ML20031G889
| ML20031G889 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/15/1981 |
| From: | Churchill B CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | SUNFLOWER ALLIANCE |
| Shared Package | |
| ML20031G886 | List: |
| References | |
| NUDOCS 8110260151 | |
| Download: ML20031G889 (30) | |
Text
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g L M E: cG = z::y; z ;c3 UNITED STATES OPAMERICA-yQ U[$
f NUCLEAR REGULATORY COMMISSION t
kb SEP 19190l >'
Before the Atomic Safety and Licensing Board 3 t' '"0 :n@l /
tm4 a san 2 3
In the Matter of
)
CLEVELAND ELECTRIC ILLUMINATING
)
Docket Nos. 50-440 4
COMPANY, et al.
)
50e441
)
(Perry Nuclear Power Plant
)
(Operating License)
Units 1 and 2)
)
APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENORS SUNFLOWER ALLIANCE, INC., ET AL. (FIRST SET)
These Interrogatories and' Request for Production of U
Documents are filed by the Cleveland Electric Illuminating i
Company et al.,
(" Applicants") pursuant to the Atomic Safety i
l and Licensing Board's ("the Board") Special Prehearing
]
Conference Memorandum and Order Concerning Party Status, Motions to Dismiss And To Stay, The Admissibility of Contentions, And The Adoption of Special Discovery Procedures, dated July 28, 1981 ("SPC Memorandum and Order"), the Board's Memorandum and Order dated September 9, 1981, and the Nuclear Regulatory Commicsion's Rule of Practice.
The interrogatories and document requests are directed to Intervenors Sunflower Alliance, Inc., et. al. and pertain to one or more of the seven issues specified on pages 97 and 98 of the SPC Memorandum and Order, as modified by the September 9 Memorandum and Order.
The Interrogatories submitted herein are filed pursuant to 10 CFR S 2.740b which requires that the Interrogatories be answered separately and fully in writing 8dj0260151811015 ADOCK 05000440 G
under oath or-affirmation, within 14 days after service.
The Interrogatories are intended to be continuing in nature and the answers must be immediately supplemented or amended, as appropriate, should the Intervenors obtain any new or differing information responsive to the Interrogatories.
The Request for Production of Documents is filed pursuant to 10 CFR S 2.741, which requires that the Intervenors produce and either furnish copies of or permit Applicants to inspect and copy any documents responsive to the request and which are in the possession, custody or control of the Intervenors.
The Request for Production of Documents is also continuing in nature and the Intervenors must produce immediately any additional documents they obtain which are responsive to the Request.
For purposes of these Interrogatories, the term
" document (s)" means all 7 h ings and records of every type in the possession, con *e4 o,
custody of the Intervenors or of the Intervenors' attorhey(s,. including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, truascripts, voice recordings, and all other writings or recordings of any kind.
" Document (s)" shall also mean copies of documents even though the originals thereof are'not in the possession, custody, or control of the Intervenors. -.
t For purposes of these Interrogatories, a document shall be deemed to be within the " control" of the Intervenors or of the Intervenors' attorney (s) if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.
When identification of a document '3 requested, briefly describe the document; i.e.,
letter, memorandum, bcok, pamphlet, etc., and state the following information as appli-cable to the particular document: name, title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.
INTERROGATORIES Issue No. 1 (Applicants' Emeroency Evacuation Plans) 1.
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged in Issue No.
1.
The purpose of this Interrogatory is to identify persons knowledgeable about Issue No. 1 for possible future deposi-tions.
2.
(a)
State the name, eddress, title, employer and educational and professional qualifications of each pert'n you intend to call as an expert witness on Issue No.
- 1. _
-- _ -__ __________________________j
(b)
State the subject matter on which each such person is expected to testify.
(c)
State the substance of the facts and opinions to which each such person is expected to testify.
(d)
Sta';e a summary of the grounds for such opinions, and identify all documents upon which such person relies to substantiate such opinions.
See purpose statement for Interrogatory No. 1.
The purpose of this Interrogatory is also to clarify the scope of Issue No. 1 and to ascertain the factual bases which support each element of Issue No. 1 so that the Applicants adequately can prepare their response to the Issue.
3.
Identify all documents in your possession, custody or control, including all relevant page citations, pertaining to the subject matter of Issue No.
1.
See purpose statement for Interrogatory No.
2.
4.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Issue No. 1 or which you intend to use during your cross-examination of witnesses presented by Applicants and/or the NRC on Issue No. 1.
See purpose statement for Interrogatory No.
2.
l 5.
For each of the followir.g claims, explain i
l precisely (i) what aspects of Applicants' emergency evacuation plans you allege are inadequate or deficient, (ii) explain (
precisely why they are inadequate or deficient, (iii) explain precisely how the inadequacy or deficiency affects the plan, (iv) state in detail the factual bases for your answer, and (v) specifically identify the NRC regulations or other NRC regula-tory requirements with which you allege Applicants' evacuation plans do not comply.
(a)
Applicants' emergency evacuation plans contain inadequate notification plans.
See Petition for Leave to Intervene of Sunflower Alliance, Inc. et al., dated March 15, 1981, at 4 (" Sunflower Petition").
(b)
Applicants' emergency evacuation plans contain deficiencies in radiation exposure measurement techni-ques.
See id.
(c)
Applicants' emergency evacuation plans have insufficient practical workability.
See id.
(d)
Applicants' emergency evacuation plans have inadequate notification of and information to media and residents within the 10 and 50 mile radii.
See id.
(e)
Local volunteer fire fighters might prove inadequate in assisting in the evacuation of people who do not own automobiles.
See SPC Memorandum and Order, at 20.
(f)
The City of Mentor has a road pattern which would impede ef ficient evacuation.
See id.
(g)
There are too few school buses available for evacuation in the Emergency Planning Zone ("EPZ").
See id.
i l
[ l
(h)
There are too few tow trucks adequately to serve the EPZ.
See id.
See purpose statement for Interrogatory No.
2.
6.
Explain precisely and in detail (i) each and every specific aspect of Applicants' emergency evacuation plans not identified in response to Interrogatory No. 5 which you allege to be inadequate or deficient, (ii) explain why each such aspect of the plans is inadequate or deficient, (iii) explain how the inadequacy or deficiency affects the plans, (iv) state in detail the factual bases for your answers, and (v) specifically identify the NRC regulations or other regula-tory requirements with which you allege Applicants' emergency evacuation plans do not comply.
See purpose statement for Interrogatory No.
2.
7.
For each response to Interrogatory Nos. 5(a) through 5(h) and 6:
(a)
Identi.fy all documents, including all relevant page citations, which you rely upon to support each of your claims; (b)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each of your claims; and (c)
State the name of each person you intend to call as a witness to support each claim.
l.-
1 See purpose statement for Interrogatory No. 2.
1 8.
(a)
Is it your contention that Applicants have i
not complied with the joint Commission-Federal-Energy i
Management Agency Criteria for Preparation and Evaluation,of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654, FEMA-REP-1; Rev~1) at 56, 58 (criteria 8 and 9)?
(b)
If the answer to (a) above is affirmative, i
identify each specific instance in which you allege the Applicants have failed to comply and state in detail the factual basis for your claim.
(c)
Identify all documents, including all relevant page citations, which you rely on to support this claim.
(d)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge for the factual baJes for this claim.
(e)
State the name of cach person you intend to call as a witness to support this claim.
See purpose statement for Interrogatory No. 2.
Issue No. 2 (Financial Responsibility)
[
9.
State the name, present or last known address, and present or last known employer of each person known to you l l
I
to have first-hand knowledge of the facts alleged in Issue No.
2.
The purpose of this Interrogatory is to identify persons kncJledgeable about Issue No. 2 for possible future deposi-tions.
10.
(a)
State the name, address, title, employer and educational and professional qualifications of each person you intend to call as a witness on Issue No.
2.
(b)
State the subject matter on which each such person is expected to testify.
(c)
State the substance of the facts and opinions to which each such person is expected to testify.
(d)
State a summary of the grounds for such opinions, and identify all documents upon which such person relies to substantiate such opinions.
See purpose statement for Interrogatory No. 9.
The purpose of this Interrogatory is also to clarify the scope of Issue No. 2 and to ascertain the factual bases which support each element of Issue No. 2 so that Applicants adequately can prepare their response to the Issue.
11.
Identify all documents in your possession, custody or control, including all relevant page citations, pertaining to the subject matter of Issue No.
2.
See purpose statement of Interrogatory No. 10.
12.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during,
l l
this proceeding to support Issue No. 2 or which you intend to i
use during your cross-examination of witnesses presented by Applicant and/or the NRC on Issue No. 2.
See purpose statement for Interrogatory No. 10.
13.
(a)
Do you contend that Applicents will be unable financially to operate Units 1 and 2 of the Plant during the time they are selling electricity from the Plant?
( b ',
If the answer to the preceding inter-rogatory is affirmative or other than negative, state the factual bases for your claim.
(c)
Identify all documents you rely on to support this claim.
(d)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for this claim.
(e)
State the name of each person you intend to call as a witness to support each claim.
See purpost statement for Interrogatory No. 10.
14.
(a)
State the factual basis for your claims that the Cleveland Electric Illuminating Company ("CEI") had
" considerable difficulties in cash flow," Transcript of Special Prehearing Conference, dated June 2, 1981
("Tr."), at 238, and that "there is an extremely strong posatbility that the capital structure of [CEI] is beginning to suffer."
Id. at 240. _
(b)
Identify all documents you rely on to support your claims.
(c)
State the name, present or last known address, and present or last known employer of each person kr.own to have first-hand knowledge of the factual bases for your claims.
(d)
State the name of aach person you intend to i
call as a witness to support your claims.
See purpose statement for Interrogatory No. 10.
15.
(a)
Explain precisely how the alleged cash flow problems and the alleged weak capital structure described in the answer to Interrogatory No. 14(a) have or will will affect Applicants' ability to cover the estimated costs of operation of Units 1 and/or 2 of the Plant.
(b)
Identify all documents you rely on to support your claim.
(c)
State the name, present or last known employer.of each person known to you to have first-hand knowledge of the factual bases for your claim.
(d)
State the name of each person you intend to call as a witness to support each claim-i See purpose statement for Interrogatory No. 10.
16.
Explain precisely and give specific examples of
" reasonably foreseeable contingencies" as used in Issue No.
2.
See purpose statement for Interrogatory No. 10. L
17.
(a)
State the legal basis for your contention that Applicants must be prepared to show at the time of filing the application for an Operating License for the Plant that they possess or reasonably may obtain funds te cover the costs of contingencies described in the answer to the preceding interrogatory.
(b)
Identify all documents, including all relevant page citations, which you rely on to support your claim.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the f actual bases for your claim.
(d)
State the name of each person you intend to call as a witness to support your claim.
See purpose statement for Interrogatory No. 10.
18.
(a)
State your estimate of the amount of funds Applicants must show they possess or reasonably may obtain to cover the costs of each contingency described in your answer to Interrogatory No. 16.
e (b)
Identify all documents, including all relevant page citations, which you rely on to support your claims.
(c)
State the name, present or last known address, and present or last known employer of each person p i i
-m
1 known to you to have first-hand knowledge of the f actual bases for your claims.
(d)
State the name of each person you intend to call as a witness to support your claims.-
See purpose statement for Interrogatory No. 10.
19.
(a)
Do you contend that Applicants will be unable to cover the costs of one or more of the contingencies described in the answer to Interrogatory No. 16?
(b)
If your answer to the preceding inter-rogatory is affirmative or other than negative, state each contingency for which Applicants will be unable to cover the costs and state the fartual bases for your claims.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each of your claims.
(d)
State the name of each person you intend to call as a witness to support each of your claims.
See purpose statements for Interrogatory No. 10.
Issue No. 3 (Quality Assurance Program) 20.
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged in Issue No.
3.
The purpose of this Interrogatory is to identify persons i
knowledgeable about Issue No. 3 for possible future deposi-tions.
21.
(a)
State the name, address, title, employer and educational and professional qualifications of each person yot intend to call as a witness on Issue No.
3.
(b)
State the subject matter on which each such person is expected to testify.
(c)
State the substance of the facts and opinions to which each such person is ex1.ected to testify.
(d)
State a summary of the grounds for such opinions, and identify all documents upon which such person relies to substantiate such opinions.
See purpose statement for Interrogatory No. 20.
The purpose of this Interrogatory is also to clarify the scope of Issue
'?.
3 and to ascertain the factual bases which support each element of Issue No. 3 so that Applicants adequately can prepare their response to the Issue.
22.
Identify all documents in your possession, custody or control, including relevant page citations, pertain-ing to the subject matter of Issue No. 3.
See purpose state-ment for Interrogatory No. 21.
23.
Identify all documents, including relevant page citations, which you intend to offer as exhibits during this proceeding to support Issue No. 3 or which you intend to use during your cross-examination of witnesses presented by Applicants and/or f5e NRC on Issue No. 3.
See purpose statement for Intes sgatory No. 21.
24.
(a)
Do you contend that the voluntary stop vork order issued in February, 1978 (documented in an Immediate Action Letter dated Februar-f 8, 1978 from the NRC to CEI) indicated one or more defects or inadequacies in Applicants' quality assurance program?
(b)
If the answer to the preceding inter-rogatory is affirmative or other than negative, describe what aspects of Applicants' quality assurance program allegedly were def ective or inadequate, why they were inadequate or defective, and state the factual bases for each claim.
(c)
Identify all documents, including all relevant page citations, which you rely on to support each 1
claim.
(d)
State the name, presen-
>r last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each of your claims.
(e)
State the name of each person you intend to call as a witness to support each claim.
See purpose statement for Interrogatory No. 21.
23.
(a)
Do you contend that any additional defects or inadequailes directly related to the stop work order issued in February, 1978 and not described in the answer to i 1
Interrogatory No. 24(b) allegedly existed in Applicants' quality assurance program?
(b)
If the answer to the preceding inter-rogatory is affirmative or other than nege'ive, describe what aspects of Applicants' quality assurance program allegedly were defective or inadequate, why t..ey were defective or inadequate, what time period each such detect or inadequacy existed, and state the factual booes for your claims.
(c)
Identify all documents you rely on to support these claims.
(d)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each of these claims.
(e)
State the name of each person you intend to call as a witness to support each of these claims.
See purpose statements for Interrogatory No. 21.
26.
(a)
If the answers to Interrogatory Nos. 24(a) or 25(a) are affirmative or c-.ier than negative,-is it your contention that any such defects or inadequacies still exist in
(
Applicants' quality assurance program as of the date of your answers to these interrogatories?
(b)
If the answer to the preceding inter-rogatory is affirmative or other than negative, state precisely what aspects of Applicanus' quality assurance program allegedly are still defective or inadequate, why they are defective or inadequate, and state the factual bases for your claims.
(c)
Identify all documents, including all relevant page citations, which you rely on to support each claim.
(d)
State the name, present or last known address, and pcesent or last known employer of each per?..on known to you to hava first-hand knowledge of the factual bases for each of your claims.
(e)
State the name of each person you intend to call as a witness to support each claim.
See purpose statement for Interrogatory No. 21.
27.
(a)
If the answers to Interrogatory Nos. 24(a) or 25(a) are affirmative or other than negative, is it your l
contention that any such defects or inadequacies have caused or resulted in construction deficiencies that can be characterized as " unsafe construction"?
(b)
If the answe: to the preceding inter-rogatory is affirmative or other than negative describe precisely the nature and location of each such alleged con-struction deficiency in Units 1 and/or 2 of the Plant and state the factual bases for each of your claims.
(c)
Explain precisely how each such alleged construction defect has arisen from a defect or inadequacy in Applicants' quality assurance program which was ind'.cated in the NRC's February 8, 1978 Immediate Action Latter.
(d)
Identify all documents, including all relevant page citations, which you rely on to support each allegation of construction deficiencies and your claims that such deficiencies were caused by a defect or inadequacy in Applicants' quality asaurance program which was indicated in the NRC's February 8, 1978 Immediate Action Letter.
(e)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each of your claims.
(f)
State the name of each person you intend to call as a witness to support each of your claims.
See purpose stat ement for Interrogatory No. 21.
28.
If your answer to Interrogatory No. 27(a) above is affirmative or other than negative:
(a)
Identify all such construction deficier.cies which have been corrected.
(b)
Identify all such construction deficiencies which have not been corrected, and the reasons why they have not been corrected.
(c)
Identify each document, including all relevant page citations, which you rely on for your answers to Interrogatories (a) and (b) above.
(d)
State the name, present or last known address, and present or last known employer cf each person l l
anown to you to have first-nand knowledge of the factual bases for each of your claims.
J (e)
State the name of each person you intend to call as a witness to support each of your claims.
See purpose statement for Interrogatory No. 21.
Issue No. 4 (Testing of Emergency Core Cooling System ("ECCS"))
29.
State the present or Iast known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged in Issue No.
4.
The purpose of this Interrogatory is to identify persons knowledgeable about Issue No. 4 for possible future deposi-tions.
30.
(a)
State the name, address, title, employer and educational and professional qualifications of each person you intend to call as a witness on Issue No.
4.
(b)
State the subject matter on which each such person is expected to testify.
(c)
State the substance of the facts and opinions to which each such person is expected to testify.
(d)
State a summary of the grounds for such opinions, and identify all documents upon whien such persor relies to substantiate such opinions.
See purpose statement for Interrogatory No. 29.
The purpose of this Interrogatory is also to identify with _.
particularity the legal and factual bases which support Issue No. 4 so Applicants adequately can prepare their response to the Issue.
31.
Identify all documents in your possession, custody or control, including all relevant page citations, ertaining to the subject matter of Issue No. 4.
See purpose f
statement for Interrogatory No. 30.
32.
Identify all documents which you intend to offer as exhibits during this proceeding to support Issue No. 4 or which you intend to use during your cross-examination of witnesses presented by Applicants and/or the NRC on Issue No.
4.
See purpose statement for Interrogatory No. 30.
33.
(a)
State the factual bases for your claim that the Plant is a prototype pl.'nt.
(b)
Identify all documents you rely on to support this claim.
(c)
State the name, present or last known address, and present or last known employer of each person known tc you to have first-hand knowledge of the factual bases for this claim.
(d)
State the name of each retson you intend to call as a witness to support this claim.
See purpose statement for Interrogatory No. 30.
34.
(a)
What is a " full-scale 30 degree sector steam test"?
(b)
What is the purpose of conducting a full-scale 30 degree sector steam test?
(c)
Identify all boiling water nuclear reactors in this country which have been required to perform a full-scale 30 degree sector steam test before Leing authorized for operation by NRC.
(d)
Provide the factual bases for each of your answers to Interrogatories 34(a)-(c) above.
(e)
Identify each document, including all relevant page citations, which you rely on to support these answers.
(f)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases of these answers.
(g)
State the name of each person you intend to call as a witness to support this claim.
See purpose statement for Interrogatory No. 30.
35.
(a)
Do you contend that Applicants must perform a full-scale 30 degree sector steam test before the ECCS or the reactor at the Plant can be operated safely?
(b)
If your answer to the preceding inter-rogatory is negative, explain the reasons why Applicants must perform such a test prior to licensing of the Plant and state the factual and legal bases for your claim.
2 (c)
If your answer to Interrogatory No. 35(a) is affirmative or other than negative, state the factual and legal bases for your claim.
(d)
Identify all documents, including all relevant page citations, which you rely on to support the answers to Interrogatory Nos. 35(a)-(c).
(e)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases to support the answers to Interrogatory Nos. 35 ( a)--( c).
(f)
State the name of each person you intend to call aE a witness to support your ancwers to Interrogatory Nos.
35(a)-(c).
See purpose statement for Interrogatory No. 30.
36.
(a)
Is it your contention that NRC regulations require Applicants to conduct a full-scale 30 degree sector steam test before the reactor can be authorized for operation?
(b)
If the answer to the preceding inter-regatory above is affirmative or other than negative, provide the precise citation to the provisions of 10 CFR S 50.46, f
Appendix K of 10 CFR Part 50, or any other NRC regulation which requires Applicants to conduct a full-scale 30 degree sector steam test.
Provide an explanation for your answer.
(c)
State the name, present or last known address, and present or last known employer of each person.
known to you to have first-hand knowledge of the f actual bases to support the answers to Interrogatory No. 36(a) and (b).
(d)
State the name of each person you intend to call as a witness to support your answers to Interrogatory Nos.
36(a) and (b).
See purpose statement for Interrogatory No. 30.
Issue No. 5 (Scram Discharge volume) 37.
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged in Issue No.
5.
Tne purpose of this Interrogatory is to identify persons knowledgeable about Issue No. 5 for possible future deposi-tions.
38.
(a)
State the name, title, employer and educational and professional qualifications of each person you intend to call as a witness on Issue No.
5.
(b)
State the subject matter on which each such person is expected to testify.
(c)
State the substance of the facts and opinions to which each such person is expected to testify.
(d)
State a summary of the grounds for such opinions, and identify all documents upc1 which such person relies to substantiate such opinions.
1 See purpose statement for Interrogatory No. 37.
The purpose of this Interrogatory is also to ascertain with particularity the factual bases which support Issue No. 5 so that Applicants adequately can respond to the Issue.
39.
Identify all documents in your possession, custody or control, including all relevant page citations, pertaining to the subject matter of Issue No. 5.
See purpose statement for Interrogatory No. 38.
40.
Identify all documents which you intend to offer as exhibits during this proceeding to support Issue No. 5 or which you intend to use during your cross-examination of witnesses presented by Applicants and/or the NRC on Issue !;o.
5.
See purpose statement for Interrogatory No. 38.
41.
(a)
State the factual bases for your claim that
" Applicants' reactor trip system is not protected against a pipe break to the scram discharge volumes from the hydraulic control units"; OCRE Supplement, item 13.
(b)
Identify all documents you rely on to support this claim.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each claim.
(d)
State the name of each person you intend to call as a witness to support this claim.
See purpose statement for Interrogatory No. 38.
42.
(a)
Explain how Applicants allegedly must demonstrate the safety of the Plant's reactor from an.
l unrecoverable losa of coolant accident resulting from a pipe break in the scram discharge volume and state the factual bsses for your claim.
(b)
Identify all documents, including all relevant page citations, which you rely on to support this claim.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of :the factual bases for this claim.
(d)
State the name of each person you intend to call as a witness to support this claim.
Ste purpose statement for Interrogatory No. 38.
Issue No. 6 (Anticipa1ed Transient Without Scram ("ATWS"))
43.
State the name, present or last known address, and present or last known employer of each persoa known to you to have first-hand knowledge of the facts alleged in Issue No.
6.
The purpose of this Inteirogatory is to identify persons knowledgeable about Issue No. 6 for possible future deposi-tions.
44.
(a)
State the name, address, title, employer and educational and professional qualifications of each person you intend to call as an expert witness on Issue No. 6.
(b)
State the subject matter on which each such person is expected to testify. --
~
(c)
State the substance of the facts and opinions to which each such person is expected to testify.
(d)
State a summary of the grounds for such opinions, and identify all documents upon which such person relies to substantiate suca opinions.
See purpose statement for Interrogatory No. 43.
The purpose of this Interrogatory is also to ascertain the factual bases which support Issue No. 6 so that. Applicants adequately can prepare their response to the Issue.
45.
Identify all documents in your possession, cus-tody or control, including all relevant page citations, pertaining to the subject matter of Issue No. 6.
See purpose statement for Interrogatory No. 44.
46.
Identify all documents which you intend to offer as exhibits during this proceeding to support Issue No. 6 or which you intend to use during your cross-examination of witnesses presented by Applicants and/or the NRC on Issue No.
6.
See purpose statec.ent for Interrogatory No. 44.
47.
(a)
State the factual bases for your claim that Applicants should install an automated (as opposed to manual) standby liquid control system to mitigate the consequences of an AT4S.
(b)
Identify all documents, including all relevant. page citations, which you rely on to support this claim..
(c)
State the name, present or last known address, ar.d present or last known employer of each person known to you to have first-hand knowledge of the f actual bases for this clcim.
i 4
(d)
State the name of each person you intend to call as a witness to suppor t your claim.
See purpose statements for Interrogatory No. 44.
48.
(a)
Is it your contention that che use of a manual standby liquid control system provides insufficient prchection against an ATWS?
(b)
If the answer to the preceding inter-rogatory is affirmative or other than negative, state the f actual bases for your claim.
(c)
Identify all documents, including all relevant page citations, which you rely on to support this claim.
(d)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for this claim.
(e)
State the name of each person you intend to call as a witness to support your claim.
Sge purpose statement for Interrogatory No. 44.
49.
(a)
Do you contend that Applicants' FSAR indicates that there is insufficient protection at the Plant
against a serious ATWS; i.e.,
an ATWS more potentially dangerous than a small malfunction reported in a Licensee Event Report?
(b)
If the answer to the preceding inter-rogatory is affirmative, specify the section(s) of the FSAR on which you are rely.
(c)
State the name, present or last known zddress, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for this claim.
(d)
State the name of each person you intend to call as a witness to support this claim.
See purpose statement for Interrogatory No. 44.
50.
Specify:
(a)
Approximately how many serious transients occur per year in new reactors; and (b)
Approximately how many serious transients occurred in each of the years 1978 through 1980.
See purpose statement for Interrogatory No. 44.
51.
For each answer to Interrogatory Nos. 50(a) and (b).
(a)
State the factual bases for your claims; (b)
Identify nil documents, including all relevant page citations, which you rely on to support your claims;.
1 1
i (c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for your claims; and (d)
State the name of each person you intend to call as a witness to support your claims.
See purpose statement for Interrogatory No. 44.
General Interrogatories Pertaining to Issue Nos. 1 through 6 52.
State the name, title or position, address and employer of each person who provided information used in preparing responses to any of the foregoing interrogatories.
The purpose of this Interrogatory is to identify persons knowledgeable about each issue for possible future depositions.
53.
For each person identified in response to the preceding interrogatory, state the numbers of the interroga-tories for which information was supplied.
See purpose statement for Interrogatory No. 52.
54.
State the name, title or position, address and employer of each person who searched for documents in order to respond to any of the foregoing requests for identification of documents.
See purpose statement for Interrogatory No. 52.
55.
For each person identified in response to the preceding interrogatory, state the numbers of the interroga-tories for which the search was conducted and the location
- l l
where the search was conducted.
See purpose statement for Interrogatory No. 52.
56.
Identify any written or recorded statement of any individual pertaining to the subject matter of Issues 1 through 6, not previously identified in response to the foregoing interrogatories.
See purpose statement for Interrogatory No. 52.
REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that Intervenors 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, at the office of Lawrence O. Beck at the Cleveland Electric Illuminating Company, or at a place mutually convenient to the parties.
The term " document (s)" means all writings and records of every type in the possession, control or custody of the Intervenors or of the Intervenors attorney (s), including, but not limited to, memoranda, correspondence, reports, surveys,
~ tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings or recordings of any kind.
" Document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of the Intervenors.
A document shall be deemed to be within the " control" of the Intervenors or of the Intervenors' attorney (s) if they have ownership, pc-assion or custody of the document or copy thereof, or have the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.
Applicants request that Intervenors produce each and every document identified or described in the answers to the above Interrogatories 1 through 56.
1 Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE i
By e- -
7 BCIt6e W.
Ch_urchill Jay E.
Silberg Bonnie S. Gottlieb Counsel for Applicant; 1800 M Street, N.W.
Washington, D.C.
2003 (202) 822-1000 Dated:
October 15, 1981.
,