ML19320D744
| ML19320D744 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 07/15/1980 |
| From: | Rooney M, Szwajkowski R GENERAL ELECTRIC CO., MAYER, BROWN & PLATT |
| To: | Rorem AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8007220147 | |
| Download: ML19320D744 (6) | |
Text
Dated:
July 15, 1987
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Dockedng & Sm!ce In the Matter of
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Branch
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GENERAL ELECTRIC COMPANY
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Docket No. 70-1308 od \\
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(Renewal of SNM-1265)
(GE Morris Operation Spent
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Fuel Storage Facility)
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GENERAL ELECTRIC'S INTERROGATORIES PROPOUNDED TO THE INTERVENOR, ROREM, et al.
General Electric propounds the following interrogatories to ROREM, et al. in accordance with the provisions of 10 C.F.R.
S 2.740b.
1.
For each witness whom you will or may call as an expert to give opinion testimony in the hearing of this matter, state the following:
a.
Name and address; b.
Name and address of his employer of the organization with which he is associated in any professiona] capacity; c.
The field in which he is to be offered as an expert; d.
A summary of his qualifications within the field in which he is expected to testify; e.
The substance of the facts to which he is expected to testify; f.
The substance of the opinions to which he Sects 2 o /g7
is expected to testify and a summary of the grounds for each opinion; and g.
State the dates and addressees of all reports rendered by such experts.
2.
For each person retained or specifically employed as an expert with regard to this license renewal application or hearing, about whom no decision has been made as to whether such expert will be called, state the following:
a.
Name and address; b.
His particular field of expertise; c.
A summary of his qualifications within the field; and d.
Whether such expert has submitted or trans-mitted any reports analyses or opinions in any form.
If so, state the dates and addressees of all reports, analyses or opinions.
3.
Define the phrase " risks and consequences", including sufficient detail for translation of the meaning of the phrase into engineering specifications, as used in subparagraph (b) of Contention 1.
4.
With reference to Contention 1(b), state with particularity the manner in which the following accidents are postulated to occur at the Morris Operation, describing in technical detail the postulated consequences thereor, including the anticipated magnitude of the alleged release of radioacH ve elements, and state the facts upon which such postulations are based:
1
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a.
An accident caused by a tornado-impelled missile; b.
An accident involving the loss of coolant, either alone or in conjunction with an accident causing a rift in the building structure; c.
Accidents involving earthquakes; d.
Sabotage-related accidents not analyzed in NEDM-20682; e.
Fire; f.
Flooding; g.
Acts of war; h.
Human error; and i.
Massive electrical power failure.
5.
State with particularity the manner in which the CSAR does not adequately describe the " risks and consequences" of the accidents and occurrences listed as subparts (i) through (ix) inclusive of Contention 1(b).
6.
State with particularity the manner in which the Physical Security Plan does not meet the requirements of 10 C.F.R. Part 73, as alleged in Contention 2.
7.
Define the phrase " risks of sabotage related events" used in Contention 2 and specifically state the facts upon which the contention that such events are a threat are based.
8.
State with particularity the manner in which the CSAR does not adequately assess " risks and consequences of sabotage related events" as alleged in Contention 2. L.
9.
With reference to Contention 2, state the facts upon which the contention that " advances in the technology of explosives.
. could make sabotage a more probable event" is based and describe the impact of such alleged developments on the alleged risk of sabotage at the Morris Operation.
10.
With reference to Contention 2, state the regulatory basis, including the specific statute or regulation relied upon, which requires the CSAR to include an assessment of
" credible risks of sabotage related events."
11.
Describe in technical detail any accident contem-plated by Contention 6 which is postulated to require:
a.
The evacuation of large numbers of people in the Joliet and/or Kankakee areas and/or b.
The hospitalization of large numbers of people within a 50-100 mile range of the facility.
12.
Define the term "meaaures" used in subparagraph (c) of Contention 6.
13.
With reference to Contention 6, state the regulatory basis, including the specific regulation or statute relied upon, which require that:
a.
A comprehensive evacuation plan for the area should exist; b.
Hospitals within a 50-100 mile range should be equipped to handle large numbers of people exposed to radiation; c.
General Electric take responsibility for informing residents of a possible accident at the Morris Operation; and d.
General Electric take financial responsi-bility for forming an evacuation plan, equipping hospitals, training personnel, and maintaining equipment described in this contention.
With regards to the Contentions admitted by the Board in this matter, these Interrogatories are continuing Interroga-tories and require supplemental answers if the State of Illinois obtains further information between the time the Answers are served and the time of an initial decision in the matter.
Respectfully submitted, GENERAL ELECTRIC COMPANY
%'./
WA Ronald W.
Szwajkowski
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Matthew A.
Rooney OF COUNSEL:
MAYER, BROWN & PLATT 231 South LaSalle Street Chicago, Illinois 60604 (312) 782-0600 i
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75808 @ 7 9
Bmoch In the Matter of
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k GENERAL ELECTRIC COMPANY
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Docket No. 70-1308 Consideration of Renewal of
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Materials License No. SNW-1265)
Issued to GE Morris Operation )
Fuel Storage Installation
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CERTIFICATE OF SERVICE F
The undersigned hereby certifies that he served a copy of GENERAL ELECTRIC'S INTERROGATORIES PROPOUNDED TO THE INTERVENOR, ROREM ET AL.,
in the above-captioned proceeding on the following persons by causing the said copies to be deposited in the United States mail at 231 South
'aSalle Street, Chicago, Illinois, in plainly addressed and sealed envelopes with proper first class postage attached before 5:00 P.M.
on July 15, 1980:
Andrew C. Goodhope, Esq., Chairman Susan N.
Sekuler, Esq.
Atomic Safety and Licensing Board George William Wolff, Esq.
3320 Estelle Terrace Office of the Attorney General Wheaton, Maryland 20906 188 West Randolph Street Suite 2315 Dr. Linda W.
Little Chicago, Illinois 60601 Atomic Safety and Licensing Board 5000 Hermitage Drive Marjorie Ulman Rothschild, Esq.
Raleigh, North Carolina 27612 United States Nuclear Regulatory Commission Dr. Forrest J. Remick Washington, D.C.
20555 Atomic Safety and Licensing Board 305 East Hamilton Avenue Atomic Safety and Licensing Ctate College, Pennsylvania 16801 Board Panel U.S. Nuclear Regulatory Atomic Safety.and Licensing Appeal Commission Panel Washington., D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary Bridget L. Rorem U.S. Nuclear Regulatory Essex, Illinois 60935 Commission Washington, D.C.
20555 Everett J.
Quigley f
R.R.
1, Box 378
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Kankakec, Illinois 60901
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grc '.,
Matthew A.
Rooney
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