ML20010C190
| ML20010C190 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/13/1981 |
| From: | Sherwin Turk NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | JOINT INTERVENORS - WATERFORD |
| Shared Package | |
| ML20010C188 | List: |
| References | |
| NUDOCS 8108190229 | |
| Download: ML20010C190 (15) | |
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8/13/81 UNITED STATES OF AMERICA 14UCLEAR REGULATORY COM111SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
LOUISIAHA POWER Al40 LIGHT COMPANY Docket No. 50-382 (Waterford Steam Electric Station )
Unit 3)
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HRC STAFF'S THIRD SET OF INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM, JOINT INTERVEGORS (SAVE OUR WETLANDS, INC. AND OYSTERSHELL ALLIANCE, INC.)
The HRC Staff (" Staff") hereby requests that Intervenors Save Our Wetlands, Inc. and Oystershell Alliance, Inc. (" Joint Intervenors"), pursuant to 10 CFR 69 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following Interrogatcries and produce or make available for inspection and copying, all documentary material identified in the responses to interrogatories below. As provided in paragraph 3 of the " Stipulation on Dis-covery Schedule" (" Stipulation)", forwarded to the Atomic Safety and Licensing Board ("Licensir.g Board") on September 25, 1979, these interrogatories relate to new information contained in the Staff's Safety Evaluation Report (SER) relevant to allt*ied contentions.
Pursuant to pargraph 5 of the Stipulation, these interrogatories must be answered within 30 days, and any objections to the interrogetories must be served within 15 days.
All references provided in response to these interrogatories are to be identified by author, title, date of publication and publisher if the reference is published; if any such reference is not published, it is to be identified 0108190229 810813 PDR ADOCK 05000382 PDR-
by author, title, date it was written, the qualifications of the author rele-vant to this proceeding, and the location where a copy of the document may be obtained.
All persons named in response to these interrogatories are to be identi-fied by name, address, employer, position, education, professional qualifica-tions, and publications related to their views concerning the subject matter of this proceeding.
IliTERR0 GAT 0 RIES Oli C0!iTEf4TIO!I 17 17-1.
State whether' Joint Intervenors contend that the Staff's review and analysis (SER 913.3.1) of the Applicant's Emergency Plan, as revised in -
FSAR Amendrent 17 submitted on April 27, 1981, fails to adequately resolve the issue (s) raised by the Joint Intervenors in Contention 17.
17-2.
If the answer to Interrogatory 17-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
17-3.
If the answer to Interrogatory 17-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention along with a summary of their views or positions relevant to the subject matter of your contention.
17-4.
If the answer to Interrogatory 17-1 is affirmative, identify i
all persons whom Joint Intervenors intend to call as witnesses in this pro-
,j ceeding, along with a suntaary of their views or positions relevant to the subject matter of your contention.
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17-5.
If the answer to Interrogatory 17-1 is affirmative, identify dll document,ary or other material that Joint Intervenors intend to use in this proceeding to support this contentfore and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
INTERR0GATORIES ON, CONTENTION 19 19-1.
State whether Joint Intervenors c9ntend that the solutions identified in the Staff's SER (5 4.2.2.4) fail to adequately resolve the issue (s) raised by Contention 19 19-2.
If the answer to Interrogatory 19-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
19-3.
If the answer to Interrogatory 19-1 is affirmative, identify all person "non whom Joint Intervenors rely in support of this contention, along with a sumary of their views or positions relevant to the subject matter of this contention.
19-4.
If the answer to Interrogatory 19-1 is affirmative, identify all persons whom Joint Interveners intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
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. 19-5.
If the ansver to Interrogatory 19-1 is affirmative, identify all decumentary or other material that Joint Intervenors intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
INTERR0GATORIES ON CONTENTION 20 20-1.
State whether Joint Intervenors contend that the Staff's SER (611.2) fails to adequately resolve the issue (s) raised by Contention 20.
20-2.
If the answer to Interrogatory 20-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
20-3.
If the answer to Interrogatory 20-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
20-4.
If the answer to Interrogatory 20-1 is affirmative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
20-5.
If the answer to Interrogatory 20-1 is affirmative, identify all documentary or other material that Joint Intervenors intend to use in this proceeding to support this contention and that you intend to offer as exhibits
or this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
INTERR0GATDRIES ON CONTENTION 21 21-1.
State whether Joint Intervenors contend that the Staff's SER (592.4,3.4,7.4) fails to adequately resolve the issue (s) raised by Conten-tion 21.
21-2.
If the answer to Interrogatory 21-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
21-3.
If the answer to Interrogatory 21-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
21-4.
If the answer to Interrogatory 21-1 is affirmative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
21-5.
If the answer to Interrogatory 21-1 is affirmative, identify all documentary or other material that Joint Intervenors intend to use in tnis proceeding to support this contention and that you intend to offer as exhibits l
on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
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INTERR0GATORIES ON CONTENTION 22 22-1.
State whether Joint Intervenors contend that the Staff's SER (9 3.8) fails to adequately resolve the issue (s) raised by Contention 22.
22-2.
If the answer to Interrogatory 22-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
22-3.
If the answer to Interrogatory 22-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
22-4.
If the answer to Interrogatory 22-1 is affirmative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
22-5.
If the answer to Interrogatery 22-1 is affirmative, identify all documentary or other material that Joint Intervenors intend to use in this proceeding to sup'.o et this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
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INTERROGATORIES ON CONTENTION 23 23-1.
State whether Joint Intervenors contend that the Staff's SER (55 2.5, 3.2, 3.4, 3.7) fails to adequately resolve the issue (s) raised by Contention 23.
23-2.
If the answer to Interrogatory 23-1 is affirmative, state ir, detail the reasons and basis for Joint Intervenors' contention.
23-3.
If the answer to Interrogatory 23-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
23-4.
If the answer to Interrogatory 23-1 is affirmative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
23-5.
If the answer to Interrogatory 23-1 is affirmative, identify all documentary or other material that Joint Intervenors intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
INTERROG/.f0 RIES ON CONTENTION 24 24-1.
State whether Joint Intervenors contend that the Staff's SER (557.5,7.6,22.2) fails to adequately resolve the issue (s) raised by Conten-tion 24.
24-2.
If the answer to Interrogatory 24-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
24-3.
If the answer to Interrogatory 24-1 is affirmative, identify all persons upon whom Joint Interver. ors rely in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
24-4.
If the answer to Interrogatory 24-1 is affirmative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your c.ontention.
24-5.
If the answer to Interrogatory 24-1 is affirmative, identify all documentary or other material that Joint Intervenors intend to use in this i
proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses l
presented by the Applicant and/or Staff, i
INTERR0GATORIES ON CONTENTION 25 25-1.
State whether Joint Intervenors contend that the Staff's SER
($ ?2.2) fails to adequately resolve the issue (s) raised by Contention 25.
I 25-2.
If the answer to Interrogatory 25-1 is affirmative, state in detail th9 reasons and basis for Joint Intervenors' contention.
25-3.
If the answer to Interrogatory 25-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject matter of this contention.
25-4.
If the answer to Interrogatory 25-1 is affiniative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
1 25-5.
If the answer to Interrogatory 25-1 is affirmative, identify all documentary or other material that Joint Intervenors intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses i
presented by the Applicant and/or Staff.
INTE2K0GATORIES ON CONTENTION 26 26-1.
State whether Joint Intervenors contend that the Staff's SER (9513.3,22.2) fails to adeouately resolve the issue (s) raised by Contention 26.
26-2.
If the answer to Interrogatory 26-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
26-3.
If the answer to Interrogatory 26-1 is affirmative, identify all persons upon whan Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject atter of this contention.
26-4.
If the answer to Interrogatory 26-1 is affirmative, identify ali persons whom Joint Intervenors intend to call as witnesses in this pr0ceeding, along with a sumr.ary of their views or positions relevant to the subject matter of your contention.
26-5.
If the answer to Interrogatory 26-1 is affinmative, identify all documentary or other material that Joint Intervenors intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refe* to during your cross-exaaination of witnesses presented by the Applicant and/or Staff.
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s INTERROGATOIRES ON CONTENTION 27 27-1.
State whether Joint Intervenors contend that the Staff's SER (95 12.3, 22.2) fails to adequately resolve the issue (s) raised by Contention 27.
27-2.
If the answer to Interrogatory 2/-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
27-3.
If the answer to Interrogatory 27-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject F.atter of this contention.
27-4.
If the ar swer to Interrogatory 27-1 is affirmative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
27-5.
If the answer to Interrogatory 27-1 is affirmative, identify all docunentary or other material that Joint Intervenors intend to use in this proceeding to support this contention and that you inter.1 to offer as exhibits on this contention or to refer to during your cross-examinatfor; of witnesses presented by the Applicant and/or Staff.
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INTERR0GATORIES ON CONTENTION 28 28-1.
State whether Joint Intervenors contend that the Staff's SER (59 6.2, 22.2) fails to adequately resolve the issue (s) raised by Contention 28.
t 28-2.
If the answer to Interrogatory 28-1 is affirmative, state in detail the reasons and basis for Joint Intervenors' contention.
28-3.
If the answer to Interrogatory 28-1 is affirmative, identify all persons upon whom Joint Intervenors rely in support of this contention, along with a summary of their views or positions relevant to the subject matter of i
this contention.
l 28-4.
If the answer to Interrogatory 28-1 is affirmative, identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contention.
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28-5.
If the answer to Interrogatory 28-1 is affirmative, identify cll f
documentary or other material that Joint Intervenors intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses prese.1ted by the Applicant and/or Staff.
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INTERR0GATORIES ON CONTENTION 29 29-1.
State whether the Staff's SER (9 22.2) sufficiently identifies each "HRC-mandated TMI-based chaage," the cost of which Joint Intervenors contend should be considered by the Applicant as stated in Contention 29.
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29-2(a).
If the answer to Interrogatory 29-1 is affirmative, identify each such "HRC-mandated TMI-based change," the cost of which Joint Intervenors contend should be considered by the Applicant.
29-2(b).
If the answer ~to Interrogatory 29-1 is negative, identify all "HRC-mandated THI-based changes " the cost of which Joint Intervenors contend should be considered by the Applicant.
29-3.
State in detail the reasons and basis.~or Joint Intervenors' contention as set forth in respoisse to Ir?,errogatories 29-1 and 29-2.
29-4.
Identify all persons upon whom Joint Intervenors rely in support of this contention, along with a suncary of their views or positions relevant to the subject matter of this contention.
29-5.
Identify all persons whom Joint Intervenors intend to call as witnesses in this proceeding, along with a summary of their views or positions relevant to the subject matter of your contenticq.
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29-6.
Identify all documentary or other material that Joint Inter-venors intend to use in this proceeding to support this contention and that you intend to offer as exhibits on this contention or to refer to during your cross-examination of witnesses presented by the Applicant and/or Staff.
Respectfully submitted, v E r&
Sherwin E. Turk Counsel for NRC Staff Dated at Bethesda, Maryland this 13th day of August, 1981 f
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UNITED STATES OF AMERICA HULLEA.( REGULATORY COM. MISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CERTIFICATE OF SERVICE 4'
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I hereby certify Mat copies of "NRC STAFF'S 111IRD SET OF INIERROGATORI$$ Mo)
AND REQUEST FOR DOCUBENIS FRCA!, IDUSIANA CONSUbER'S IZAGUE, INC." and "NRC STAFF'S THIRD SET OF INIERROGATORIES 10, MO REQUEST FOR DOCUSENTS FROM, JOINT INIERVEf0RS (SAFE OUR WETIANDS, INC. AND OYSTERSHEIl AILIANCE, INC.)" in the above-captioned proceeding have been served on the following by deposit in UnitedStatesmail,firstclass,or,asindicatedbyanasterisk,throupi deposit in the Nuclear Regulatory Comission's internal mail systs, this 13th day of August,1981:
Sheldon J. Wolfe, Esq., Chiirman*
Lyman L. Jones, Jr., Esq Adainistrative Judge Gillespie & Jones Atomic Safety and Licensing Board P.O. Box 9216 U.S. Nuclear Regulatory Commission Metairie, LA 70005 Washington, DC 20555 Luke B. Fontana Esq.
Dr. Walter H. Jcrdan 824 Esplanade Avenue Administrative Judge New Orleans, LA 70116 881 West Guter Drive Oak Ridge, TN 37330 Malcolm Stevenson, Esq.
Monroc & Lemann Dr. Harry Foreman 1424 Whitney Building Administrative Judge New Orleans, LA 70130 Box 395, Mayo University of Minnesota Atomic Safety and Licensing Board Minneapolis, Mti 55455 Panel
- U.S. Nuclear Regulatory Comission E. Blake, Esq.
Washington, DC 20555 George F. Trowbridge, Esq.
Shaw, Pittman, Poti.s & Trowbridge Atomic Safety and Licensing' Appeal 1800 M Street, N.W.
Panel (5)*
Washington, DC 20036 U.S. Huclear Regulatory Commission Washington, DC 20555 Stephen M. Irving, Esq.
535 North 6th Street Docketing and Service Section (1)*
Baton Rouge, LA 70802 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 b-
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Shenvin E. Turk Counsel for NRC Staff
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