ML19294A772
| ML19294A772 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/20/1979 |
| From: | Broehl D, Rachel Johnson, Landrey B PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| References | |
| NUDOCS 7903220116 | |
| Download: ML19294A772 (15) | |
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UNITED STATES OF AMERICA 9
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BEFORE THE ATOMIC SAFETY AND LICENSING BOA.o_n.
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In the Matter of
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Docket 50-344 PORTLAND GENERAL ELECTRIC COMPANY,
)
et al
)
(Control Building Proceeding)
)
(Trojan Nuclear Plant)
)
CERTIFICATE OF SERVICE I hereby certify that on February 20, 1979:
- 1) Licensee's Response to Interrogatories dated January 29, 1979 from Nina Bell of the Consolidated Intervenors; and
- 2) Affidavits of R. W. Johnson, D. J. Broehl, B. T. Landrey, L. W. Erickson, and D. L. Damon 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.
Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555 Dr. Kenneth A. McCollom, Dean Docketing and Service Section (3)
Division of Engineering, Office of the Secretary Architecture and Technology U. S. Nuclear Regulatory Commission Oklahoma S tate University Washington, D. C.
20555 Stillwater, Oklahoma 74074 Joseph R. Gray, Esq.
Dr. Hugh C. Paxton Counsel for NRC Staff 1229 - 41 S treet U. S. Nuclear Regulatory Commission 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 790322o1//,
CERTIFICATE OF SERVICE John H. Socolofsky, Esq.
Mr. John A. Kullberg Assistant Attorney General Route 1, Box 250Q Of Attorneys for the State of Oregon Sauvie Island, Oregon 97231 100 State office Building Salem, Oregon 97310 Mr. David B. McCoy 348 Hussey Lane Robert M. Johnson, Esq.
Grants Pass, Oregon 97526 Assistant Attorney General Of Attorneys for the State of Oregon Ms. C. Cail 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. S tephen M. Willingham 632 S. E.18th Street 555 N. Tomahawk Drive Portland, Oregon 97214 Portland, Oregon 97217 Columbia Environmental Council Columbia County Courthouse P. O. Box 611 Law Library S t. Helens, Oregon 97051 Circuit Court Room St. Helens, Oregon 97051
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Ronald W.
' son Corporate torney Portland General Electric Company Dated:
February 20, 1979
P C U C O '.n_ v. L,f i W O y, g
vg3 g Y,g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 06; 17 3 Ch I
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD T
In the Matter of
)
)
Docket 50-344 PORTLAND GEN 2RAL ELECTRIC COMPANY,
)
et a1
)
(Control Building Proceeding)
)
(Trojan Nuclear Plant)
)
LICENSEE'S RESPONSE TO INTERROGATORIES DATED JANUARY 29, 1979 FROM NINA BELL OF THE CONSOLIDATED INTERVENORS The following are Licensee's Responses dated February 20, 1979 to Inter-rogatories dated January 29, 1978 from Nina Bell of the Consolidated Intervenors. Licensee objects to Interrogatories 1, 4, 5, 6, 9, and 10 on the grounds specifically set forth below.
Persons responding to each interrogatory sre indicated by their initials as follows:
R. W. Johnson (RWJ)
D. J. Broehl (DJB)
B. T. Landrey (BTL)
L. W. Erickson (LWE)
D. L. Damon (DLD)
Interrogatory 1
" Provide cost estimates for all pending construction and contracts with Bechtel Power Corporation for both full and partial ownership."
Response to Interrogatory 1 The Licensee objects to Interrogatory 1.
The Response to Interrogatory 2 (below) provides cos t estimates concerning the preposed control Building modification program described in PGE-1020.
To the extent that Interroga-tory 1 seeks cost ectimates for FGE/Bechtel " construction and contracts" other than the proposed Control Building modification program, however, such request is beyond the scope of the evidentiary hearing as set forth in the Commission's Order for Modi.fication of License of May 26, 1978 and in the Licensing Board's Notice of Evidentiary Hearing of August 1, 1978.
Thus the information requested by Interrogatory 1 is not relevant to the subject matter of this proceeding, nor is it reasonably calculated to lead to the discovery of admissible evidence as required by 10 CFR 32.740 (b)(1).
(RWJ)
Interrogatory 2
" Provide detailed cost analysis for Control Building modifications."
Response to Interrogatory 2 No " detailed cost analysis" has been performed for the Control Building modifications.
Present estimates of overall costs for field work, investigations, analyses, engineering, testing and licensing (from the time the design deficiency was identified in April 1978 until completion of field work for the proposed modifications), including such costs to support interim operation, are as follows:
Cost of field work (performed by Bechtel) $2-3 million; Engineering, testing and licensing support (performed by Bechtel) $5 million; and Technical engineering, licensing and construction support (performed by PGE) $2.5 million.
(DLD, DJB)
Interrogatory 3
" Provide all press releases and statements made by PGE regarding the Control Building proceedings and the modifications to be done."
Response to Interrogatory 3 Licensee notes that Interrogatory 3 is a request for production of documents, which should properly be made under 52.741. Nevertheless, press releases and statements prepared by PGE regarding the Control Building proceeding and modifications to be done are provided to Ms. Bell as Attachment 1.
Material in Attachment 1 is available to all parties as Document File 27 in the Trojan Control Building Document Room at PCE's headquarters in Portland.
This attachment does not include transcripts of press conferences or interviews as these are not normally prepared by PGE.
(LWE, BTL)
Interrogatory 4
" Provide documentation for environmental qualification of saf ety related equipment."
Response to Interrogatory 4 The Licensee objects to Interrogatory 4.
The scope of this proceeding is limited to the seismic capability of the Control Building Complex, the seismic qualification of equipment therein, and the adequacy of proposed modifications to the Control Building. Accordingly the response to Interrogatory 8 (below) provides information concerning seismic qualification of equipment in the modified Control Building Complex.
Interrogatory 4, on the other hand, is not only unduly broad (since it appears to extend to equipment outside of the Control Building Complex) but in requesting information pertaining to environmental qualification is beyond the scope of the evidentiary hearing as set forth in the Commission's May 26, 1978 Order for Modification of License and in the Response to Interrogatory 4 (concl.)
Licensing Board's Notice of Evidentiary Hearing of August 1, 1978.
Thus the information requested by Interrogatory 4 is not relevant to the subject matter of this proceeding, nor is it reasonably calcu-lated to lead to the discovery of admissible evidence as required by 10 CFR 52.740(b)(1).
(RWJ)
Interrogatory 5
" Provide contract between PGE and Burlington Northern Railroad."
Response to Interrogatory 5 The Licensee objects to Interrogatory 5.
Interrogatory 5 requests a document be made available, thus it should be the subject of a raquest for production of documents under 52.741.
Even if the request were properly made, however, Licensee would object on the grounds of undue breadth and relevance.
The railroad track within the Control Buil' ding which will be rerouted under the modification program described in PGE-1020 is owned by the Licensee and is not the subject of any contract with the Burlington Northern Railroad. Contracts or arrangement.s between Licensee and Burlington Northern Railroad concerning the railroad line which passes through a portion of the site of the Trojan plant do not relate to the modification program, and are beyond the scope of the evidentiary hearing as set forth in the Commission's May 26, 1978 Order for Modification of License and in the Licensing Board's Notice of Evidentiary Hearing of August 1, 1978. Thus the information requested by Interrogatory 5 is not relevant to the subject matter of this proceeding, nor is it reasonably calculated to lead to the discovery of admissible evidence as required by 10 CFR 52.740(b)(1).
(RWJ)
Interrogatory 6
" Portland General Electric's analysis of the implications of Single Failure Criterion as it applies to Fire Protection.
Single Failure is defined in 10 CFR Part 50, App. A."
Response to Interrogatory 6 Licensee objects to Interrogatory 6.
The scope of this proceeding is limited to the seismic capability of the Control Building Complex, the seismic qualification of the equipment therein, and the adequacy of proposed modifications to the Control Building.
Since Interrogatory 6 does not relate to any seismic aspect of the Complex or its equipment, but is addressed to the general subject of Fire Protection, it is beyond the scope of the evidentiary hearing as set forth in the Commission's May 26, 1978 Order for Modification of License and in the Licensing Board's Notice of Evidentiary Hearing of August 1, 1978.
Thus, the information requested 'oy Interrogatory 6 is not relevant to the subject matter of this proceeding, nor is it reasonably calculated to lead to the discovery of admissible evidence as requested by 10 CFR 82.740(b)(1).
(RWJ)
Interrogatory 7
" Provide the PGE Nuclear Plant Qulaity [ sic] Assurance Program for Operation, Rev.
4."
Response to Interrogatory 7 PGE's Nuclear Projects Quality Assurance Program for Operations (NPQAP/0),
Revision 4, was provided with Amendment 33 to the Trojan Final Saf ety Analysis Report (FSAR) which is available in the Trojan Control Building Document Room at PGE's headquarters in Portland.
An additional copy of the NPQAP/0 has been placed in the Document Room as Document File 26.
As requested by this Interrogatory a copy of the NPQAP/0, Revision 4, is provided as Attachment 2 only for Ms. Bell. As indicated above, two copies of this document are available to all parties in PGE's Control Building Document Room.
(LWE)
Interrogatory 8
" Explain how and when reviews will be made to confirm the selmic quiai-fication [ sic] of safety related equipment following the modifications to the Control Building."
Response to Interrogatory 8 Appendix B of the " Report on Design Modification for the Trojan Control Building" (PGE-1020) served on all parties on January 17, 1979, addresses the methodology as to how the seismic capability of safety-related equipment will be confirmed for the spectra resulting from the modifi-cations to the Control Building. These analyses are presently in progress and will be completed prior to structural modification of the Control Building.
(DLD)
Interrogatory 9
" Provide detailed budget for manpower costs of Control Building proceeding."
Response to Interrogatory 9 Licensee objects to Interrogatory 9.
The Interrogatory appears to request information concerning Licensee's budget for the conduct of the proceeding. Such information is not relevant to the subject matter of this proceeding, nor is it reasonably calculated to lead to admissible e '.uence as required by 10 CFR 2.740(b)(1).
(RWJ) 8 Interrogatory 10
" Provide information that demonstrates that the flow deliveries and actuation times of ECCS compnents [ sic] meet or exceed values assumed in the ECCS analyses."
Response to Interrogatory 10 Liceraee objects to Interrogatory 10.
The scope of this proceeding is limited to the seismic capability of the Control Building Complex, seismic qualification of the equipment therein, and adequacy of proposed modification to the Control Building.
Since Interrogatory 10 does not relate to any seismic aspect of the Complex or its equipment, but is addressed to the general subject of the functioning of ECCS componencs, it is beyond the scope of the evidentiary hearing as set forth in.'ie Commission's May 26, 1978 Order for Modification of License and in the Licensing Board's Notice of Evidentiary Hearing of August 1, 1978.
Thus the information requested by Interrogatory 10 is not relevant to the sub-iect matter of this proceeding, nor is it reasonably calculated to lead to the discovery of admissible evidence as required by 10 CFR 5 2.740(b)(1).
(RWJ)
Response to Nina Bell Interrogatory 3 Dated January 29, 1979 Attachment #1 PRESS RELEASES AND STATEMENTS MADE BY FGE REGARDING THE CONTROL BUILDIN'; PROCEEDINGS AND THE MODIFICATIONS TO BE DONE
( Available in the Control Building Document Room at PGE'S headquarters in Portland, Oregon, and thus is not provided to parties other than Ms. Bell, except as requested as copies from the Document Room.)
Response to Nina Bell Interrogatory 7 Dated January 29, 1979 Attachment #2 PORTLAND GENERAL ELECTRIC COMPANY'S NUCLEAR PROJECTS QUALITY ASSURANCE PROGRAM FOR OPERATIONS (NPQAP/0), REVISION 4 (Available in the Final Safety Analysis Report, Section 17 and also as a separate file in the Control Building Document Room at PGE's headquarters in Portland, Oregon, and thus is not provided to parties other than Ms. Bell except as requested as copies from the Document Room.)
UNITED STATES OF AMERICA 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)
)
STATE OF OREGON
)) ss County of Multnomah )
AFFIDAVIT OF RONALD W. JOHNSON Ronald W. Johnson, being duly sworn according to law, deposes and says that he is a Corporate Attorney, Portland General Electric Company, and that the answers associated with his name and contained in the Licensee's Responses dated February 20, 1979 to Interrogatories of Nina Bell of Consolidated Intervenors dated January 29, 1979 are true and correct to the best of his knowledge and belief.
l
~
r Ronald W < Johnson Subscribed and sworn to before me this g day of February 1979.
d.-1. d e k 4 /nu Notary Public of Or4gon My Commission Expires of#f-[/[/9
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket 50-344 PORTLAND GENERAL Ell'.CTRIC COMPANY,
)
et al
)
(Control Building Proceeding)
)
(Trojan Nuclear Plant)
)
STATE OF OREGON
)) ss County of Multnomah )
AFFIDAVIT OF D. J. BROEHL D. J. Broehl, being duly sworn according to law, deposes and says that he is Assistant Vice President, Generation Engineering-Construction, Portland General Electric Company, and that the answers associa.ed with his name and contained in the Licensee's Responses dated February 20, 1979 to Interrogatories of Nina Bell of Consolidated Intervenors dated January 29, 1979 are true and correct to the best of his knowledge and belief.
[-
/ V / 'D. J. Broehl Subscribed and sworn to before me this,-fg $ day of February 1979.
f i _,_/. k ubL Notary Public of Oret,on My Commission Expires
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UNITED STATES OF AMERICA 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)
)
STATE OF OREGON
)) ss County of Multnomah )
AFFIDAVIT OF BRZ".E T. LANDREY Bruce T. Landrey, being duly sworn according to law, deposes and says that he is a Public Information Representative, Portland General Electric Company, and that the answers associated with his name and contained in the Licensee's Responses dated February 20, 1979 to Interrogatories of Nina Bell of Consolidated Intervenors dated January 29, 1979 are true and correct to the best of his knowledge and belief.
M BTdce T. Landrey g m
Subscribed and sworn to before me this cJE1b day of February 1979.
LN Notary Public of Qfegon My Comnission Expires
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/
UNITED STATES OF AMERICA 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)
)
STATE OF OREGON
)) ss County of Multnomah )
AFFIDAVIT OF LIEF W. ERICKSON Lief W. Erickson, being duly sworn according to law, deposes and says that he is a Trojan Licensing Supervisor, Generation Licensing & Analysis Department, Portland General Electric Company, and that the answers associated with his name and contained in the Licensee's Responses dated February 20, 1979 to Interrogatories of Nina Bell of Consolidated Inter-venors dated January 29, 1979 are true and correct to the best of his knowledge and belief.
s m
( Lief W. Erickson Subscribed and sworn to before me this jd 6 day of February 1979.
A t e /, h b>t -
Notary Public of pregon My Commission Expires u
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/
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket 50-344 PORTLAND GENERAL ELECTRIC COMPANY,
)
et a1
)
(Control Building Proceeding)
)
(Trojan Nuclear Plant)
)
STATE OF OREGON
)
)
ss County of Multnomah )
AFFIDAVIT OF D. L. DAMON D. L. Damon, being duly sworn according to law, deposes and says that he is a Project Engineer, Bechtel Power Corporation, and that the answers associated with his name and contained in the Licensee's Responses to dated February 20, 1979 to Interrogatories of Nina Bell of Consolidated Inter-venors dated January 29, 1979 are true and correct to the best of his knowledge and belief.
(h
} hf?vb D. L. Danon Subscribed and sworn to before me this,7699 day of February 1979.
Lvi k, 9 cbn Notary Public of Ore %on My Commission Expires dJwd 8//
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