ML19350C587
| ML19350C587 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 03/19/1981 |
| From: | Rooney M GENERAL ELECTRIC CO., MAYER, BROWN & PLATT |
| To: | Rorem B AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 8104060234 | |
| Download: ML19350C587 (5) | |
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Dated:
March 19, 1981
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' UNITED STATES OF AMERICA N
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E'UCLEAR REGULATORY COMMISSION S'
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'u ly,,iy GENERAL ELECTRIC COMPANY
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Docket No. 70-1308
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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 SECOND SET OF INTER-ROGATORIES PROPOUNDED TO THE INTERVENOR, ROREM, ET AL.
General Elt:tric 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 regarding any proposed Additional Contentions, state the following:
a.
Namt and address; b.
Name and address of his employer or the organization with which he is associated in any
- professional capacity; c.
The field in which he is to be offered as an expert; i
d.
A summary of.his qualifications to testify regarding the specific proposed Additional Contention or Contentions about.which.he is expected to testify;
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e.
The substance of the facts to which he is pected to testify; f.
The substance of the opinions to which he 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 sitch experts.
2.
For each person retained or specifically employed as an expert with regard to any proposed Additional Contention, about whom no decision has been made as to whether such expert will be called to testify, state the following:
a.
Name and address; b.
His particular field of expertise; E
c.
A summary of his qualifications as an expert regarding the specific proposed Additional Contention or Contentions concerning which he has been retained or specifically employed; and d.
Whether such expert has submitted or transmitted any reports, analyses or opinions in any form.
If so, state'the dates and addressees of all reports, analysesLor' opinions.
3.
With regard to each proposed Additional Contention
' state with particularity the factual basis for each such
.. contention, including'all facts and~ technical info,rmation or l data relied _upon in-formulating 1such contention.
4.
With regard to proposed Additional Contention A, state with particularity the regulatory basis for the allegation that the impact of transportation of spent fuel on the renewal of the license for the Morris Operation, as opposed to the siting of the Morris Operation, must be evaluated in the CSAR.
5.
With regard to proposed Additional Contention B, state with particularity any alleged inadequacies in General Electric's decommissioning plan or its decontamination and decommissioning procedures.
6.
With regard to proposed Additional Contention B, state with particularity the basis for the statement that General Electric has failed to provide. reasonable assurance that it possesses the financial ability to decontaminate and i
decommission the Morris Operation.
With regard to proposed Additional Contention C, 7.
state the regulatory basis for the allegation that events prec p tated by transportation of spent fuel must be described ii or evaluated in the CSAR.
8.
With regard to proposed Amended Contention C, state with particularity the nature of any alleged deficiency in the description or-evaluation in the CSAR of any event, which may be precipitated by the storage of any spent fuel, damaged or otherwise, at the Morris Operation.
-9.
With regard to proposed Additional Contentu state what regulatory basis,.if any, exists for the allegation that any damaged spent. fuel may not be received or stored at the Morris Operation.- m
10.
With regard to proposed Additional Contention D, state with particularity the basis for the assumption that General Electric seeks anything more than to continue to operate the Morris Operation at its present capacity in the present licensing proceeding.
11.
State the author, title, publication, page and column within the publication, and date of publication of the article purportedly quoted in the second paragraph of proposed Additional Contention A.
With regards to any proposed Additional Contentions admitted by the Board in this matter, these Interrogatories are continuing interrogatories and require supplemental answers if i
Rorem, et al. 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 9htD L a Ronald W. Szwajkowsk4 Matthew A. Rooney Its Attorneys OF COUNSEL:
MAYER,LBROWN &~PLATT 231. South LaSalle Straet
. Chicago, Illinois 60604 (312) 782-0600
. _4_
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
GENERAL ELECTRIC COMPANY
)
)
Docket No. 70-1308 Consideration of Renewal of
)
Materials License No. SNW-1265)
Issued to GE Morris Operation )
Fuel Storage Installation
)
CERTIFICATE OF SERVICE The undersigned hereby certifies that he served a copy of GENERAL ELECTRIC'S SECOND SET OF 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 LaSalle Street, Chicago, Illinois, in plainly addressed and sealed envelopes with proper first class postage attached before 5:00 P.M.
on March 19, 1981:
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 Bosrd 305 East Hamilton Avenue Atomic Safety and Licensing State 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 j
Office of the Secretary Bridget L. Rorem U.S. Nuclear Regulatory Essex, Illinois 60935 Commission Washington, D.C.
20555 Everett J.'Quigley R.R.
1, Box 378 Kankakee, Illinois ~60901 y
pt Matthew A.
Rooney 9-
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