ML20009E284
| ML20009E284 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 07/24/1981 |
| From: | Lynch M Office of Nuclear Reactor Regulation |
| To: | PORTER COUNTY CHAPTER INTERVENORS |
| References | |
| NUDOCS 8107280002 | |
| Download: ML20009E284 (10) | |
Text
.
e 7/24/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
NORTHERN INDIANA PUBLIC SERIVCE
)
DocketNo.50-367j@t r COMPANY
)
(Construction P(ffai f
}
Extension)f[ [ -}q
~
1-(Bailly Generating Station, f
Nuclear-1)
)
JUL 2 71981 * [2 NRC STAFF ANSWERS TO PORTER COUNTY CHAPTER
" D5s
[
i INTERVEN0RS' FIRST SET OF INTERR0GATORIES o
,M
\\
s/>k7 i,h h^"
i 1.
Mr. Boyd left the Commission's employment on June 15, 1979. He is now Vice President df KMC, Inc., located at 1747 Pennsylvania Avenue, N.W., Washington, D.C. 20006.
His telephone number is (202) 822-0820.
2.
A.(a)
Louis Bykoski.
(b)
U.S. Nuclear Regulatory Commission, Washington, D.C.
4 20555. Telephone Number: (301) 492-4879.
(c)
Regional Environmental Economist, Regional Inpact Analysis Section, Siting Analysis Branch, Division of Engineering, Office of Nuclear Reactor Regulation.
Mr. Bykoski performs socioeconomic impact analysis of nuclear generating facilities.
l l
(d) Mr. Bykoski consulted, aided, provided and furnished information for the " Socioeconomic Impacts" section of the " Environmental l
Impact Appraisal Regarding The Extension of Construction Pennit CPPR-104" (hereinaf ter "EIA").
g$O7 8107280002 810724 PDR ADOCK 05000367 G
PDR l
B.(a) Lewis G. Hulman.
(b)
U.S. Nuclear Regulatory Commission, Washington, D.C.
20555. Telephone Number:
(301) 492-8595.
(c) Chief, Systems Interaction Branch; formerly Chief, Hydrology-Meteorology Branch, Office of Nuclear Reactor Regulation.
Mr. Hulman was the original hydrologic reviewer of the Bailly construction permit application. He has continued to provide related hydrologic review services with the exception of his time spent in private industry during which he acted as a consultant to the NRC.
(Seeanswerto Interrogatory No. 8.)
(d) Mr. Hulman consulted, aided, provided and furnished information for the " Installation of the Slurry Wall" section of the "NRC Staff Evaluation of the Request for An Extension of Construction Permit No. CPPR-104" (hereafter " Staff Evaluation") and the " Impacts From Continued Construction Dewatering" section of the EIA.
C.(a) William F. Lovelace.
(b)
U.S. Nuclear Regulatory Commission, Washington, D.C.
20555.
Telephone Number (301) 492-9860.
l (c)
Engineering Specialist, Management Infomation Branch, 1
Office of Management and Program Analysis. Mr. Lovelace performs management and program analysis related to the construction of nuclear generating plants.
(d) Mr. Lovelace consulted, aided, provided and furnished information on the application of the "NRC Caseload, Planning Projections for Fiscal Years 1981-85" (March 1979) to the questior, of reasonable time to construct the Bailly plant.
1
D.(a)
M. David Lynch.
(b)
U.S. Nuclear Regulatory Commission, Washington, D.C.
20555.
Telephone Number: (301) 492-8413.
(c) Licensing Project Manager (Bailly Generating Station, Nuclear-1), Licensing Branch No. 2 Division of Licensing, Office of Nuclear Reactor Regulation. Mr. Lynch has the responsibility for coordinating the review of all licensing action regarding the Bailly facility.
(d) Mr. Lynch is the principal author of the NRC Staff Evaluation.
3.
[ Pursuant to the Licensing Board's Order of July 10, 1981, the Staff need not respond to this interrogatory.]
4.
Yes.
5.
(a)
Each fact which the Staff contends contributes to a conclusion that " good cause' exists for the fact that construction of l
Bailly was not completed by the latest construction completion date l
contained in the construction permit and the oasis for the contention that each fact contributes to " good cause" are set forth in the Staff Evaluation.
(b) Not applicable.
6.
Yes.
I 7.
(a)(i), (ii), (iii) & (iv)
Each fact which the Staff contends contributes to a conclusion that " good cause" exists for an extension of the Bailly construction permit, the basis for the contention that each
fact contributes to " good cause," the length of the extension which the Staff considers reasonable, and the basis for cor.cluding that such an extension is reasonable are set forth in the Staff Evaluation.
(b) Not applicable.
8.
(a)
L. G. Hulman has returned to employment with the NRC after an interval as an employee of Tetra Tech, Inc., Pasadena, California.
(b) !!r. Hulman was a consultant to the NRC as an employee of Tetra Tech, Inc. from March 19, 1s81, to April 22, 1981.
(c) Mr. Hulman consulted on the impact of dewatering during the extended period comprising the early construction phases at the Bailly site.
(d) The documents on which Mr. Hulman relied are listed in the bibliography attached to the written report prepared and submitted by Mr.
Hulman.
He is the custodian of these documents at his office in Bethesda, Maryland.
Since these documents are available for PCCI's inspection and copying in Bethesda, summaries are not being provided.
(e)
Yes. A copy of this report is produced in response to l
PCCI's Second Request to the NRC for Production of Documents" (filed contemporaneously with these answers; the request is hereafter identified i
l as "second document request"). A summary is therefore not necessary.
(f)
Yes.
(i) Raymond Gonzales, Myron H. Fliegel, George Lear, and M. D. Lynch.
(ii)
No formal summary of the oral report is available, but the contents of the oral report were subsequently contained in the final report, which is being produced in the Staff response to PCCI's second document request.
l l
~
(iii)
No notes or memoranda concerning the oral report have been prepared. At least one of the participants in the meeting (George Lear) made handwritten notes of the meeting which he has retained (uncirculated) in his files.
9.
(a)
M. David Lynch, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
L. G. Hulman.
U.S. Nuclear Regulatory Commission, Washington, D.C.
20555.
Louis Bykoski, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
(b) Mr. Lynch will testify on the Staff Evaluation and EIA.
Mr. Hulman will testify on the impact of dewatering during the extended period of construction at the Bailly site. Mr. Bykoski will testify on the socioeconomic impacts of the requested extended construction period at Bailly.
(c) The substance of the facts and opinions to which Mr. '.ynch, Mr. Hulman and Mr. Bykoski are expected to testify and the ground for each opinion are stated in the Staff Evaluation and in the EIA.
(d) The documents relied upon or examined by Mr. Lynch in l
preparation of the Staff Evaluation are identified therein.
To the extent such documents have not been transmitted to PCCI as a party to this proceeding, they are provided in response to the second document request.
With respect to documents relied upon or examined by Mr. Hulman, see our answer to Interrogatory 8(d).
j The documents relied upon or examined by Mr. Bykoski are identified in the " Socioeconomic Impacts" section of the EIA. As parties to this proceeding, PCCI has received copies of these documents.
(e) Messrs. Lynch and Bykoski have prepared no written reports other than what is presented in the Staff Evaluation and EIA. With respect to Mr. Hulman, see response to Interrogatory 8(c).
(f) Mr. Lynch and Mr. Bykoski have not given any oral reports to anyone.
Mr. Hulman, during the time he was employed by Tetra Tech, Inc., gave an oral report. See answer to interrogatory 8(f).
10.
Staff does not expect to call witnesses other than expert witnesses.
11.
(a) The report was completed and concurred in by all persons whose concurrence was necessary in early March 1981.
(b)
Darrell G. Eisenhut, Director, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
(c) Due to the lack of Staff personnel available to conduct the technical aspects of the review within the priorities then being pursued, the technical assistance of the Corps of Engineers was obtained.
The Office of Management and Budget had authorized such use of the Corps.
(
12.
(a)
M. David Lynch.
(b)
U.S. Nuclear Regulatory Commission.
(c) and (d). Licensing Project Manager, (Bailly Nuclear Unit 1),
Licensing Branch No. 2, Division of Licensing, Office of Nuclear React'ir Regulation.
13.
(a) We presume that PCCI mistakenly referred to "the person identified in Interrogatory 13" when it meant " Interrogatory 12."
On this presumption, we answer as follows.
The person; listed in response l
l
~
to Interrogatory 2(a) are also the persons who provided or furnished information to Mr. Lynch, consulted with him in the preparation of the Interrogatory responses, or otherwise aided in the preparation of the responses.
(b)
Each such person consulted, aided, or pecvided or furnished information with respect to those responses where his name appears.
(c) The nature of the information or aid furnished was verification of responses.
t l
l i
1
., ~..,,,_____.,...,.
.,,,-,.,r,
UNITED STATES OF NIERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of NORTHERN INDIANA PUBLIC SERVICE
)
Docket No. 50-367 COMPANY (Construction Permit Extension)
(Bailly Generating Station,
)
Nuclear-1)
)
AFFIDAVIT OF M. DAVID LYNCH I, M. David Lynch, being duly sworn, depose and state that:
I am employed by the Licensing Branch No. 2, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
A copy of my professional qualifications is already on record in this proceeding.
I was responsible for the preparation of, and have read, the "NRC Staff Answers to Porter County Chapter Intervenors' First Set of l
Interrogatories" filed July 24, 1981 and hereby certi., that the answers are true and correct to the best of my knowledge and belief.
(JALl
/
. David Lynch Subscribed and sworn to before me this,2May of July,1981 W
(>
Not&ry PubFic gf/
My Comission Expires
/j / 9I2/
O V
i
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
NORTHERN INDIANA PUBLIC SERVICE
)
Docket No. 50-367
)I (Construction Permit Extension)
COMPANY (Bailly Generating Station,
)
Nuclear-1
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF ANSWERS TO PORTER COUNTY CHAPTER INTERVENORS' FIRST SET OF INTERROGATORIES" in the above-captioned proceeding have been served on the following by deposit in the Un'ited States mail, first class or as indicated by an asterisk by deposit in the Nuclear Regulatory Commis~sion's internal mail system, this 24th day of July,1981:
- Herbert Grossman, Esq., Chairman, Robert L. Graham, Esq.
Administrative Judge One IBM Plaza Atomic Safety and Licensing Board Panel 44th F10or U.S. Nuclear Regulatory Commission Chicago, Illinois 60611 Washington, D.C.
20555 George and Anna Grabowski Robert L. Holton, Administrative Judge 3820 Ridge Road School of Oceanography Highland, Indiana 46322 Oregon State University Corvallis, Oregon 97331 John Van Vranken, Esq., Chief Northern Region J. Venn Leeds, Administrative Judge Environmental Control Division 10807 Atwell 188 West Randolph Street Houston, Texas 77096 Chicago, Illinois 60601 Kathleen H. Shea, Esq.
Clifford Mezo, Acting President Lowenstein, Newman, Reis, Axelrad Local 1010 and Toll United Steelworkers of America 1025 Connecticut Avenue, N.W.
3703 Euclid Avenue Washington, D.C.
20036 East Chicago, Indiana 46312 Robert J. Vollen, Esq.
William H. Eichhorn, Esq.
c/o BPI Eichhorn, Morrow & Eichhorn 109 North Dearborn Street 5243 Hohman Avenue Chicago, Illinois 60602 Hammond, Indiana 46320 Edward W. Osann, Jr., Esq.
Atomic Safety and Licensing Suite 4600 Board Panel One IBM Plaza U.S. Nuclear Regulatory Commission Chicago, Illinois 60611 Washington, D.C.
20555
- 2-Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.
20555
- Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comission Washington, D.C.
20555
- ssN 4
Stephen'H. Lewis Counsel for NRC Staff 1
J s
. ~.e a.,--
.,w
-e-
,,e--w 9
e, n
7w.
,-~-v-e-
m w.-----y9.
ew,.
--w ww-
-+-s,
,-,my,-my--
-e-ee-.-e.--
reps.,---.
.-,y,
-,-r--
-#c--
m..ne,-+
m