 (3) | |
Text
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05 /15/P 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'S SECOND SET OF INTERROGATORIES ON PHASE II TO CONSOLIDATED INTERVENORS The Nuclear Regulatory Commission (NRC) Staff hereby requests that Conso-lidated Intervenors, pursuant to 10 CFR 62.740b, answer separately and fully, in writing under oath or affirmation, the fo.llowing interrogatories within 14 days after service hereof.
For each response to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of the response.
The NRC Stgff further requests that the Intervenor, pursuant to 10 CFR 62.741, provide copies of, or make available for Staff inspection and copying, any documents referred to by the Intervenor in response to the accompanying interrogatories.
Interrocatories Related to Scecific Contentions The following interrogatories relate to contentions as modified and admitted by the Licensing B)ard in its Prehearing Conference Order of April 12, 1979 and to Consolidat'.
- ervenors' contention I which, though not admitted 2256 011 79061102/c7
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as an issue in the Phase II proceeding, is to be considered by the Staff in the security evaluation the Staff is to conduct.' Since the first set of interrogatories filed by the Staff on March 9,1979 covered each con-tention submitted by Consolidated Intervenors, the numbering of the intpe-
' tories in this second set will begin where the first set of interrogatories ended.
' Contention 1 Cl-19.
In contention 1(b), you assert that the Licensee has not sub-mitted sufficient information to determine whether security at Trojan during the modifications will be maintained with regard to physical security measures to accommodate additional workers for both the general plant and the modification areas.
Do you believe that it is possible that additional physical security measures will be needed to accommodate the addi-tional workers required to perform the modifications? If so, yhy?
Cl-20.
In contention 1 you state that your concerns with regard to security and the effects of the modifications thereon. relate to four listed matters (contentions 1(a) to (d)) but are not limited to those matters.
State specifically and in detail:
(a) any additional concerns you have with regard to security in relation to the modifications.
(b) the bases for those concerns.
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Contantion 4 C4-4.
In contention 4, you refer to the " extensive removal of struc-
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tures" pursuant to the modifications.
In the Staff's interrog-atory C4-1 of March 9,1979, you were asked to identify the structures referred to in the above phrase and you responded "All referred to in PGE-1020".
Indicate specifically by section and page numbers those parts of PGE-1020 in which the structures referred to in Contention 4 are identified.
Contention 11 Cll-4.
In response to the Staff's interrogatory Cll-2(a), you indicated that the " effects of drilling" to which ye" refer in contention 11 are, among other things," exascerbating the existing deformities and cracks".
(a) Are you personally aware of any " existing deformities and cracks" in the walls which will be drilled pursuant to the modification work.
(b)
If the answer to (a) is "yes", describe these existing i
deformities and cracks (i.e. size and nature), indicate where each is located (i.e. identify wall, elevation ~ -
and approximate location at a particular elevation), and state the manner in which you became aware of the existence of these deformities and cracks.
(c)
If the answer to (a) is "no", state the basis for your assertion in response to Staff interrogatory C11-2(a) that deformities and cracks exist.
Respectfully submitted, I
h.e.~s% E?]s/
u o eph R. Gray e !::
. i. a c.
..,o c a '. _
this 15tn day of May,1979
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