ML20005A422

Objections to Joint Intervenors' First Set of Interrogatories.Interrogatories Are Overly Broad & Seek Info Which Is Irrelevant to Issues.Certificate of Svc Encl

ML20005A422
Person / Time
Site:	Callaway
Issue date:	06/23/1981
From:	Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO.
To:	JOINT INTERVENORS - CALLAWAY
Shared Package
ML20005A418	List: ML20005A417 ML20005A422
References
ISSUANCES-OL, NUDOCS 8106300307
Download: ML20005A422 (5)

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- - -' Juno 23,1981 fl UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL

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(Callaway Plant, Unit 1) )

APPLICANT'S OBJECTIONS TO JOINT INTERVENORS' FIRST SET OF INTERROGATORIES TO UNION ELECTRIC Joint Intervenors Coalition for the Environment, St. Louis Region, Missourians for Safe Energy and Crawdad Alliance have filed a First Set of Interrogatories to Union Electric. Applicant submits the following objections to those interrogatories.

INTERROGATORY 8: With respect to the preceding interrogatory and separately with respect to each subpart thereof, please describe fully:

kc)' Any repairs, replacements, or other remedial or precautionary measures that were taken with respect to embeds, including an enumeration of the following:

(i) the number of manually welded embeds repaired on site; (ii) the number of manually welded embeds returned to the fabricator for repair or replacement; (iii) the number of mechanically wolded embeds repaired on site; (iv) the number o f mechanically welded embeds returned to the fabricator for repair or replacement.

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(d) The identity and location of any documents relating to any of the measures specified in answer to this interrogatory.

OBJECTION: Applicant objects to this Interrogatory (subparts (c) and (d)) on the grounds (1) that it is overly broad, bur- -

densome and oppressive in that it would require a search for, collation and review of over 6,000 documents in order to extract, compile and provide the information requested; and (2) that it seeks information not reasonably calculated to lead to the discovery of admissible evidence.

INTERROGATORY 140: Referring to the parameters and assumptions listed under Table 12.2-11 (SNUPPS, FSAR, Vol. 9), state whether-Union Electric believes longer fuel storage and compacting of fuel assemblies in the spent fuel pool will change the estimated rate of evaporation and airborne radioactive concentrations.

CBJECTION: Applicant objects to this interrogatory because it seeks information which is irrelevant to the issues in this operating license proceeding. Applicant would not be able to compact fuel assemblies under the terms of the operating license which is under consideration here. In order to compact spent fuel, it would be necessary for Applicant to apply for an amendment to the operating license. The information sought by this interrogatory might be relevant to a licensing proceeding i

initiated by the Commission if such an application is ever filed.

INTERROGATORY 145: State the time periods that Union Electric estimates spent fuel rods can be stored in spent fuel pools before degradation of cladding and structural parts and increased compacting provide an increased risk of a criticality incident.

i OBJECTION: Applicant objects to the second part of this l interrogatory, which is concerned with the increased risk of I l

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I a criticality. incident from increased compacting of spent fuel rods. As previously stated, Licensee cannot compact spent fuel under the terms of the operating license application which is the subject of this proceeding.

Respectfully submitted, SEAW, PITTMAN, POTTS & TROWBRIDGE Thomas A. Baxter Richard E. Galen Deborah B. Bauser Counsel for Applicant 1800 M Street, N.W.

I Washington, D.C. 20036 (202) 822-1000 Dated: June 23, 1981

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL

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(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "Appli-cant's Objections to Joint Intervenors' First Set of Interroga-tories to Union Electric" were served this 23rd day of June, 1981 by deposit in the U.S. mail, first class, postage prepaid, to the parties identified on the attached Service List.

~~ 4 s Thomas A. Baxter i

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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ~

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL

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(Callaway Plant, Unit 1) )

SERVICE LIST James P. Gleason, Esquize Kenneth M. Chackes, Esquire Chaizman Chackes and Hoare Atomic Safety and Licensing Board 314 N. Broadway 513 Gilnoure Drive St. Iouis, Missouri 63102 Silver Spring, Maryland 20901 Mr. John G. Peed Mr. Glenn O. Bright Ibute 1 Atcznic Safety and Licensing Kingdczn City, Missouri 65262 Board Panel U.S. Nuclear Regulatory Ccmnission tir. Howard Steffen Washington, D.C. 20555 Chanois, Missouri 65024 Dr. Jerry R. Kline Mr. Harold Icttmann Atomic Safety and Licensing Ibute 1 Board Panel Owensville, Missouri 65066 U.S. Nuclear Regulatory Connission '

Washington, D.C. 20555 Mr. Earl Brtwn .

P.O. Box 146 Iby P. Lessy, Jr. , Esquire Auxvasse, Missouri 65231 Office of the Executive Icgal Director U.S. Nuclear Regulatory Ccmnission Mr. Fred Luekey Washingtcn, D.C. 20555 Rural Ibute Rhineland, Missouri 65069 Docketing and Service Section Office of the Secretary Mr. Samuel J. Birk U.S. 'luclear Regulatory Camission P.O. Box 243 Washington, D.C. 20555 bbrrison, Missouri 65061

, Joseph E. Birk, Esquire Mr. Pobert G. Wright Assistant to the General Counsel Ibute 1 Union Electric Conpany Fulton, Missouri 65251 P.O. Box 149 St. Icuis, Missouri 63166 Eric A. Eisen, Esquire Birch, Horton, Bittner & & nice Treva J. Hearne, Esquire 1140 Connecticut Avenue, N.W., #1100 i

Deputy General Counsel Washingten, D.C. 20036 l

Missouri Public Service Ccmnission P.O. Box 360 l Jefferson City, Missouri ,65102