ML20010B126
| ML20010B126 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/10/1981 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | JOINT INTERVENORS - CALLAWAY |
| References | |
| NUDOCS 8108140052 | |
| Download: ML20010B126 (5) | |
Text
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To August 10, 1981 p
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- g. LNy p2 V QD ORE THE ATOMIC SAFETY AND LICENSING BOARD
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UNION ELECTRIC COMPANY
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Docket No.
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(Callaway Plant, Unit 1)
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APPLICANT'S INTERROGATORIES AND REQUE:
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J FOR DOCUMENT PRODUCTION (SET NO. 2) 5
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,f JOINT INTERVENORS ON THElR CONTENTION' rs Pursuant to 10 C.F.R. SS 2.740b, and 2.741, Ah611' cant requests that the Joint Intervenors--1/answer separately and fully in writing, and under oath ca affirmation, each of the following interrogatories, and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to interrogatories below.
Inter-rogatory responses are due no later than September 10, 1981.-2/
Special Prehearing Conference Order (April 21, 1981), at 17.
Applicant requests that the name and address of the person or persons who provide information used in an'swering each interrogatory be identified, and that the source of information be disclosed where an answer is based in whole or 1/
The Joint Intervenors consist of the Coalition for the Environment (St. Louis Region), Missourians for Safe Energy, and the Crawdad Alliance.
Special Prehearing Conference Order (April 21, 1981) at 1-4.
2f Objections to interrogatories or the production of docu-ments, inspections, etc. under 10 C.F.R. S 2.741 must be served within fourteen (14) or thirty (30) days, respectively.
Special Prehearing Conference Order (April 21, 1981), at 18.
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l in part on information other than the personal knowledge of the person or persons answering.
These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, should the Joint Intervenors, their counsel, or a'r individual acting on behalf of the Joint Intervenors, 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, i
i transcript, report, hand written notes, test data) and provide 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 of the person or persons having possession of the document.
Also state the portio!. or portions of the document (whether sec-tion (s), chapter (s), or page (s)) upon which you rely.
l l
CONTENTION 2A I
l 2A-1.
In your Response to Applicant's Interrogatories and Requests for Document Production (Set No. 1) to Joint Intervenors On Their Contention 2 (hereinafter "J.
I.'s Response"), at Interroga-tory A-1(1) (a) on page 5, you state, " Inadequacies of currently
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available [ monitoring] systems are d'cca discussed in the t
literature."
Identify each irr 'r tu y of which you are aware, l
and all documents upon which you re y to substantiate your answer.
2A-2.
State the factual basis, including any documentation upon which you rely, for requiring consideration of a 100-year drought in evaluating luw flow conditions in the Missouri River (J.
I.
Response, Interrogatory A-1(3) (a), at 8).
2A-3.
Is it your contention that it is not possible to predict the amount of dilution afforded by the Missouri River (J.
I.
Response, Interrogatory A-1(3) (a), at 9)?
2A-4.
Identify the specific ways in which you believe " Applicant's projection of bioconcentration does not adequately account for the intake of radionuclides, adsorbed by the sediment, on bottom feeders" (J.
I.
Response, Interrogatory A-1(5) (a), at 9).
2A-5.
Identify any documents, including applicable portions thereof, upon which you rely to substantiate your answer to Interrogatory 2A-4, above.
2A-6.
In J.
I.
Response, Interrogatory A-1(5) (a), at page 9, you state that "[t]he only way to know how much radioactivity is in fish is to measure 4.t.."
Does this statement mean th t -
you do not believe models can be used to predict the potential bioconcentration of radionuclides in fish?
Please 6xplain your answer in detail, and include references to any documentation i
upon which you rely.
,2A-7.
State the factual basis, including any documentation upon l
l which you rely, for your assertion that there will be more l
than 0.00007 curies of radioisotopes not individually identified and termed "all others" in Table 11.1-2 of the SNUPPS FSAR, which will be released to the Missouri River each year from Callaway Plant, Unit 1 (J. I. Response, Interrogatory at 10).
2A-8.
Specify the "other factors" to which you refer in your response to Interrogatory A-4, at page 17 of the J.
I. Response.
Identify the dosuments on which you rely to support your answer.
2A-9.
Identify the documents on which you rely in positing the possibility of a 360 or 620-mile canal being built on the Missouri River (J.
I.
Response at 23).
Specify the "(o]ther environmental monitoring deficiencies" which you consider "still unresolved" (J.
I. Response, Interrogatory A-25, p. 29).
Identify the documents on which you rely to support your answer.
In your view, is it possible to have sufficient knowledge of the river's discharge, "[gliven the multiple claims on the water from the Missouri River" (J.
I.
Response, Interrogatory l
A-2 7, p. 30)?
CONTENTION 2D 2D-1.
Identify the particular articles to which you refer in your l
l response to Interrogatory D-1(5) (b)
(J.
I.
Response, Interroga-i tory D-1(5) (b), p. 38).
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CONTENTION 2G 2G-1.
Provide the factual basis, including any documentation on which you rely, to support the assertion that "[t]he presence of radioisotopes accelerates the corrosion rate of metallic materials" (J.
I.
Response, Interrogatory G-1(2) (a), p. 47).
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Thomas A.
Baxter Deborah B. Bauser Counsel for Applicant 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
August 10,1981
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