ML20003C149

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Second Round Interrogatories Requesting Info Re Seismic Parameters to Be Applied to Assess Liquefaction at Site & Bases for Disagreement W/Nrc Use of Earthquake Magnitude of 5.0 to 5.5.Certificate of Svc Encl
ML20003C149
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 02/25/1981
From: Stephen Burns
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Olsen F
AFFILIATION NOT ASSIGNED, COULEE REGION ENERGY COALITION
References
ISSUANCES-SC, NUDOCS 8102260712
Download: ML20003C149 (4)


Text

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UNITED STATES OF AMERICA p

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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l (Order to Show Cause)

Occket No. 50-409 SC DAIRYLAND POWER COOPERATIVE (La Crosse Boiling Water Reactor)

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NRC STAFF'S SECOND ROUND INTERR0GATORIES TO THE CONSOLIDATED PARTIES The NRC Staff hereby requests that the consolidated parties in this proce'. ding, the Coulee Region Energy Coalition and Fredrick it. Olsen III, answer the following interrogatories separately and in writing under oath or affirmation. These interrogatories are posed pursuant to 10 C.F.R. 2.740b and should be answered by March 27, 1981, as established under the Board's schedule. Prehearing Conference Memorandun at 2 (Jan. 6,1981).

For each response to the interrogatories, identify the person or persons who prepared or contributed to the preparation of the response.

For all documents that are identified in response to the interroga-tories, identify the document by author, title, date, general subject matter, specific page or section references, and place where a copy of the document may be obtained. The NRC Staff further requests under 10 C.F.R. 2.741 that the consolidated parties provide copies of, or make available for inspection and copying, the documents identified in response to the interrogatories.

These interrogatories are continuing in nature and must be supple-mented in accordance with 10 C.F.R. 2.740(e) to include information later acquired.

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1.

Identify the seismic parameters which you contend should be applied in assessing liquefaction potential at the La Crosse site.

(a)

Identify and describe all factual data on which you rely in support of this contention; (b) Explain how this factual data supports the seismic parameters which you contend should be applied; (c)

Identify each document on which you rely in support of your contention.

2.

Identify the bases, if any, for your disagreement with the Staff's reliance in reviewing liquefaction potential on an earth-quake of magnitude 5.0 to 5.5 at a distance of less than 25 KM producing a peak ground acceleration of 0.129 and an equivalent duration of 5 cycles at the La Crosse site.

(a)

Identify and describe all factual data on which you rely

'in support of these bases; (b)

Explain how this factual data supports each of these bases; l

(c) ' Identify each document on which you rely in support of each of these bases.

l 3.

State the name and address of each person whom you have engaged to conduct any reviews or analyses related to the seismicity of the La Crosse site. As to each person, provide the following infomation:

_(a)

Professional qualifications, including educational history, technical training, and work experience; i

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(b) Subject matter of any review or analysis performed by the person; (c) A description of any review or analysis performed by j.

the person and a summary of the results of the review or analysis; and (d) An identification of any written reports or documents prepared by the person as part of any such review or analysis.

Respectfully subnitted, Stephen G. Burns Counsel for NRC Staff f _

Dated at Bethesda, Maryland this 25th day of February,1981 4

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F UNITED STATES OF AfiERICA NUCLEAR REGit!.ATORY COMMISSION BEFORE THE A10!ilC SAFETY AND LICENSING BOARD In the Matter of Docket No. 50-409 SC DA!RYLAND POWER COOPERATIVE (Order to Show Cause)

(La Crosse Boiling Water Reac'7r)

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CEI.4FICATE OF SERVICE I hereby certify that copies of the NRC STAFF'S SECOND ROUND INTERR0GA-TORIES TO THE CONSOLIDATED PARTIES in the above-captioned proceeding have been served on the following by deposit in the United States nail, first class, or as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 25th day of Februa ry,1981.

Charles Bechhoefer, Esq.*

0. S. Hiestand, Esq.

Chairnan Morgan, Lewis & Bockius Atomic Safety & Licensing Board 1800 M Street, N. W.

U. S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555 Atomic Safety & Licensing Board Dr. George C. Anderson Panel

  • Department of Oceanography U. S. Nuclear Regulatory Commission University of Washington Washington, D. C. 20555 Seattle, Washington 98195 Atomic Safety & Licensing Appeal Mr. Ralph Decker Panel
  • Route 4 Box 190D U. S. Nuclear Regulatory Commission Cambridge, Maryland 21613 Washington, D. C. 20555 Coulee Region Energy Coalition Mr. Frederick ti. Olsen, III Attn: Ms. Ann K. Morse 609 N. lith Street P. O. Box 1583 La Crosse, Wisconsin 54601 La Crosse, Wisconsin 54601 Docketing & Service Section*

Fritz Schubert, Esq.

U. S. Nuclear Regulatory Commission Staff Attorney Washington, D. C. 20555 Dairyland Power Cooperative 2615 East Avenue, South La Crosse, Wisconsin 54601 Mr. Frank Linder General Manager Dairyland Power Cooperative Stephen G. Burns

-2615 East Avenue, South Counsel for NRC Staff La Crosse, Wisconsin 54601