ML20010G509

Supplemental Response to Applicant Interrogatories & Requests for Document Production (Set 1) Directed to Joint Intervenors.Certificate of Svc Encl.Related Correspondence

ML20010G509
Person / Time
Site:	Callaway
Issue date:	09/10/1981
From:	Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY
To:	UNION ELECTRIC CO.
References
ISSUANCES-OL, NUDOCS 8109220071
Download: ML20010G509 (5)

Text

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UNITED STATES OF AMERICA DED NUCLEAR REGULATORY COMMISSION

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UNION ELECTRIC COMPANY (Callaway Plant, Unit 1)

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Docket No. STN 50-483-pOf C

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'm SEP2 219815 p SiipPLEMENTAL RESPONSE TO APPLICANT'S S " E V37 *3 -

INTERROGATORIES AND REQUESTS FOR DOCUMEN'l\V N

f PRODUCTION (SET. NO.1) TO JOINT INTERVENORS I : \ \ h, g 7 Joint Intervenors submit the following Supplemental Re N6 Applicant's Interrogatories and Requests for Document Production (Set No.1) to Joint Intervenors. All documents identified, unless otherwise indicated, are in the possession and/or control of Kenneth M. Chackes, Attorney for Joint Intervenors and will be made available for inspection and/or copying upon retsonable request.

CONTENTION NO. I 1 A-9. (a) This was communicated orally to Kay Drey from construction workers, a former UE Quality Control Engineer, a former Radiographer at the Callaway Plant, and NRC Inspectors.

Appilcant's answer and objection to Joint Intervenors' Interrogatory 8 (First Set), and the 6000 documents referred to in the objection.

(b) Documents include those listed in (a), above, s.nd:

NCR 2-8031-C-B and associated surveillance reports ULNRC-238 D503 3 BLSM-6708 /

. PQWP-175 8109220071 810910 PDR ADOCK 05000483 G PDR

____ __ _.____ - . ~ - - . _ _ _ . _ _ . _ _ _ _ _ _ - _ , _ _ _ _ _ _ _ . . ~ . . _ _ _ _ - - .

Bechtel Meraorandum 10/28/77, to G. Westoff from R.D. Chappell Corrective Acthn Report No. 2-0059-C dated 9/6/77 Attachment B (dated 6/27/77) to NCR 2-1193-C-B i (c) Objected to.

l (d) None.

IB-9. (d) Objected to.

(e) None. d i

1D-6. (b) The following is substituted for the answer to Interrogatory ID-6(b):

l The very fact that requirements for concrete cover were r either ignored or grossly misunderstood indicates a failure of the quality assurance program. Even after the NRC Indicated to the Applicant that allegations about the improper installation of

, reinforcing steel and the resulting substandard concrete coverage l

were under investigation numerous instances of failure to adhere to proper construction practices and Appendix B criteria were found. See NRC Report Nos. 50-483/77-11, pp. 9-11, and 50-483/78-01, pp. 9-10.

CONTENTION NO. 2 C-1. (a) See Supplemental Answer to NRC Interrogatory Q-3(a) and (b).

(b) See (a), above.

(c) Objected to.

, (d) None. .

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! C-2. See Supplemental Answer to NRC Interrogatory Q-3(c).

C-3. See Supplemental Answer to NRC Interrogatory Q-3(e).

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C-4. Joint Intervenors have no responsive information beyond that contained .

I in Supplemental Answer to NRC Interrogatory Q-3.

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q C-5. No.

C-6. No.

C-7. (1) Radionuclides such as Cs137, accumulate at or near the outfall pipe of a nuclear power plant. Dredging and/or flooding would cause resuspension of these materials. The U.S. Army Corps of Engineers has conducted dredging operations in the Missouri River and such operations reasonably can be expected to occur again.

(2) Radiological Surveillance Studies, EPA: (a) Haddom Neck EPA-520/3-74-007 (1974) and (b) Yankee Row RD77-1 (1971).

(3) None.

C-8. Three nuclear power plants discharge into the Missouri River or a tributary thereof: Fort Calhoun, in Nebraska; Cooper, at Brownville, Nebraska; and Ft. St. Vrain, at Platteville, Colorado. In addition, active and abandoned uranium mining and milling sites along the river and its tributaries all release radioactive contaminants into the river upstream of the Callaway Plant Site.

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~3 Kenneth M. Chackes, attorney for Joint Intervenors Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance, and authorized as their agent for the purpose of answering the above interrogatories, hereby states to the best of his knowledge, information and belief that the responses provided above ve true and contain such information as is presently available to Joint Intervenors.

Kenneth M.Chackes

. :::D's~ b km Subscribed and sworn to before me this /c7 day of September,1981,

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Notary ~ Pug '

g My Commission Expires: 6 (d k CHACKES AND HOARE Kenneth M. Chackes

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Attorneys for Joint Intervenors 314 North Broadway St. Louis, MO 63102 314/241-7961

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

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(Callaway Plant, Unit 1) )

J CERTIFICATE OF SERVICE I hereby certify that copies of the Supplemental Response to Applicant's Interrogatories and Request for Document Production (Set. No.1) to Joint Intervenors have been served on the following by deposit in the United States mail this lith day of September,1981.

James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036  ;

Docketing and Service Section Office of the Secretary U.S. iidelear Regulatory Commission Washington, D.C. 20555 , )

i Roy P. Lessy, Jr., Esq. 1 1

Office of the Executive Legal Director l U.S. Nuclear Regulatory Commission i Washington, D.C. 20555

& 1,.,b ek Kenneth M. Chackes CHACKES AND HOARE

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