ML19289F435
| ML19289F435 | |
| 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 7906070362 | |
| Download: ML19289F435 (10) | |
Text
UNITED
'ATES OF AMERICA NUCLEAR LGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 30ARD In the Matter of
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Docket 50-344 PORTLAND GENERAL ELECTRIC COMPANY,
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et al
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(Control Building Proceeding)
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(Trojan Nuclear Plant)
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LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR E"cENE ROSOLIE AND CvALITION FOR SAFE POWER Intervenor Eugene Rosolie, pro 3 and on behalf of the Coalition for Saf e Power (hereinaf ter referred to as "Intervenor") submitted on Febniary 26, 1978, 26 contentions for the second phase of this pro-ceeding. Licensee, pursuant to 10 CFR 2.740 and 2.740b, requests that Intervenor answer separately and fully in writing, under oath or af firmation, each of the interrogatories contained herein within 14 days af ter service of this document. This set of interrogatories is addressed to a number of the above-ref erenced contentions in order to ascertain the bases for such contentions, if any, with reasonabli specificity.
For each response, identify the person or persons who prepared or sub-stantially contributed to the preparation of the response. Where an answer is based in whole or in part on information other than the personal knowledge of the person or persons answering, disclose the source of that inf o rma t ion.
If additional information becomes available with respect to one or more of the responses after the interrogatories have been answered, the
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responses are to be a:r
' d in a timely manner to provide such additional i
information.
2232 014 7 9 0 6 0 7 0 'R
The terms used hereinaf ter are defined as follows:
PCE-1020, means the " Report on Design Modifications for the Trojan Control building", January 1979.
The term, " modifications", ref ers to the modifications described in PGE-1020, and " modification work" refers to t.he onsite activities to perform those modifications.
The term, " workers", ref ers to the ons ue construction trades personnel necessary for performance of the modifications.
Interrogatorv 1 This interrogatory relates to your Contention 3.
(a) In what way do you allege that Plant Staf f review of the modifi-cations is inadequate?
(b) What Technical Specifications dc you expect will be violated by the modifications?
(c) Please state separately the bases for your responses to parts (a) atd (b).
Interrogatorv 2 Th is interrogatory relates to your Contentions 7 and 8.
(a) Please identify the causative agents you allege could lead to health effects on workers.
(b) Please identify each respect in which you expect that workers will be exposed to radiation in excess of limits specified in the NIi's regulations.
2232 015 (c) Please state separately tne bases for your respon<es to parts (a) and (b).
Interrogatory 3 This interrogatory relates to your Contentioc 9.
(a) k' hat accidents at Trojan do you allege would lead to releases of radiation equal to or exceeding the limits of 10 CFR 100?
(b) klich of :ae aes ' dents in your response to part (a) do you allege will have an increased risk of occurrence if operation is allcwed during the modification work?
(c) For each accident listed in response to part (b), how will the modification program increase that risk?
(d) Please state separately the bases for your responses to parts (a) through (c).
Interrogatorv 4 This interrogatory relates to your Contention 10.
PCE-1020, Section 6, indicates the quality assurance programs applicable to the modifications.
(a) Please specify in what manner you allege that the described quality assurance programs are it. adequate to assure (1) proper material purchase and (2) aroper ccmpletion of modifications.
(b) Please provide the basis for your response to part (a).
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,1 s
Interrogatorv 5 This interrogatory relates to your Contentions 12 and 13.
PGE-1020, Section 5.3, provides an evaluation of Plant operation and the modification work.
(a) Please specifically identify each statement in thet section related to operation of the Plant during the modification work 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 specify in what way you allege that operation of the Plant during modification work results in undue risk to the public's health and safety.
(d)
Please state separately the bases for your responses to parts (a) through (c).
Interrogatorv 6 Th is interrogatory relates to your Contention 14.
PGE-1020, Section 5.3, provides an evaluation of the effects of the modifica-tions and modification work on safety-related equipment.
(a) Please specifically identify each statement in tha-section related to effects of modification work on saf ety-related equipment with which you disagree.
(b) Please indicate the scope of the information not pro-vided in that section which you allege is ' required to make the necessary showing.
22 (c) Please specify any inadequacies 3,u are aware of in the Licensee's assessment of affects of the modifications on safety-related equipment.
(d) Please state separately the bases for your responses-to parts ia) through (c).
Interrogatorv 7 This interrogatory relates to your Contentions 15 and 16.
PCE-1020, Sections 5.3.3, 5.3.4, 5.3.6, 5.3.9, and 5.3.11, ident if y saf e ty-related equipment af fected by the modifications and the protection provided therefor.
(a) Please specifically identify each statement in those sections related to protection of safety-related eg'2ipment with which you disagree.
(b) Please indicate the scope of the information not pro-vided in those sections which you allege is required to make the necessary showing.
(c) Please state separately the bases for your responses to parts (a) and (b).
Interrogatory 8 This interrogatory relates to your Contention 17.
PGE-1020, Section 5.3.15, evaluates the ef fect of the modification work on Plant ope ra t ions.
(a) Please specifically identify each statement in that section with which you disagree.
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(b) Please indicate the scope of the information not pro-vided in that section which you allege is required to make the necessary showing.
(c) What emergencies do you allege would pose an undue risk to the public health and safety?
(d) Please specify how the modifications will hamper the Plant operators in their response to the emergencies listed in response to part (c), above.
(e) Please state separately the bases for your re conses to parts (a) through (d).
Interrogatory 9 This interrogatory relates to your Contention 19.
Section 5.2 of and Appendix B to PGE-1020 indicate the metnods of evaluating the seismic qualification of safety-related equipment in emsideration of the modifications.
(a) Please specifically identify each statement in those sections related to methods of seismic qualification of saf ety-related equipment with which you disagree.
(b) Please indicate the scope of the information not pro-vi ed in those sections which you allege is required to make the necessary showing.
(c) Do you allege that the methods of seismic qualification of equipment described in PGE-1020 are dif f erent from the methods of seismic qualification of equipment which were found to be adequate for interim operation.by the Licensing Board?
(d) If the answer to part (c) is yes, please specif y the differences you believe exist. 2232 019
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(e) Do you allege that different methods of seismic qualifica-tion of equipment should be required for the qualification work described in PGE-1020?
(f) If the answer to part (e) is yes, what about the modifica-tion pro,; ram requires that dif ferent methods be used?
(g) Please state separately the bases for your responses to parts (a) through (f).
Interrogatory 10 This interrogatory relates to your Contention 20.
PGE-1020, Sec-tion 5.3.4, evaluates the effects of drilling holes in existing walls.
(a) Please specifically identify each statement in that section with which you disagree.
(b) Please indicate the scope of the infor=ation not pro-vided in that section which you allege is required to make the necessary showing.
(c) Please identify the postuisted effects drilling could have en existing cracks in Control Building walls.
(d) Please state separately the bases for your responses to parts (a) through (c).
Interrogatory 11 This interrogatory relates to your Contention 21.
PGE-1020, Sec-tions 4.2.5 and 5.3.6, discuss provisions for supply of combustion air to the E=ergency Diesel Generators.
2232 020 (a) Please specifically identify each statement in those sections related to the combustion air supply for the E=ergency Diesel Generators with which you disagree.
(b) Please indicate the scope of the information not pro-vided in those sections which you allege is required to make the necessary showing.
(c) Please specify how installation of the new air supply louvers will affect the ability of either Emergency Diesel Generator to perform its intended function.
(d) Assuming that installation of the new air supply louvers does not af f ect the ability of either Emergency Diesel Generator to operate, please specify in what manner the Plant canno t be operated safely during that installation.
(e) Please state separately the bases for your responses to parts (a) through (d).
Interrogatory 12 This interrogatory relates to your Contention 22.
PGE-1020, Sec-tion 3.7, discusses the effects of the modifications on building deflections.
(a) Please specifically identify each statement in that section with which you disagree.
(b) Please indicate the scope of the information not pro-vided in that section which you allege is required to make the necessary showing.
(c) Please specify how the proposed modifications will af fect deflections between buildings.
2232 021 (d) Please state separately the bases for your responses to parts (a) through (c).
t 2232 022 p
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f RonaldW[ Johnson Corporate Attorney Portland General Electric Company
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CONTINENTAL DETECTIVE SERVICE, INC.
AFFIDAVIT OF SERVICE STATE OF OREGON mucMAH COUNTY OF HN E m I
, being first duly sworn, depose and say: That I am and at all times hereinafter was a competent person over the age of tweng-one years of age and not a party to or attorney LICENSEE'S FIRS? SET CF INTERRCGATCRIES in the above entitled cause: That the foregoing TO INTERVENCR, EUGENE RCSOLIE AND CCALI5$ gb gl 3AFE e
to me for service on the STH MARCH 19 79 That I served saiA ZFCWER d27 of INTERROGATCRIES therein referred to en the below named party at the following time, date and place, to-wit:
Eugene Rosolie 215 S. E.
9th Avenue Portland, Oregon March 5, 1979 6:50 p.m.
MULTNCMAH In the County of
, State of Oregon, by then and there personally delivenng to I M RROGATORIES 2nd leaving with the party just named a copy of said I
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Subscr:6ed and sworn to before me this "U day of MARCH 79
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Notary Public for Oregon My Comnussion Expires
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J AFFIDAVIT OF SERVICE 2232 023