ML19322A131

Applicant'S Interrogatories to Intervenors & Request for Production of Documents Concerning Position Re Issues Before ASLB & Plans Re Upcoming Hearings.Certificate of Svc Encl

ML19322A131
Person / Time
Site:	Perkins
Issue date:	12/15/1978
From:	Mcgarry J DUKE POWER CO.
To:
References
NUDOCS 7901030017
Download: ML19322A131 (10)

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UNITED STATES OF AMERICA w *~#r / o NUCLEAR PEGULATORY CCMMISSION g

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DUKE POWER COMPANY ) Cocket Nos. 3?N 50-488

) STN 50-489 (Perkins Nuclear Station, ) STN 50-490 Units 1, 2 and 3) )

APPLICANT'S INTERROGATORIES TO INTERVINORS AND REQUESTS TO PRODUCE Pursuant to 10 CFR S$2.740b and 2.741, Applicant serves the following interrogatories and requests to produce on In-tervenors to be answered under oath by a duly authorized rep-resentative. Each answer should include all knowledge in the possession of all officers, directors, members, associate =em-bers, advisors, agents, employees, consultants, and counsel for Intervenors.

In answering the interrogatories and in responding to the request to produce, please recite the interrogatories or request preceding each answer. These interrogatories and this request to produce shall be continuing, and, if after answering or respending, additional information or documents are obtained, please update the answer and response with such additional information. The term " documents" shall include, without limitation, the following: originals and copies (car-ben, photographic, microfilm or otherwise) of all writings, correspondence, minutes, =emoranda, reports, notes, diaries, 7901030011

messages, telegrams, letters, books, ledgers, phocographs, pictures, films, drawings, sketches, blueprints, data sheets,.

publications, advertisements, brochures, pamphlets, leaflets, contracts and/or other written material of whatsoever kind known to or in control er possession of Intervenors, their attorneys, members, consultants, officers, cont setors, agents, or other representatives. In the event any documee.t requested in these interregatories has been destroyed or is unavailable, describe in detail the reascns therefor.

Interrogatories and Request to Produce

1) Please set forth Intervenors' understanding of the re-maining issues pending before the Licensing Board.

2) What is the basis for Intervenors' description of such issues?

3) Maat is Inte,rvenors' position with respect to such issues?

4) What is Intervenors' hasis for such position?

5) Please list all dccuments and/or studies relied upon in support of Intervenors' position.

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6) Have Interverors undertaken any research and/or conducted any studies with regard to the remaining issues? If so, please describe the nature of such research and/or studies and provide specific reference to and copies of documents relied upon in such research and/or studies.

7. Have Intervenors contacted any individual and/or group with regard to the remaining issues? If so, please identify and indicate the reason for contacting any named individual and/or group, the date of the contact and the individual and/or group response.

8) With respect to individual and/cr group which Intervenors may'have contacted, have they prepared any documents, undertaken any research and/or conducted any studies upon which Intervenors will rely? If so, please describe and provide copies.

9) Do Incervenors plan to participate in the upccming hear-ings with regard to the remaining issues? If so, please set forth the substance of Intervenors' participation.

10) Co Intervenors plan to file testimony in the upcoming hearings pursuant to 10 CFR 52.743(b). If so, who will spcnsor (i.e., witness) such testi=cny?

11) Please identify any witness which Intervenors plan to call at the upcoming hearing, and provide a su= nary of their educational and professional background. Also, please set forth any other informatien hearing upon their qualifications to testify.

12) If Intervenors plan to call witnesses at the upcoming hearing, please indicate with specificity the nature of their testimony. In addition, please list and provife copies of documents which they rely upon with respect to the subject testimony. Also, please state whether w

such individuals have undertaken any research, conducted 1

any studies and/or contacted any individuals and/or  ;

1 groups with reference to their testimony. If so, please-describe and provide copies.

13) Are Intervenors of the view that sites obviously superior to the Perkins site exist for the construction and operation of a nuclear power plant similar to Perkins?

If so, list specific sites and please furnish any analy-sis which compdres Perkins to sites considered ebviously superior to Perkins.

14) If Intervenors are of the view such sites exist, please set forth the basis for such conclusion.

15) What. criterion do Intervenors consider'to be the most important with respect to alternate site selection?

Please explain the basis for such criterion selection.

16) What other criteria do Intervenors consider to be hn-portant with respect to alternate site selection?

Please explain the basis for such criteria.

17) Em e Intervenors visited sites other than Perkins? If so, please list.

r 181 How long have Intervenors considered sites other than Perkins as viable alternatives. Please provida documents to support this respense.

19) Have Intervenors reviewed the documents of the Applicant relative to sites other than Perkins? If not, why not?

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If so, please answer-the following:

a. Do Intervenors agree with the content of such documents?

b. Are any facts contained therein erroneously stated?

If so, what are the correct facts?

c. Has any pertinent information been cmitted? If so, please specify such information.

d. Is there any error in the methcdology employed?

If so, please explain,

e. Provide documents reflecting Intervencrs ' analysis of such document.

20) Have Intervenors reviewed the documents of the NRC Staff relative to sites other than Perkins? If not, why not?

If so, please answer the following:

a. Do Intervenors agree with the content of such documents?

b. Are any facts contained therein erroneously stated?

If so, what are the correct facts?

c. Has any pertinent information been cmitted? If so, please specify such information.

d. Is there any error in the methodology empicyed?

If so, please explain.

e. Provide documents reflecting Intervencrs' analysis of such document.

21) Have Intervenors obtained any dccu=ents from the State l l

of North Carolina relative to site selection subsecuent I

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to the conclusion of the environmental phase of the evidentiary hearing which addressed alternate sites on April 29, 1977? If so, please submit copies and answer the following:

a. Do Intervenors agree with the content of such documents?

b. Are any facts contained therein erroneously stated?

If so, what are the correct facts?

c. Has any pertinent information been omitted? If so, please specify such information.

d. Is there any error in the nethodology employed? If so, please explain.

e. Provide documents reflecting Intervenors ' analysis of such document.

22) What local, state or federal officials have Intervenors contacted with respect to consideration of sites other than Perkins?

23) In light of the lapse of time since the initial inter-vention, please confirm whether the respective inter-vening participants remain active participants in this proceeding. If not, please explain.

2 4 )- Please list the date of the last meeting of the respective intervening participants regarding the issues presently under consideration.

25) Please state whether all of the respective intervening participants are aware of the position taken by Inter-I venors in response to these interrogatories.

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26) Which, if any, of the respective intervening participants assisted in the preparation of the response to these in-terrogatories? please list specific names.

27) Have Intervenors attended any local, state or federal meetings relative to the subject of alternate sites in general? If so, please list the time, place, subject matter and principal spokesman.

28) Have Intervenors attended any local, state or federal meetings relative to the subject of sites alternate to Perkins? If so, please list the time, place, subject matter and principal spckesman.

29) Have Intervenors attended any local, state or federal meetings relative to the subject of the Yadkin River in general? If so, please list the time, place, subject matter and principal spokesman.

30) Have Intervenors attended any meeting sponsored by knowledgeable authorities (by training and/or experience) in power plant siting? If so, please list the time, place, subject matter and principal spokesman.

Respcctfully submitted, t

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J. m enael McGarry, III /' g Of counsel:

William L. Porter, Esq.

Associate General Counsel Cuke Pcwer Company December 15, 1978 l

w UNITED STATES OF AMERICA NUCLEAR REGUL TORY COMMISSICN In the Matter of )

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DUKE POWER COMPANY ) Docket Nos. STN 50-488

) STN 50-489 (Perkins Nuclear Station ) STN 50-490 Units 1, 2 and 3) )

CERTIFTCATE OF SER'IICE t

I hereby certify that copies of " Applicant's Interrogatories to Intervenors and Requests to Produce", dated Decemher 15, 1978 in the captioned matter, have been served upon the fol-lowing by deposit in the United States mail this 15th day of December.

Elizabeth S. Scwers Charles A. Barth, Esq.

Chairman, Atomic Safety Counsel for NRC Regulatory and Licensing Board Staff U. S. Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D. C. 20555 U. S. Nuclear Regulatory Commissicn Dr. Donald P. deSylva Washington, D. C. 20555 Associate Professor of Marine Science William A. Raney, Jr., Esq.

Rosenstiel School of Marine Special Deputy Attorney and At=cspheric Science General University of Miami State of North Carolina Miami, Florida 33149 Department of Justice Post Office Sox 629 Dr. Walter H. Jordan Raleigh, North Carolina 881 West Guter Drive 27602 Oak Ridge, Tennessee 37830 William G. Pfefferkorn, Esq.

William L. Porter, Esq. 2124 Wachovia Building Associate General Counsel Winston-Salem, North Carolina Duke Power Company 27101 Post Office Sox 2178

! Charlotte, North Carolina

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4 Mary Apperson Davis Mr. Chase R. Stephens Route 4 Docketing and Service Station Box 261 Office of the Secretary Moc.4eville, North Carolina U. S. Nuclear Regulatory 27028 Ccmmission Washington, D. C. 20535 Chairman, Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Ccmmission Washington, D. C. 20555

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