ML20004C605
| ML20004C605 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/26/1981 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | Jeffrey Reed AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20004C598 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8106040319 | |
| Download: ML20004C605 (10) | |
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.t' May~26,.1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION
~BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD y
In.the Matter of'
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UNION ELECTRIC COMPANY
)
Docket No. STN 50-483 OL
)
(Callaway' Plant, Unit 1)
)
APPLICANT' S INTERROGATORIES AND ~ REQUESTS FOR PRODUCTICN OF DCCUMENTS (SET NO. 1)
TO INTERVENOR JOHN G.
REED 4
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Pursuant to 10 C.F.R.-SS 2.740b, and 2.741, Applicant I
requests that Intervenor John G. Reed answer separately and fully in writing, and under oath or affirmation, each of the i
i following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents
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I identified in the responses to interrogatories below.
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Interrogatory responses are due no later than July 10, 1981.1 Special Prehearing Conference Order (April 22, 1981), at 17.
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Objections to interrogatories or the production of documents,
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inspections, etc. under 10 C.F.R. 52.741 must be served within fourteen-(14) or thirty (30) days, respectively.
Special Prehearing Conference Order (April 21, 1981), at 18.
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.Applicantirequests-that the name and address of the
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-personlor persons who providefinformation used in answering-each interrogatory be: identified, and that1the source of.
1information be disclosed wherenan answer is based in whole or-in part.or information other..than;the personal'knowl' edge of-the person or persons answering.
t These' interrogatories are intended to be continuing-in nature, and the answers should;promptly_be supplemented or amended as appropriate,4should Mr.1 Reed or any-individual-
-acting on his behalf-obtain any new or differing information responsive to these interrogatories.
Where identification of a document is_ requested,
.briefly describe the document (e.g., book, letter, memorandum, transcript,' report, hand: written notes, test data) and provide
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the following information as~ applicable:
document name,_ title, number, author, date of publication and publisher, addressee, date' written or approved, and the name and address.cf the person or persons having possession of the document.
Also state the portion or portions of the document (whether sec-tion (s), chapter (s), or page(s)) upon which you rely.
i CONTENTION 1 4
l-1.
Identify the portion or portions of the Missouri F.
Nuclear Accident Plan, prepared by the Missouri Disaster Planning and Operations Office (DPOO), upon i
which you rely to support your contention that I.
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LApplicant has not made sufficient arrangements with local ~ governments,'nor-local agencies and organiza-
-tions to meet.the requirements of 10 C.F.R. Part 50,
.Section-50.47(b)..
1-2.
With respect to. each portion of the Missouri Nuclear:
Accident' Plan' identified in your_ response to Interrogatory 1-1,1 describe the' nature of your
.dissatisf action' with-that' reference, and the factual basis for your. dissatisfaction, including any documentation in support thereof.
I l-3. -
Identify the portion or portions of the Callaway Plant Radiological Emergency Response Plan (RERP),
prepared by Applicant, upon which you rely to support your contention that Applicant has not made suffi-
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cient arrangements with local governments, nor local j
agencies and ' organizations to meet the requirements l
of 10 C.F.R. Part 50, Section 50.47(b).
1-4.
With respect to each portion of the Callaway Plant RERP identified in your response to Interrogatory l-3, describe the nature of yout dissatisfaction with that reference, and the factual basis for your I
dissatisfaction, including any documentation in j
t support thereof.
.1-5.
Identify any other documents upon which you rely, including the applicable portion or portions thereof, i
to support Contention 1.
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q 1-6.-
Provide _ the name, address and' qualifications of each~
witness who.willl testify in support of Contention 1.
CONTENTION 2 2-1.
Identify the portion or portions of the Missouri Nuclear AccidentLPlan-upon-which you will rely to
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support the allegation raised in Contention 2 that funding of local government (s) tc_ meet radiological safety response capability-has not been adequately addressed by (a) the NRC, (b) the FEMA, and (c) other
~ Federal agencies.
2-2.
With respect to each portion of the Missouri Nuclealu Accident Plan identified in yoar response to Interrogatory 2-1, describe the nature of your dissatisfaction with t,lat. reference, and the ractual-basis for your dissatisfaction, including any documentation in support thereof.
2-3.
Describe how, in your view, NRC, FEMA or other Federal agencies should address the issue of funding of local government (s) to meet radiological safety l
response capability.
2-4.
Provide the factual basis for your response to Interrogatory 2-3, including the applicable documents upon which you taly to support your position. :
2-5.=
-Identify the portion or-portions'of the Callaway1 i
Plant RERP upon which-you: rely to support'your' allegation--that_. funding of-local: government (s)'to 1 meet radiological safety: response capability has_not:
'been adequately addressed.
2-6.
With-respect to_each portion offthe Callaway-Plant'
~RERP identified in your response-to1 Interrogatory 2-5,-describe the nature of your-dissatisfaction with that reference,-and.the factual 1 basis for your dissatisfaction, including any documentation in support chereof.
2-7.
Identify any other documents upon which you rely, including any applicable portion or-portions thereof, to support your allegation that funding of local government (s) to meet radiological safety response
. capability has not been adequately addressed.
2-8.
Provide the name, address and qualifications of each witness who will testify in support of your allega-tion that funding of local government (s) to meet
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radiological' safety response capability has not been adequately addressed.
2-9.
.With respect to your allegation that failure to resolve the problem of funding for emergency planning and response capability at the local level of _
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government will result inla placing of responsibility for supporting commercial nuclear power-plants upon.
governmental'-jurisdictions'which do not have the financial ability to meet establishedENRC criteri-for the-protection of public health-and safety,
' identify, (a) ~ the " local level of government" to which you refer;.
i(b) the " government-jurisdictions" to which you refer; and (c) the " established'NRC' criteria for the protection
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of public. health'and safety" to which you refer.
2-10.~
State the factual basis, and any documentation in support thereof, for your allegation.that failure to.
resolve the problem of funding for emergency planning and response-capability at the local level of government will result in a placing of responsibility for supporting commercial nuclear power plants upon government jurisdictions which do not have the l
financial ability to meet established NRC criteria for the protection of public health and safety.
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4 2-11.
State the-factual basis for your concern that the matter of. funding for emergency planning and response capability will be deferred until after the Callaway i
i Plant is in operation.
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,,sy CONTENTION 3
.3-1.
Identify the portion or portions ef the Missouri Nuclear Accident Plan upon.which'you rely to support
.your; contention that there has not been an: adequate.
definition of the allocation of responsibilities-for.
offsite emergency planning'between state and local organizations, as provided in-NUREG-0654.
3-2.-
With respect to each' portion of the Missouri Nuclear Accident Plan identified Lin your response to Interrogatory-3-1,-. describe the-nature of your dissatisfaction with that reference, and the factual basis for your dissatisfaction, including any documentation in support thereof.
3-3.
Identify the portion or portions of the Callaway Plant RERP upon which you rely to support your contention that there has not been adequate defini-tion of the allocationof responsibilities for offsite emergency planning between state and local organiza-tions, as provided in NUREG-0654.
3-4.
With respect to each portion of the Callaway Plant RERP identified in your response to Interrogatory 3-3, describe the nature of your dissatisfaction with that reference, and the factual basis for your dissatisfaction, including any documentation in support thereof.
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. Describe howLyou would~ define the allocation of-responsibilitiesffor offsite-emergency planning.
-between:stateJand localcorganizations.
3-6.
Specify the' portions'of.NUREG-0654.upon which7you rely-in support of contention 3.
3-7.-
Identify any other documents, including the appli-cable portions thereof, upon which you rely in supportLof Contention 3.
1 3-8.
Identify the name, address and qualifications of each 4
witness who will testify in support of Contention 3.
Respectfully submitted,
-SHAW, PITTMAN,.POTTS &~-TROWBRIDGE Thomas A.
Baxter '
Deborah B.
Bauser Counsel for Applicant 1800 M Street, N.W.
Washington, D.C.
20036 i
(202) 822-1000
.i Dated:
May 26, 1981 4
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. UNITED. STATES'OF AMERICA-NUCLEAR REGULATORY COMMISSION'
.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the/ Matter of
)
-)
- UNION ELECTRIC COMPANY
)
Docket No. STN:50-483 OL
.)
' (Callaway Plant, _ Unit 1)'
. )
-CERTIFICATE OF-SEP'JICd I hereby certify that copies.of " Applicant's Interroga-tories - and Requests for Document Production (Set No. 1) to Joint Intervenors on Their Contention No.
-1,"
" Applicant's Interroga -
tories and Requests for Document Production (Set No. ')-to Joint
-' Intervenorsion Their Contention 2" and " Applicant's.laterrogatories and Requests for Production of Documents (Set No. 1) to-Intervenor John G. Reed" were served this 26th day of May, 1981 by deposit
-in the U.S.~ mail, first class, postage prepaid, to the parties identified on the attached Service List.
EMmL 8. t%a Deborah B.
Bauser b
9
v t,,w UNITED' STATES OF AMERICA.
- NUCLEARJREGULATORY COMMISSION BEFORE THE ATOMIC' SAFETY'AND-LICENSING BOARD LIn the Matter of;
.)
..)
UNION-ELECT. SIC COMPANY'
-)
- Docket No. STN ~ 50- 4 8 3 ~ OL -
-)-
(Callaway. Plant, Unit 1)
)
SERVICE' LIST James P.LGleason, Esquire Kenneth M. Chackes, Esquire Chairman Ciackes and Hoare.
At mic Safety and Licensing Board 314 N. Broadway
~513 Gilcure Drive St. Iouis, Missouri: 63102 Silver. Spring,. Maryland-.20901 Mr. John G. Paed Mr. Glen. O. Bright Pcu*a 1 Atcmic Safety and Licensirg Kingdom City, Missouri 65262 Bcard Panel U.S. Nuclear Pagulatory Comnission Mr. Howard Steffen Washingten, D.C.
20555 Chamois, Misscuri 65024 Dr. 'Jerr! R. Rline Mr. Harold Ictt:rann Atomic Safety and Licensing Poute 1 Board Panel
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Owensville, Missouri 65066 U.S. Nuclear Regulatorf Ccmnssion Washington,.D.C.
20555 Mr. Earl Brcwn P.O. Box 146 Poy P. Lessy, Jr., Esquire Auxvasse, Missouri 65231 Office of the Executive Iagal Director U.S. Nuclear Pagulatory Cennission Mr. Fred Luekey Washington, D.C.
20555 Rural Pcute Phineland, Missouri 65069
' Docketing and Service Secticn Office of the Secretary-Mr. Samuel J. Birk U.S. Nuclear Pagulatory Comitission P.O. Box 243 Washingten, D.C.
20555 Morrison, Missouri 65061
.Jeseph E. Birk, Esquire Mr. Pcbert G. Wright Assistant to the General Counsel Pcute 1 Unicn Electric COnpany Fulten, Missouri 65251 P.O. Box 149
- St. Icuis, Misscuri 63166 e
Treva J. Hearne, Esquire Deputy General Counsel Missouri Public Service Ccmnission i
~ P.O. Box 360' L
j Jefferson City,. Missouri j 5102 I
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