ML19291C500

Answers to Licensee First Set of Interrogatories.Alleges That Inability to Operate Certain Equipment Automatically Contributed to TMI-2 Accident.Objects to Remaining Questions

ML19291C500
Person / Time
Site:	Rancho Seco
Issue date:	01/07/1980
From:	Hursh G CASTRO, R. & HURSH, G.
To:	SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8001240506
Download: ML19291C500 (3)

Text

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y UNITED STATES OF AMERICA hA Y

NUCLEAR REGULATORY COMMISSION v,

f BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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SA met MUNICIPAL UTILITY Docket No. 50-312 (Rancho Seco Nuclear Generating Station)

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ANSWERS OF GARY HURSH AND RICHARD CASTRO TO THE FIRST SET OF LICENSEE'S INTERROGATORIES GARY HURSH and RICHARD CASTRO offer the following responses to the First Set of Interrogatories from Licensee.

Interrogatory No.

1.

These answering Intervenors offer the same response as previously stated in Answers dated December 5, 1979 Interrogatory No.

2.

Objection, not an interrogatory.

Without waiving our objection, if Licensee is asking who has knowledge which served as the basis for the answer to each interrogatory, it is Intervenor Gary Hursh.

Interrogatories 3 through 9.

Interrogatory 3 through 9 and each of the are objected to as requesting information whh.c'h.is nlotithe responsibility or obligation of these Petitioners to provide.

Petitioners have stated the areas of concern, the Board has defined the scope of the hearing, it is now incumbent on the Licensee and the NRC staff to demonstrate convincingly that each 1793 174-o1340 s o6 g.

and every contention is without merit, and that Rancho Seco can operate safely.

Interrogatory No. 3 Without waiving our objection as previously stated, we don't know.

But, there certainly is a question as to the adequacy of the modification.

Interrogatory No 4.

See answer to Interrogatory No. 3 Interrogatory No. 5 See answer to Interrogatory No. 3 Interrogatory No. 6.

Without waiving our objection as previously stated, we don't know.

However, it is common knowledge that during the accident at TMI-2, a contributing factor was the inability I

to operate certain equipment automatically instead tf manually.

Interrogatory No. 7 A.

Do not know yet.

B.

Not Applicable.

C.

Objection, not an interrogatory.

Interrogatory No. 8.

Without waiving our objection as previously stated, we don't know.

But, there certainly is a question as to the adequacy of the testing and training.

Interrogatory No. 9.

Without waiving our objection as previously stated, we don't know.

I am an Intervenor in the above-entitled matter; I have read the foregoing Answers and know the contents thereof;

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and I certify that the answers are true and correct.

Executed on January 7, 1980, at sacramento, California.

I declare under penalty of perjury that the foregoing is true and correct.

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