ML20005B489
| ML20005B489 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 07/02/1981 |
| From: | Van Vranken J ILLINOIS, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8107080288 | |
| Download: ML20005B489 (8) | |
Text
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lhK Dated: July 2, 1981.
q QTED CORRESPONDENCB
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UNITED STATES OF AMERICA W
NUCLEAR REGULATORY COMMISSION G
IN THE MATTER OF
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)
GENERAL ELECTRIC COMPANY
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Docket No.
(Renewa g\\ d EMII
)
(GE Morris Operation Spent Fuel
)
Storage Facility).
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RESPONSE TO SECOND SET OE
. u.5.Md5 INTERROGATORIES PROPOUND BY NRC STAFF
.p
/ mi V Interrogatory G-1.
State whether or not you intend to call any person or persons as witnesses in this proceeding in support of (a)
Contention A (c)
Contention C (b)
Contention B (c)
Contention D and provide the names, addresses, educational backgrounds and professional qualifications of those persons you intend to call.
Response
(a)
Contention 4 (e) :
No.
(b)
Deleted.
(c)
Contention 8:
Gregory C. Ilinor.
See resume submitted August 25, 1980.
(d)
Contention 9:
No.
(e)
Contention 10:
No.
Interrogatory G-2.
Indicate which of those persons identified in response to Interrogatory G-1 will appear voluntarily and which persons you T,j '.} /qVf k
ep y
intend to subpoena.
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Response
Mr. Minor will appear voluntarily.
Interrogatory G-3.
Provide summaries of the views, positions, or proposed testimony on (a)
Contention A (c)
Contention C (b)
Contention B (d)
Contention D of all persons named in response to Interrogatory G-1 that you intend to present during this proceeding.
Response
(a)
Contention 4 (e) :
not applicable.
(b)
Deleted.
(c)
Contention 8:
There is not enough data in the CSAR to ensure the control room will remain habitable in the event of an accident or large release of radioactive material; nor is there sufficient data to conclude that the access routes l.
l will remain at low enough exposure rates and contamination levels to permit personnel access during and following an accident.
1 The control room at the Morris Operation is located at l
i the 65' level, beneath the unused computer room and immediately adjacent to the filter room.
Ventilation air is drawn from the i
outside at elevation 85'.
One access route is through the basin i.
i area, another route is through stairwells to the Crane Maintenance l
and Equipment area.
l The filters in the filter room could become contaminated in the event of a release or accident.
The air intake could draw in radioactively contaminated air in the event of a release or accidert, and the access route through the pool or basin area could be inaccessible in an accident condition.
Other access routes are not discernible in the data supplied with the CSAR.
(d)
Contention 9:
Not applicable.
(e)
Contention 10:
Not applicable, f
Interrogatory G-4:
Identify by author, title, date of publication and publisher, all books, documents and papers that you intend to employ or rely upon in presenting you direct case on (a)
Contention A (c)
Contention C (b)
Contention B (c)
Contention D and provide copies of, or make available for Staff inspection and copying, thr'.e items.
Response
(a)
Contention 4 (e) :
None other than those identified in the Contention.
(b)
Deleted.
(c)
Contention 8:
None other than those identified in the Contention.
(d)
Contention 9:
None other than those identified in the Contention.
(e)
Contention 10:
None other than those identified in the Contention.
Interrogatory G-5:
If the representations made in (a)
Contention A (c)
Contention C (b)
Contention B (d)
Contention D are based in whole or in part on any documents prepared by the Licensee or NRC Staff which you contend are deficient, identify the documents and specify the particular portions thereof you regard as deficient and explain why they are deficient.
Response
(a)
Contention 4 (e) :
CSAR, Sec. A.7.5.3 and 9.6.
It is deficient as stated in the Contention.
(b)
Deleted.
(c)
Contention 8:
CSAR Sec.
5.5.5.4.
It is deficient as stated in the Contention and in response to G-3.
(d)
Contention 9:
CSAR Sec.
9.3.
It is deficient as stated in the Contention.
(e)
Contention 10:
As stated in the Contention.
Interrogatory G-6:
Identify by author, title, date of publication and publisher, all books, documents or papers that you intend to employ or rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in connection with (a)
Contention A
'(c)
Contention C (b)
Contention B (d)
Contention D
Response
(a)
Contention 4 (e) :
None.
(b)
Deleted.
(c)
Contention 8:
None.
l (d)
Contention 9:
None.
(e)
Contention 10:
None.
Respectfully submitted, TYRONE C. FAHNER Attorney General State of Illinois BY:
4
@OHN VAN VRANKEN Assistant Attorney General l
l Environmental Control Division 188 W.
Randolph Street - Suite 2315 Chicago, Illinois 60601 (312) 793-2491 1 e
UNITED STATES O F AME RI C A NUCLE AR REGULATORY COMMISSIO" BEFORE THE ATO MI C S AFETY AND LICENSING BOARD In The Matter Of
)
Docket No. 70-1308 GENERAL ELECTRIC COMP ANY
)
)
(Spent Fuel Pool)
(GE Morris Operation Spent )
Fuel S torage Facility)
)
AFFIDAVIT OF GRE GO RY C.
MINOR STATE OF CALIFORNI A
)
)
ss.
COUNTY OF S ANTA CLARA )
GREGO RY C.
MINOR deposes and says under oath as follows:
I, the undersigned, have assisted in preparing and review-ing responses to interrogatories on Morris Ope ra te. ( oa ten tions.
To che best of my knowledge, the responses at -
2e and Correct.
bYh.tr1 M&HJ
[G G0b C.
MINOR Subscribed and sworn to before me this
.7 9 r/
day of May, 1981.
JEAN H. JONES l
V'o
'7 NOTARY PUSLIC-CAL!FDPNIA
+
N OTARY P UB LI C SANTA CLARA COUNTY My Commcen Ex;wes kvmc S 13:
My Commission Expires: //-9
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PROOF OF SERVICE I hereby certify that on this 2nd day of July, 1981,
.I served copies of the foregoing Response to Second Set of Interrogatories Propounded by NRC Staff, upon each of the persons named on the attached Service List, by causing copies to be deposited in the U.
S. Mail, in envelopes properly addressed and sealed, first class postage prepaid.
M
@HN VAN VRANKEN
SERVICE LIST Andrew C.
Goodhope, Esq.
Everett Jay Quigley Chairman R.R.
1 Box 378 3320 Estelle Terrace Kankakee, Illinois 60901 Wheaton, MD 20906 Mrs. Elaine Walsh (Patrick)
Dr. Linda W.
Little 33 Pheasant Trail 5000 dermitage Drive Wilmington, Illinois 60481 Raleigh, NC 27612 Ronald Szwajkowski, Esq.
Dr. Forrest J, Remick Mayer, Brown & Platt 305 E. Hamilton Avenue 231 South LaSalle Street State College, PA 16801 Chicago, Illinois 60604 Fridget Little Rorem Lssex, Illinois 60935 Edward Firestone, Esq.
Legal Operation General Electric Company 175 Curtner Ave., Mail Code 822 San Jose California 95125 Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Ccmmission Washington, D.C.
20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Marjorie Ulman Rothschild Office of the Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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