ML19289F431
| ML19289F431 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/05/1979 |
| From: | Rachel Johnson PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19289F432 | List: |
| References | |
| NUDOCS 7906070360 | |
| Download: ML19289F431 (13) | |
Text
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s UNITED STATES OF AMERICA Ol6 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket 50-344 PORTLAND GENERAL ELECTRIC COMPANY, )
et al
)
(Control Building Proceeding)
)
(Trojan Nuclear Plant)
)
LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENORS NINA BELL AND CONSOLIDATED INTERVENORS Intervenor Nina Bell, pro se, and on beitalf of the Consolidated Intervenors (herein after collecti'.'ely referred to as "Intervenors"), submitted on Feb ruary 26, 1979, 25 contentions for the second phase of this proceeding.
Licensee, pursuant to 10 CFR 2.740 and 2.740b, request that Intervenors answer separately and fully, in writing, under oath or affirmation, each of the interrogatories contained hereit} within 14 dcys after.ervice of this document. This set of interrogat'ories is addressed to a number of the above-referenced contentions in order to ascertain the basis for such contentions, if any, with reasonable spectficity.
For each response, identify the person or persons who prepared or substan-tially contributed to the preparation of the response. Miere an answer is based in whole or in part on the information other than the personal knowledge of the person.v persons answering, disclose the source of that information.
If additional information becomes available with respect to one or more of the responses, af ter the interrogatories have been answered, the responses are to be amended in a timely manner to provide such additional information.
2232 001 79060703Go G
a s
The terms ue4d hereinaf ter defined as follows:
PGE-1020 means the " Report on Design Modifications for the Trojan Control Building", January 1979.
The term " modifications" refers to the modifications described in PGE-1020, and " modification work" refers to the casite activities to perform those modifications.
The term " workers" refers to the onsite construction trades personnel necessary for performance of the modifications.
Interrogatory 1 This intcrrogatory relates to your Contention 2.
(a)
(1) Please indicate wbich cable penetrations will potentially be subjected to fires because of the modification program.
(ii) Please indicati; how the modification work will result in such higber fire potential.
(iii) Plea,e indicate how the fire protection of these cable penetrations is inadequate in light of the alleged increased fire potential.
(iv) Please separately provide the bases for your responses to subparts (1) through (iii).
(b)
(1) Please indicate how the proposed modification work will af f ec t the Plant 's ability to meet the Single Failure Criterion of 10 C7". 50, Appendix A, from a fire protection standpoint.
(ii) Please indicate the manner in which the Plant's abilit7 to mee t that criterion will be inadequate.
2232 002
(iii) Please separately provide the bases for your responses to subparts (1) and (11).
(c) Please indicate the basis for your belief that welding will be required in the cable spreading room.
(d) Access between the Control Building and other structures is considered in Section 5.3.15 of PCE-1020.
(1) Please specifically identify each state =ent in that section with which you disagree.
(ii) Please indicate the scope of the information not provided in that section which you allege is required to =ake the necessary showing.
(iii) Please specify how you believe fire brigade access will be affected by the proposed modifications and modification work.
(iv) Please separately provide the bases for your responses to subparts (1) through (iii).
(e)
(1) Please indicate the specific locations within the Plant where you allege fire could " spread from one division to another".
(ii) Please specify divisions within each location identified in subpart (1) from or to which fire could spread.
(iii) Please specify for those divisions indicated, in response to subpart (ii), how the fire could " spread f rom one division to another".
(iv) Please indicate the particular safe shutdown capability whose redundancy could be "irradicated" by the postulated fire which has " spread from one division to another". 2232 003
(v)
Please specify the specific pieces of equipaent which, if subjected to fire, would lead to such loss in redundancy.
(vi)
Please separately provide the bases for your responses to subparts (i) through (v).
Interrogatorv 2 This interrogatory relates to your Contention 3.
Seismic qualification of safety-related equipment during and af ter modifications is discus in Section 5.2 and Appendir. 8 of PGE-1020.
sed (a)
Please specifically identify each statement in those sections with which you disagree.
(b)
Please indicate the scope of the information not provided in those sections which you allege is required to make the necessary showing.
(c)
Please separately provide the bases for your responses to parts (a) and (b).
_Interrogarorv 3 This interrcgatory relates to your Contention 4.
The effect of the modification work on Plant operations of PGE-1020.
is described in Section 5.3.15 (a)
Please specifically identify each statement in that section with which you disagree.
(b)
Please identify the structures which you believe will be removed.
(c)
Please indicate how the removal of those structures will impair the ability of the Plant to operate safely.
-4 2232 004
w s
e (d) Please indicate how the removal of those structures will impair the ability of the operators to operate the Plant safely.
(e) Please identify the other tasks in the modification program which you believe will Espair the ability of the operators e.o operate the Plant safely.
(f) Please indicate how those other tasks will impair the ability of the Plant to operate safely.
(g) Please separately provide the bases for your responses to parts (a) through (f).
Interrogatorv 4 This interrogatory relates to your Contention 5.
The design, construction, and placement of the 3-inch steel plate and their effect on safe operation during and af ter ins tallation are described in Sections 4.2.3 and 5.3.11 of PGE-1020.
(a) Please specifically identify each statement in those sections with which you disagree.
(b) Please indicate the scope of the information not provided in those sections which you allege is required to make the necessary showing.
(c) Please separately provide the bases for your responses tc parts (a) and (b).
Interrogatorv 5 This interrogatory relates to your Contention 6.
Section 6 of PGE-1020 describes the quality assurance measures to be implemented during the modification work.
2232 005 (a) Please specifi:
~ 7 identify each statement in that section with which yev ugree.
(b)
Please indicate the scope of the information not provided in that section which you allege is required to demonstrate che adequacy of quality assurance measures.
(c) Please identify any inadequacies that you are aware of in the referenced quality assurance programs.
(d)
Please indicate the manner in which the quality assur,nce identified in Section 6 will not be in compliance programs with NRC regulations.
(e)
Please separately provide the bases for your responses to parts (a) through (d).
Interrogatorv 6 This interrogatory relates to your Contention 7.
The modification work program and Licensee's evaluation of the performance of the work are described in Sections 4 and 5.3 of PGE-1020.
(a) Please specifically identify each statement in those sections relating to the integrity of safety-related equipment and cables during the modification work with which you disagree.
(b) Please indicate the scope of the information not provided in those sections which you allege is required to make the necessary showing.
(c) Please identify any inadequacies that you allege exist as to Licensee's ability to perform such a program.
(d)
Please identify any inadequacies that you allege exist as to Licensee's ability to "=aintain the integrity of safety-related equipment and cables". 2232 006
(e)
Please separately provide the bases for your responses to parts (a) through (d).
Interrogatory 7 This interrogatory relates to your Contention 11.
The ef fects of drilling are described in Section 5.3.4 of PGE-1020.
(a) Please specifically identify each statement in that section with which you disagree.
(b)
Please indicate the scope of the information not provided in that section which you allege is required to make the necessary showing.
(c)
Please separately provide the bases for your responses to parts (a) and (b).
Interrogatorv 8 This interrogatory relates to your Contentions 12 and 13.
The effect of the proposed modifications on Plant operations is described in Section 5.3.15 of PGU1020, and safety evaluations of the modification program are described in Section 5 of PGE-1020.
(a)
Please specifically identify each statement in Section 5 con-cerning the safety of operation during the modification work and the protection of health and saf ety with which you disagree.
(b)
Please indicate the scope of the information not provided in that section which you allege is required to make the necessary showing.
(c)
Please separately identify the bases for your responses to parts (a) and (b).
2232 007
Interrogatorv 9 This interrogatory relates to your Contention 14 Section 3.6 of PCE-1020 describes the manner in which the Control Building is being restored to design requirements.
(a) Please specifically identif y each statement in that section with which you disagree.
(b) Please. indicate the scope of the information not provided in that section which you allege is necessary to make the necessary showing.
(c) Please separately provide the bases for your responses to parts (a) and (b).
Interrogatory 10 This interrogatory relates to your Contention 15.
(a) Flease indicate the further assurance you believe necessary that proper quality assuran te and inspection will be implemented.
(b) Is such further assurance required by NRC Regulations?
(c) Please separately provide the bases for your respenses to parts (a) and (b).
Interro..itory 11 This interrogatory relates to your Contentiou 16.
I u Please identify the specific tasks of the modification program during which you allege workers will receive radiological doses exceeding the limits set forth in the NRC regulations.
2232 008
s (b) Please identif y cach respect in which you allege that workers will receive radiological doses exceeding the limits set forth in lIRC regulations.
(c) Please separately provide the bases for your responses to parts (a) and (b).
Interrogatorv 12 This interrogatory relates to your Contention 18.
Supervision over workers during construction and modifications is described in Section 6.3 of PGE-1020.
(a) Please specifically identify each statement in that section concerning supervision of workers with which you disagree.
(b) Please indicate the scope of the information not provided in that.9ection which you allege is required to make the necessary :hoving.
(c) Please specify any inadequacies you are aware of in License:'s program for supervision of workers.
(d) Please separately provide the bases for your responses to parts (a) through (c).
Interrogaterv 13 This :nterrogatory relates to your Contention 20.
The ef f ect of the
=odifi:ations on building deflections is described in Section 3.7 of PCE-1620.
(a) Please specifically identify each statement in that section with which you disagree.
2232 009
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(b) Please indicate the scope of the information not provided in that section which you allege is required to make the necessary showing.
(c) Please separately provide the bases for your responses to parts (a) and (b).
Interrogatorv 14 D is interrogatory relates to your Contencio. 23.
Please provide the basis for your allegation that " bolt placement is arbitrary and does not ensure complete safety".
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Ronald.- Johnson Corpor te Attorney Portland Ceneral Electric Company 2232 010
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PORTLAND GENERAL ELECTRIC COMPANY,
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et al
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(Control Building Proceeding)
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(Trojan Nuclear Flant)
)
e CERTIFICATE OF SERVICE I hereby certify that on March 6,1979:
- 1) Licensee's first set of Interrogatories to Intervenors Nina Bell and Consolidated Intervenors;
- 2) Licensee's first set of Interrogatories to Intervenor Eugene Rosolie and Coalition for Safe Power; and
- 3) Affidavits of Ser" ice of John Beovich on Nina Bell and Eugene Rosolie; have been served upon the persons listed below by depositing copies thereof in the United States mail with proper postage affixed for first class mail, except as noted by asterisk (*) below indicating those persons who received personal service of items (1) and (2) on March 5,1979 as attested to by item (3).
Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Panel U. S. Nuclear Re6alatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555 Dr. Kenneth A. McCullom, Dean Docketing and Service Section (3)
Division of Engineering, Office of the Secretary Architecture and Technology U. S. Nuclear Regulatory Commission Oklahoma 3 tate University Washington, D. C.
20555 Stillwater, Oklahoma 74074 Joseph R. Gray, Esq.
Dr. 'dugh C. Paxton Counsel for NRC Staff 1229 - 41st Street U. S. Nuclear Regulatory Ccemission Los Alamos, New Mexico 87544 Washington, D. C.
20555 Atomic Safety and Licensing Board Lowenstein, Newman, Reis, Axelrad & Toll Panel 1025 Connecticut Ave., N. W.
U. S. Nuclear Regulatory Commission Suite 1214 Washington, D. C.
20555 Washington, D. C.
20036 2232 011
CERTIFICATE OF SERVICE John H. Socolofsky, Esq.
Mr. John A. Kullberg Assistant Attorney General R.sute 1, Box 250Q Of Attorneys for the State of Oregon Sauvie Island, Oregon 97231 100 State Office Eailding Salem, Oregon 97310 Mr. David B. McCoy 348 Hussey Lane Robert M. Jr' son, Esq.
Grants Pass, Oregon 97526 Assistant act _ney General Of Attorneys for the State of Oregon Ms. C. Gail Parson 100 State Office Building P. O. Box 2992 Salem, Oregon 97310 Kodiak, Alaska 99615 William Kinsey, Esq.
- Mr. Eugene Rosolie Bonneville Power Administration Coalition for Safe Power P. O. Box 3621 215 S. E. 9th Avenue Portland, Oregon 97208 Portland, Oregon 97214
- Ms. Nina Bell Mr. Stephen M. Willingham 728 S. E. 26th Avenue 555 N. Tomahawk Drive Portland, Oregon 97214 Portland, Oregon 97217 Columbia Environmental Council Columbia County Courthouse P. O. Box 611 Law Library St. Helens, Oregon 97051 Circuit Court Room St. Helens, Oregon 97051 Ronald W ohnson Corpor Attorney Portland General Electric Company Dated: March 6, 1979 2232 012
CONTINENTAL DETECTIVE SERVICE, INC.
AFFIDAVIT OF SERVICE STATE OF OREGON COUNTY OF mmcm OVICH I
, being first duly sworn, depose and say: That I am and at all times hereinafter was a competent person over the age of twenty-one years of age and not 2 party to or attorney LICENSEE'S FIRST SET OF INTERROGATORIFS was delivered iri che above entitled cause: That the foregoing 'C"Q INTERVENORS, NINA BgLL AND CONSOL STH MAR n i
to me for service on the day of 39 That I smed sa L I
RRCMRIES therein referred to on the below named party at the following time, date and place, to-wit:
Nina Bell 215 S.
E.
9th Avenue Portland, Oregon March 5, 1979 6:50 p.m.
E UCMAH In the County of
, State of Oregon, by then and there personally delivering to INTERRCGATC. JS and leaving with the party just named a copy of said W
%< n Subscp ed and sworn to before me this 5TH day of 79 MARCH
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Notary Public for Oregon
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AFFIDAVIT OF SERVICE 2232 013