ML19338E655
| ML19338E655 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/02/1980 |
| From: | Gallen K, Glazer S, Hiestand O DAIRYLAND POWER COOPERATIVE, MORGAN, LEWIS & BOCKIUS |
| To: | Olsen F AFFILIATION NOT ASSIGNED, COULEE REGION ENERGY COALITION |
| References | |
| ISSUANCES-SC, NUDOCS 8010030514 | |
| Download: ML19338E655 (5) | |
Text
0V f, !OfQ ItEIEIED C01UtdSPONDENCE
\\191ff 7
'\\
UNITED STATES OF AMERICA S
CocKgtg3 NUCLEAR REGULATORY COMMISSION
[-
Usng-M O i e ct
'** Ret & se&'1 g y
- O IN THE MATTER OF
)
/
)
4
/
N DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409
)
(Show Cause)
)
(LA CROSSE BOILING WATER
)
REACTOR)
)
LICENSEE'S INTERROGATORIES TO CONSOLIDATED INTERVENORS Pursuant to 10 C.F.R.
52.740b and the discovery schedule established at the September 11, 1980 prehearing conference, Dairyland Power Cooperative (Dairyland or DPC), the licensee in the above-captioned proceeding, hereby propounds the following interrogatories to be answered by Consolidated Intervenors (i.e., Frederick M. Olsen and the Coulee Region Energy Coalition (CREC)) by October 20, 1980, in writing and under oath.
These interrogatories are continuing in nature and must be supplemented to include information thereafter acquired in accordance with the requirements of 10 C.F.R.
52.740(e).
1.
Please state the name and address of each person whom you have engaged or utilized to conduct any reviews, analyses, tests, or studies related to the liquefaction potential of the soils at the LACBWR site and the two issues g0}
O$
soloeso a
G U
5
. identified in the Order to Show Cause issued by the Nuclear Regulatory Commission on February 25, 1980, and as to each such person please provide the following:
l (a) his or her professional qualifications, by way of education and/or experience, as applicable; (b) the subject matter of each such review, analysis, test or study; (c) a description of each such review, analysis, test, or study and a summary of the results of same; (d) a description and identification of any written reports prepared as a result of each such review, analysis, test or study.
2.
With respect to any individuals whom you intend to introduce as witness to testify on your behalf with regard to these issues in any public hearings which may be held in this proceeding, please provide:
(a) their qualifications, particularly as they relate to these issues; (b) all technical papers either written or published by them; (c) all books wri: ten and/or published by them; (d) all statements or testimony (both written and oral) given by them in other proceedings relating to soil liquefaction; (e) all responses to interrogatories answered by them or responses which they assisted in the preparation of relating to soil liquefaction in other proceedings.
- 3.
By the terms of the Order, Dairyland was ordered to show cause why it should not " submit a detailed design proposal for a site dewatering system to preclude the occurrence of liquefaction in the event of an earthquake with peak ground accelerations of 0.12 or less."
Is it your position that liquefaction will occur at the LACBWR site in the event of an earthquake with peak ground accelerations of 0.12g or less?
If so, why?
Please provide all documentation and data on which you rely in support of your position.
4.
Do you agree that there is no need to design and install a site dewatering system at the LACBWR site if it can be shown that liquefaction will not occur in the event of an earthquake with peak ground acceleration of 0.12g or less?
If not, why not?
Please provide all documentation and data on which you rely in support of your answer.
j 5.
Please state in detail (a) your understanding of what soil liquefaction is and (b) your position on the lique-j faction potential of the LACBWR site.
Provide all documenta-tion and data on which you rely in support of your answer.
Respectfully submitted By W. 5. HiestAnd Attorney for DAIRYLAND POWER COOPERATIVE OF COUNSEL:
Kevin P. Gallen Steven A. Glazer MORGAN, LEWIS & BOCKIUS 1800 M St., N.W.
Washington, D.C. 20036 i
' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409
)
(Liquefaction)
(La Crosse Boiling Water
)
(Show Cause)
Reactor)
)
CERTIFICATE OF SERVICE Service has on this day been effected by personal delivery or first class mail on the following persons:
Charles Bechhoefer, Esq., Chrm.
Docketing & Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Mr. Ralph S. Decker Board Panel Route 4 U.S. Nuclear Regulatory Box 190D Commission Cambridge, Maryland 21613 Washington, D.C.
20555 Dr. George C. Anderson Atomic Safety and Licensing Department of Oceanography Appeal Board University of Washington U.S. Nuclear Regulatory Seattle, Washington 98195 Commission Washington, D.C.
20555
-2 Steven Burns, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Karen Cyr, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard Shimshak Plant Superintendent Dairyland Power Cooperative La Crosse Boiling Water Reactor Genoa, Wisconsin 54632 Fritz Schubert, Esquire Staff Attorney Dairyland Power Cooperative 2615 East Avenue, South La Crosse, Wisconsin 54601 Coulee Region Energy Coalition P. O. Box 1583 La Crosse, Wisconsin 54601 Aten:
Anne Morse Mr. Harold Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Frederick M. Olsen, III 609 N. lith Street La Crosse, Wisconsin 54601
/
- 0. S. Hiestand
.