ML20010B178
| ML20010B178 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/06/1981 |
| From: | Snapp B ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO. |
| To: | CITIZENS AGAINST NUCLEAR DANGERS |
| Shared Package | |
| ML20010B176 | List: |
| References | |
| NUDOCS 8108140187 | |
| Download: ML20010B178 (9) | |
Text
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PENNSYLVANIA POWER & LIGHT COMPANY )
) Docket Nos. 50-387 and ) 50-388
)
ALLEGHENY ELECTRIC COOPERATIVE, INC. )
)
(Susquehanna Steam Electric Station, )
. Units 1 and 2) )
APPLICANTS' INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO INTERVENOR CITIZENS AGAINST NUCLEAR DANGERS ON CHLORINE CONTENTION These Interrogatories and Requests for Production of Documents are filed pursuant to the Licensing Board's July 27, 1981 Memorandum and Order (Hearing Date and Prehearing Confer-ence Matters), which allowed for limited discovery from inter-venor Citizens Against Nuclear Dangers ("CAND") on two matters as to which new information has been submitted by CAND. These matters were the basis for the Board's partial denial of Appli-cants' motion for summary disposition of the chlorine portion of p Contentica 2 in the Board's Memorandum Order of March 16, 1981
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(LBP-81-8).
' The Interrogatories submitted herein are filed pursuant to i 10 CFR $2.740b which requires that the Interrogatories be answered separately and in writing under oath or affirmation. ,
The Interrogatories are intended to be continuing in. nature and '
the answers must be immediately supplemented or amended, as appropriato, should CAND obtain any new or differing information i responsive to the Interrogatories. y The Requests for Production of Documentr are filed pursuant to 10 CFR $2.741, which requires that CAND p.oduce and either furnish copies of or permit Applicants to inspect and copy any 9 u
documents responsive to the requests and which are in the possession, custody or control of C/ ND. The Requests for g 6
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an, production of Documents are also continuing in nature and CAND must produce immediately any additional documents it obtains which are responsive to the Requests.
As specified in the July 27, 1981 Memorandum and Order, responses to these Interrogatories and -Requests for Production of Documents are due ten (10) days from their receipt by CAND.
INTERROGATORIES
- 1. Do yr.u agree with the analysis of chlorine releases from the Susquehanna facility contained in Section 4.5.5 of the Final Environmental Statement for Susquehanna (NUREG-0564, dated June, 1981)?
If you do not, please state in which respects you disagree and reasons for your disagreement and their bases.
2.
Specify the daily amount of chlorine which you estimate will be discharged into the Susquehanna River by the Susquehanna facility during the facility's operation, and give the basis for your estimate.
3.
Specify your estimate of the concentration of chlorine in the Susquehanna River during operation of the Susquehanna facility:
- a. Immediately upstrean of the Susquehanna facility's discharge point; b.
Immediately downstream of the Susquehanna facility's discharge point;
- c. In the City of Danville water supply intake;
- d. In the City of L'anville drinking water system after water treatment.
4.
With respect to the ethanol production facility ("the ethanol facility") referred to in " Citizens Against Nuclear Dangers petition and Motions on Summary Disposition" dated i i
November 24, 1980 at p. 3 ("CAND petition"):
A. What is the precise location of the i' ethanol facility? '
- b. Who owns the ethanol facility?
c.
Has the design of the ethanol facility been completed? If not, what is the f n
status of the design?
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- d. 'Has financing been obtained for const. action of the ethanol . facility? If not waat fino cing for it?
is-the status of securing.
e.
Has construction of the ethanol facility If not, when is construction
.rted?
scheduled to start?
- f. When will the ethanol facility start operation?
g.
Has the owner of the ethanol facility applied to any Federal, State. or local agency.for a permit to operate'the facility?. If the answer.is in the affirmative, list each such application, giving the date in'which the application
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was filed, the agency with whom it was filed, the status of the application and any action taken by the agency with respect to the application.
- h. Describe briefly the operation of the' ethanol facility, including the nature of:
the process, the nature and amount of all 'I waste and by product materials that will be produced by -the facility, and the ' .
disposition of each of those waste and by-product materials.
1.
What do you-contend would.be the. nature
- and concentrations of these wastes and by product. materials immediately upstream 1 i
of the Susquehanna facility? ' .
5.
rogatory 4h, For - each waste product listed in the answer to Inter- f ij identify the " slime-forming biolife" whose growth would be stimulated by the product, i which such growth would be stimu' lated, and give_the rate ofdescribe the process b throug growth of biolife stimulated per unit concentration of the product. .
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- 6. 5 For each waste product listed in the answer to Interrogatory 4h, give the additional amount of chlorinesthat 1 will need.to be discharged into the river at the Susquehanna E E
facility to arrest the growth of . slime-forming biolife.
- 7. h Wi th respect to the studies published b r3 the- U.S. [j Council on' Environmental Quality'" Linking chlorinated drinking water and cancer", referred to in page 2 of the CAND petition: b a
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- a. State the title, author, date of publication, and document number and issuing agency (if any) of each such study.
- b. Identify the information contained in
'each such study that links chlorinated drinking water and cancer.
- c. State the quantitative relationship between the concentration of chlorine in drinkin.; water and the number of cancer cases produced.
- d. Identify the number of cancer cases per yea. which will be caused by chlorine in drinking water in the city of Danville during the operation of the Susquehanna facility and give the basis for your estimate.
- e. Identify the number of cancer cases per year which will be caused by chlorine in drinking water in the city.cf Danville and will be attributa' ale to the chlorine discharges from the Su squehanna facility and give the basis for your estimate.
- 8. Are your answers to Interrogatories 1-7 based upon one or more documents?l / If so:
. a. Identify each such document on which your answer is based.
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1/ Fcr the purpose of these interrogatories, " document" means all writings and records of every type in the possession, control, or custody of Intervenor, inclu/ y; but not limited-to memoranda, correspondence, reports, 'eys, tabulations, l charts, books, pamphlets, photographs. ., bulletins, i minutes, notes, diaries, speeches, ar ,, transcripts,
! and all other records, written, c'ect.2.61, mechanical or otherwise.
" Documents" shall also meah copies of documents even though the originals thereof are not in the possession, custody, or i
control of Intervenor.
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- b. Identify the information in each document on which your answer is based.
- c. Explain how such information provides a basis for your answer.
- 9. Are your answers to Interrogatories 1-7 based upon any type of study, calculation, or analysis? If so:
- a. Describe the nature of the study, calculation, or analysis and identify any documents which discuss or describe the study, calculation, or analysis,
- b. Who performed the study, calculation, or analysis?
- c. When and where was the study, calculation, or analysis performed?
- d. Describe in detail the information that 3 was studied, calculated, er analyzed.
- e. What were the results of such study, calculation, or analysis?
- f. Explain how such study, calculation, or analysis provides a basis for your answer.
- 10. Are your answers to Interrogatories 1-7 based upon research? If so;
- a. Describe all such research and identify each document discussing or describing such research.
- b. When and where was the research conducted?
- c. By whon was the research conducted?
- d. Explain how such-research provides a basis for your answer.
- 11. Are your answers to Interrogatories 1-7 based upon conversations, consultations, correspondence or any other type of communications with one or more individuals?. If so:
-G-a.
Identify by name and address each such individual.
b.
State the educational and professional background of each such individual, including occupation and institutional affiliations.
c.
Describe the nature of each communication with each such individual, when it occurred, and identify all other individuals involved.
d.
Describe the information received from each such individual and ex basis for your answer. plain how it provides a REQUEST FOR PRODUCTION OF DOCUllENTS Applicants request that CAND respond in writing to the following request for production of documents and produce the original or best copy of each of the documents requested below, on Bryanor A.before ten days of receipt thereof, at the office of Snapp, Esquire, Pennsylvania Power & Light Company, or at a place mutually convenient to the parties.
" Documents" means all writings and records of every type in the possession, control or custody of CAND, including but not limited to memocanda, correspondence, reports, surveys, tabula-tions, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, speeches, articles, transcripts and all other records, written, electrical, mechanical or otherwise.
" Documents" shall also mean copies of documents, even though the of originals thereof are not in possession, custody or control CAND.
Applicants request that CAND produce each and every document identified 1 through 12. or described in the answers to above Interrogatories Respectfully submitted, f
PENNSYLVANIA POWER & LIGHT COMPANY ALLEGHENY ELECTRIC COOPER "JVE, INC.
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By: . p vy&w .// / ,..--$,0 f Bryan A0 Snapp /~ 7 ounsel for Applic ::
7 in Two North Ninth S reet L Allentown, Pennsylvania August 6, 1981 18101
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY CONS 1ISSION
-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PENNSYLVANIA POWER 6 LIGHT COMPANY )
and ) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that the foregoing Applicants' Interrogatories and Reque~st for Production of Documents to Intervenor Citizens Against Nuclear-Dangers on Chlorine Contention was served on Thomas J. Halligan by personally handing him a copy at Pennsylvania Power 6 Light Company's offices located at 326 Adams Avenue, Scranton, Pennsylvania on August 6, 1981. Copies were served on the attached Service List by deposit in the United States Mail, First Class, postage-prepaid, on August 6, 1981.
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M777 Z -cd, B1yan Snapp' ' '
Dated: August 6, 1981 '
UNITED STATES OF AMERICA NUCLEAR REGULATORY COmdISSION "efore the ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PENNSYLVANIA POWER & LIGHT COMPANY )
/.nd )
) Docket Nos. 50-387
) 50-388
)
ALLEGHENY ELECTRIC COOPERA' RIVE, INC. )
(Susquehanna Steam Electric Station )
Units 1 and 2) )
SERVICE LIST Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ;
James P. Gleason, Esq., Chairman Administrative Judge ;
Atomic Safety and Licensing Board i 513 Gilmoure Drive ?
Silver Spring, Maryland 20001 E Idr. Glen O. Bright Administrative Judge i~
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 _
Dr. Paul N. Purdom Administrative Judge '
Atomic Safety and Licensing-Board 245 Gulph Hills Road Radnor, Pennsylvania 19087 g Atomic Safety and Licensing Board Panel ::.
U.S. Nuclear Regulatory Commission [f Washington, D.C. 20555
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Docketing and Service Section Office of the Secretary f:%
U.S. Nuclear Regulatory Commission -
Washington, D.C. 20555 D
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Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 I
Susquehanna Environmental Advocates c/o Gerald Schultz, Esq.
Post Office Box 1560 Wilkes-Barre, Pennsylvania 18703 Ms. Collcan Marsh Box 558 A, R.D. #4 Mt. Top, Pennsylvania 18707 Larry Chandler, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555 DeWitt C. Smith, Director Pennsylvania Emergency Management Agency Transportation & Safety Building Harrisburg, Pennsylvania 17120 Jessica H. Laverty, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,
Robert W. Adler, Esq.
Dept. of Environmental Resources Commonwealth of Pennsylvania 505 Executive House :
Post Office Box 2357 :
Harrisburg, Pennsylvania 17120 i r
Mr. Thomas M. Gerusky, Director E g
Bureau of Radiation Protection Department of Environmental Resources 0 Commonwealth of Pennsylvania ;
Post Office Box 2063 ?
Harrisburg, Pennsylvania 17120 [
C e
Atomic Safety and Licensing Appeal Board Panel ..
U.S. Nuclear Regulatory Commission (3 Washington, D. C. 20555 6h 3
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