ML19296D475
| ML19296D475 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/28/1980 |
| From: | Gray J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| Shared Package | |
| ML19296D476 | List: |
| References | |
| NUDOCS 8003040659 | |
| Download: ML19296D475 (7) | |
Text
02/28/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket No. 50-344 PORTLAND GENERAL ELECTRIC COMPANY, ET AL. )
(Control Building)
)
(Trojan Nuclear Plant)
)
NRC STAFF'S THIRD SET OF INTERROCATORIES ON PHASE II TO THE COALITION FOR SAFE POWER _
The Nuclear Regulatory Commission (NRC) Staf f hereby requests that Eugene Rosolie, Nina Bell and the Coalition for Safe Power (Intervenor),
pur-suant to 10 CFR 8 2.740b, answer separately and fully, in writing under oath or affirmation, the following interrogatories within 14 days after service hereof.
For each rerponse to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of the response.
The NRC Staff further requests that the Intervenor, pursuant to 10 CFR s 2.741, provide copies of, or make available for Staff inspection and copying, any documents referred to by the Intervenor in response to the accompanying inter-rogatories.
Interrogatories Related to Specific Contentions The following interrogatories relate to contentions of the Coalition for Safe Power (CFSP) as modified and admitted by the Licensing Board in its Prehearing 1/
By Order dated August 27, 1979, Nina Bel.' and the Consolidated Intervenors were consolidated with the other intervenors in this proceeding, Eugene Rosolle and the Coalition for Safe Power. These interrogatories are directed to this single remaining intervening organization, Sereinafter referred to as Intervenor.
Boosogn g
. Conference Order of April 12, 1979. These interrogatories are directed to admitted CFSP contentions as those contentions may be affected by the NRC Staff's Safety Evaluation Report on the Proposed Control Building Modifica-tions (SER), issued on February 14, 1980, and are submitted in accordance with the Licensing Board's Order of December 29, 1979 which requires that all remaining discovery requests be filed by February 28, 1980.
(Tr. 3448).
Since the interrogatories filed by the Staff on March 9, 1979 and May 5, 1979 covered each contention submitted by CFSP, the numbering of the interrogatories in this third set will begin where the first and second sets of interrogatories ended.
CFSP Contention 3 C3-5.
In CFSP Contention 3, it is asserted that Trojan plant staff review of the proposed modifications is inadequate to assure that no viola-tions of Technical Specifications will occur. The plant staff review procedures and requirements are described and evaluated in Section
~
4.14 of the Staff's SER at pp. 58-60.
(a)
In your view, does SER Section 4.14 adequately address and thereby alleviate your concerns expressed in CFSP Contention 3?
(b)
If the answers to C3-5(a) is "yes," are you willing to withdraw CFSP Contention 3 as an issue in this proceeding?
If not, why not?
(c)
If the answer to C3-5(a) is "no":
(1) set forth in detail the bacis for your view that SER Section 4.14 does not adequately addret s and thereby alleviate your concerns expressed in CFSP Contention 3.
If you have no basis, so state.
(ii) identify specifically all inadequacies in SER Section 4.14 with regard to CFSP Contention 3 and all specific concerns raised by CFSP Con-tention 3 which, in your view, have not been addressed by SER Section 4.14.
CFSP Contention 4 C4-4.
In CFSP Contention 4, it is asserted that NRC Staff review of the proposed modifications is inadequate to assure that no violations of Technical Specifications will occur. The NRC Staff's review of Trojan Technical Specifications as they relate to modification work is described and the Staff's evaluation and conclusions in this vein are set forth in Section 4.14 of the Staff's SER at pp. 58-60.
(a)
In your view, does Section 4.14 adequately address and thereby alleviate your concerns expressed in CFSP Con-tention 4?
(b)
If your answer to C4-4(a) is "yes," are you willing to withdraw CFSP Contention 4 as an issue in this proceeding?.
If not, why not?
(c)
If the answer to C4-4(a) is "no":
(i) set forth in detail the basis for your view that SER Section 4.14 does not adequately address and thereby alleviate your concerns expressed in CFSP Contention 4.
If you have no basis, so state.
(ii) identify specifically all inadequacies in SER Section 4.14 with regard to CFSP Contention 4 and all specific concerns raised by CFSP Contention 4 which, in your view, have not been addressed by SER Section 4.14.
CFSP Contention 12, C12-4.
In CFSP Contention 12, it is asserted that the facility cannot be operated safely while modification work is being performed and that there has been no demonstration that operation during the modifica-tion work will not pose a risk to the public health and safety.
The safety of operation during modification work is evaluated and addressed in detail in SER Sections 4.1 (hole drilling), 4.2 (pro-tection of cables from dropped objects), 4.3 (fire protection during modifications), 4.5 (work effects on operator actions), 4.6 (heavy load handling), 4.7 (dust and debris effects), 4.8 (noise and vibration effects), and 4.13 (equipment qualification during work).
Based on these evaluations, the Staff recommends various conditions to assure safety during the modification work, including plant shut down during certain phases of the work (SER Section 6.2.2, pp. 88-90).
In light of the SER analyses and the recommended license conditions for performance of the modifications:
(a)
In your view, do the SER and recommended conditions adequately address and thereby alleviate your concerns expressed in CFSP Contention 127 (b)
If your answer to C12-4(a) is "yes," are you willing to withdraw CFSP Contention 12 as an issue in this proceeding?
If not, why not?
. (c)
If the answer to C12-4(a) is "no":
(i) set forth in detail the basis for your view that the SER analysis and the recommended conditions on modification work do not adequately address and thereby alleviate your concerns expressed in CFSP Contention 12.
If you have no basis, so state.
(ii) identify specifically all inadequacies in the SER analysis and recommended conditions for modifica-tion work and all specific concerns raised by CFSP Conter. tion 12 which, in your view, have not been addressed by the SER and recommended conditions on the modification work.
CFSP Contention 15 and 16 C15/16-1. In CFSP Contentions 15 and 16, it is asserted that all safety-related equipment that could be affected by the proposed modifications has not been identified and that adequate plans to protect such equip-ment durit.g the modification work have not been made.
Safety-related equipment that could be affected by the modification work has been ident*fied and listed in the SER sections referenced in interroga-tcry C12-4, licensee plans for protecting such equipment are discussed in those SER sections, and recommended conditions for protecting equipment are set forth in SER Section 6.2.2.
In light of the SER:
(<)
In your view, do the SER and recommended conditions adequately address and thereby alleviate your concerns expressed in CFSP Contention 15; in CFSP contention 16?
. (b)
If your answer to C15/16-1(a) is "yes," are you willing to withdraw CFSP Contentions 15 and/or 16 as issues in this proceeding? If not, why not?
(c)
If the answer to C15/16-1(a) is "no":
(i) set forth in detail the basis for your view that the SER and the recommended conditions for the pro-tection of equipment do not adequately eddress and thereby alleviate your concerns expressed in CFSP Contention 15 and 16.
If you have ro basis, so state.
(ii) identify specifically all inadequacies in the SER and recommended conditions with regard to CFSP Con-tentions 15 and 16 and all specific concerns raised by CFSP Contentions 15 and 16 which, in your view, have not been addressed by the SER and recommended conditions for protection of equipment.
CFSP Contention 17 C17-5.
In CFSP Contention 17, it is asserted that modification work will pose a risk to safety by hampering the ability of operators to respond to emergencies. Inis matter is addressed in detail in SER Sections 4.3 (pp. 27-29), 4.5 and 4.8.
(a) In your view, does the SER analysis adequately address and thereby alleviate your concerns expressed in CFSP Contention 17?
. (b)
If your answer to C17-5(a) is "yes," are you willing to withdraw CFSP Contention 17 as an it ue in this proceeding? If not, why not?
(c)
If the answer to C17-5(a) is "no":
(1) set forth in detail the basis for your view that the SER does not adequately address and thereby alleviate your concerns expressed in CFSP Conten-tion 17.
If you have nc i asts, so state.
(ii) identify specifically all inadequacies in the SER with regard to CTSP Contention 17 and all specific concerns raised in CFSP Contention 17 which, in your view, have not been addressed by the SER.
Respectfully submitted, ll
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'1 ose R. Gray i Cou sel for h.C St ff Dated at Bethesda, Maryland this 28th day of February, 1980
k UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPANY, ET AL. )
Docket No.
50-344
)
(Control Building)
(Trojan Nuclear Plant)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S THIRD SET OF INTERROGATORIES ON PRASE II TO THE COALITION FOR SAFE POWER" and "NRC STAFF'S RESPONSE TO LICENSEE'S MOTION FOR
SUMMARY
DISPOSITION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commis-sion's internal mail system, this 28th day of February, 1980:
Marshall E. Miller, Esq., Chairman
- Richard M. Sandvik, Esq.
Atomic Safety and Licensing Board Frank W. Ostrander, Jr.
U.S. Nuclear Regulatory Commission Counsel for' Oregon Dept. of Washington, DC 20555 Energy 500 Pacific Building Dr. Kenneth A. McCollom, Dean 520 S.W. Yamhill Division of Engineering, Portland, OR 97204 Architecture & Technology Oklahoma State University Maurice Axelrad, Esq.
Stillwater, OK 74074 Lowenstein, Newman, Reis, Axelrad & Toll Dr. Hugh C. Paxton Suite 1214 1229 41st Street 1025 Connecticut Avenue, N.W.
Los Alamos, NM 87544 Washington, DC 20036 Mr. John A. Kull;1rg Mr. David B. McCoy Route One 348 Hussey Lane Box 250Q Grants Pass, OR 97526 Sauvie Island, OR 97231 William W. Kinsey Mr. Eugene Rosolie 1002 N.E. Holladay Coalition for Safe Power Portland, OR 97232 215 SE 9th Avenue Portlend, OR 97214 Ms. Nina Bell 728 S.E. 26th Ronald W. Johnson, Esq.
Portland, OR 97214 Corporate Attorney Portland General Electric Company 121 S.W. Salmon Street Portland, OR 9720'+
Dr. W.
Reed Johnson
- Atomic Safety and Licensing Board Atomic Safety and Licensing Appeal Panel
- Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Appeal Alan S. Rosenthal, Esq.*
Panel (5)*
Atomic Safety and Licensing Appeal U.S. Nuclear Regulatory Commission Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20535 Docketing and Service Section ( 7)*
Office of the Secretary Dr. John H. Buck
- U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Washington, DC 20555 Board U.S. Nuclear Regulatory Commission Washington, DC 20555 h?h 2u Gray,/
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