ML19276F810
| ML19276F810 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 03/16/1979 |
| From: | Mcgarry J DUKE POWER CO. |
| To: | |
| References | |
| NUDOCS 7904120290 | |
| Download: ML19276F810 (7) | |
Text
N1W PUBLIC DfNNEIU Mf S
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UNITED STATES OF AMERICA q
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NUCLEAR REGULATORY COMMISSION
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In the Matter of
)
DUEE POWER COMPANY
)
)
Docket No. 70-2623 (Amendment to Materials
)
License SNM-1773 for Oconee
)
Nuclear Station Spent Fuel
)
Transportation and Storage
)
at McGuire Nuclear Station)
)
APPLICANT'S INTERROGATORIES TO THE DAVIDSON CHAPTER OF NORTH CAROLINA PUBLIC INTEREST RESEARCH GROUP (PIRG) AND REQUESTS TO PRODUCE Pursuant to the Licensing Board's Order of February 23, 1979 and 10 CFR SS2.740b and 2.741, Applicant serves the following interrogatories and requests to produce on PIRG to be answered under oath or affirmation.
Each answer should include all pertinent knowledge in the possession of all officers, directors, or members of your organization as well as pertinent information possessed by any advisor, agent, employee or counsel.
In answering the interrogatories and in responding to the request to produce, please recite the interrogatories or request preceding each answer.
These interrogatories and this request to produce shall be continuing, and, if atter answering or responding, additional information or documents are obtained which render prior responses incorrect or no longer true, please update the answer and response with such additional information.
The term " document" shall include, without limitation, writings, drawings, graphs, charts, 790412Qs27b
photographs or other data known to or in your possession, custody or control.
In the event any document requested in these interrogatories has been destroyed or is unavailable, describe in detail the reasons therefore.
Your contention reads as follows:
Intervenor contends that the prospect of a traffic accident involving a reactor-waste carrier and involving leakage of some of the contents of said carrier poses an emergency sitation which public safety officials in Charlotte (i.e.,
police chief, fire chief, civil defense head, etc.), are not adequately prepared to handle in regards to protection of the public.
1.
Please set forth your in own words the meaning of this Contention.
2.
What is the supporting basis for this Contention?
Please list all documents relied upon.
3.
Have you undertaken any research and/or conducted any stuales witn regard to this Contention?
If so, please describe the nature of such research and/or studies and provide specific reference to and copies of documents relied upon in such research and/or studies.
4.
Have you contacted any individual and/or group with regard to this Contention?
If so, please identify and indicate the reason for contacting any named in-dividual and/or group response.
5.
With respect to individual and/or groups which you may have contacted with regard to this Contention,
. have they prepared any documents, undertaken any research and/or conducted any studies upon which you will rely?
If so, please describe and provide copies.
6.
Do you plan to participate in the upcoming hearing with regard to this Contention?
If so, please set forth the substance of your participation.
7.
Do you plan to file testimony in the upcoming hearing with regard to this Contention?
If so, who will be the sponsor (i.e.,
witness) of such testimony?
8.
Please identify any witness whom you plan to call at the upcoming hearing with regard to this Contention and provide a summary of his or her educational and professional background.
Also, please set forth any other information bearing upon his or her quali-fications to testify in this proceeding in this regard.
9.
If you plan to call any witness at the upcoming hearing with regard to this Contention, please indicate with specificity the nature of his or her testimony.
In addition, please list and pro-vide copies of documents which any such witness will rely upon with respect to his or her testimony.
Also, please state whether any such witness has undertaken any research, conducted any studies and/
or contacted any individuals and/or groups with reference to his or her testimony.
If so, please
describe and provide copies.
10.
Please identify the types of accidents considered, the basis for each accident, dose from each accident, and the mode by which each accident is initiated.
11.
Please quantify the " prospect" of a traffic accident involving a " reactor-waste carrier" (i.e., what is the probability).
What is the basis for your response?
12.
Please quantify the " prospect" of a traffic accident involving a " reactor-waste carrier and involving leaking of some of the contents of said carrier" (i.e.,
what is the probability).
What is the basis for your response?
13.
Please quantify the amount of " leakage" referred to?
What is the basis for your response?
14.
What will be the impact on the "public" of accidents postulated by you?
Please quantify doses and provide the basis for your response.
15.
What is the basis for your allegation of the inadequacy of the City of Charlotte's emergency response capability?
Please explain in detail, providing any documents and/or studies which you rely upon.
16.
Have you read Table S-4 to 10 CFR S51.20(g)?
I f not, what not, If so, do you agree with the content?
If not, please explain in detail, with supporting basis.
17.
Have you read 49 CFR Parts 170-189?
If not, why not?
If so, do you agree with the content?
If not, please explain in detail, with supporting basis.
17.
Have you read 10 CFR Part 71? If not, why not?
If so, do you agree with the content?
If not, please explain in detail, with supporting basis.
Respectfully submittad, A
3:
- l Michael McGaf ry, 1 31 Of counsel:
William L.
Porter, Esq.
Associate General Counsel Duke Power Company March 16, 1979
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
DUKE POWER COMPANY
)
)
Docket No. 70-2623 (Amendment to Materials
)
License SNM-1773 for Oconee
)
Nuclear Station Spent Fuel
)
Transportation and Storage
)
At McGuire Nuclear Station)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Interrogatories to the Davidson Chapter of North Carolina Public Interest Research Group (PIRG) and Requests to Produce," dated March 16, 1979 in the captioned matter, have been served upon the following by deposit in the United States mail this 16th day of March, 1979.
Marshall I.
Miller, Esq.
Mr. Jesse L.
Riley Chairman, Atomic Safety and President Licensing Board Carolina Environmental Study U.
S.
Nuclear Regulatory Group Commission 854 Henley Place Washington, D.
C.
20555 Charlotte, North Carolina 28207 Dr. Emmeth A. Luebke Atomic Safety and Licensing Edward G.
Ketchen, Esq.
Board Counsel for NRC Regulatory U.
S. Nuclear Regulatory Staff Commission Office of the Executive Legal Washington, D.
C.
20555 Director U.
S. Nuclear Regulatory Dr. Cadet H.
Hand, Jr.
Commission Director Washington, D.
C.
20555 Bodega Marine Laboratory of California William L.
Porter, Esq.
Post Of fice Box 247 Associate General Counsel Bodega Bay, California 94923 Duke Power Company Post Office Box 33189 Charlotte, North Carolina 28242
9 Shelley Blum, Esq.
Richard P.
Wilsc.n 418 Law Building Assistant Attorney General 730 East Trade Street State of South Carolina Charlotte, North Carolina 2600 Bull Street 28202 Columbia, South Carolina 29201 Anthony Z.
Roisman, Esq.
Natural Resources Defense Chairman, Atomic Safety and Council Licensing Board Panel 917 15th Street, N.W.
U.
S. Nuclear Regulatory Washington, D.
C.
20005 Commission Washington, D.
C.
20555 Brenda Best Carolina Action Chairman, Atomic Safety and 1740 E.
Independence Blvd.
Licensing Appeal Board Charlotte, North Carolina U.
S. Nuclear Regulatory 28205 Commission Washington, D.
C.
20555 Chuck Gaddy Chairperson Davidson PIRG Mr. Chase R.
Stephens P.
O.
Box 2501 Docketing and Service Section Davidson College Office of the Secretary Davidson, North Carolina U.
S. Nuclear Regulatory 28036 Commission Washington, D.
C.
20555 Mr. David R.
Belk Safe Energy Alliance 1707 Lombardy Circle Charlotte, North Carolina 28203
~
J.
Michael McGafry, I
.