ML20031H548
| ML20031H548 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/20/1981 |
| From: | Churchill B SHAW, PITTMAN, POTTS & TROWBRIDGE, WISCONSIN ELECTRIC POWER CO. |
| To: | WISCONSIN'S ENVIRONMENTAL DECADE |
| References | |
| NUDOCS 8110280105 | |
| Download: ML20031H548 (10) | |
Text
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d USGG 0 0 g g $0) M P b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g-35,5, r D$O Before the Atomic Safety and Licensing Boar y,/
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WISCONSIN ELECTRIC POWER COMPANY
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Docket Nos. 50-266
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50-301 S
8[(,1_., i) 9 (Point Beach Nuclear Plant,
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(OL Amendment)
Units 1 and 2)
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,w; OCT 2 71981-D} e g :'j g * "
c LICENSEE'S INTERROGATORIES AND REQUEST FOR PRODUCTION \\
OF DOCUMENTS TO INTERVENOR DECADE RELATIVE TO NA
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SLEEVING DEMONSTRATION PROGRAM I
These Interrogatories and Request for Production of Documents are filed by the Wisconsin Electric Power Company
" Licensee") pursuant to the Board's October 13, 1981 Memorandum and Order Concerning The Admission of A Party and Its Conten-tions
(" Memorandum and Order Concerning Admission"), the Board's October 15, 1981 Memorandum and Order Setting Agenda and Rules For October 29-30 Hearing (" Memorandum and Order Setting Agenda"), and the Nuclear Regulatory Commission's Rules of Practice.
They are directed to Intervenor Wisconsin's Environmental Decade, Inc.
(" Decade") and pertain to the issues raised by Decade in its Contentions 3, 4,
5 and 7, as admitted at page 6 of the Memorandum and Order Concerning Admission, as well as to any other issues which Decade timely raises, as 63 S
those issues relate to interim operation of Point Beach Unit 1 with up to six steam generator tubes sleeved rather than
/l plugged.
8110280105 811020 DR ADOCK 05000266 PDR
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b The Interrogatories submitted herein are filed pursuant to 10 C.F.R. S 2.740b which requires that the Interrogatories be answered separately and fully in writing under oath or affirmation.
In accorda ce with the Board's ruling during the October 20, 1981 Special Prehearing Conference Call, responses are due in the hands of Licensee no later than 9:30 a.m. on October 27, 1981.
The Interrogatories are intended to be continuing in nature and the answers must be immediately supplemented or amended, as appropriate, should Decade obtain any new or differing information responsive to the Interrogatories.
For purposes of these Interrogatories, the term
" document (s)" means all writings and records of every type in the possession, control or custtdy of Decade or Decade's attorney (s), including, but not limited to, memoranda, corre-spondence, reports, surveys, tabulations, charts, books, pamphlets, photcgraphs, 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 Decade.
For purposes of these Interrogatories, a document shall be deemed to be within the " control" of Decade or Decade's ati rney(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.
I When identification of a document is requested, briefly describe the document, i.e.,
letter, memorandum, book, 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.
The Request for Production of Documents is filed pursuant to 10 CFR S 2.741, which requires that Decade' produce and either furnish copies of or permit Licensee to inspect and copy any documents responsive to the request and,which are in the possession, custody or control of Decade.
The Request for Production of Documents is also continuing in nature and Decade must produce immediately any additional documents it obtains which are responsive to the Request.
INTERROGATORIES Contention 3 (Brazing) 1.
(a)
State the substance of the facts and opinions to which each person you intend to call as a witness on Contention 3 at the hearing to be convened on October 29, 1981 is expected to testify.
(b)
State a summary of the grounds for such opinions, and identify all documents upon which each such person relies to substantiate such opinions.
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The purpose of this Interrogatory is to clarify the scope of i
contention 3 and to ascertain the factual bases for each element of Contention 3, so Licensee can adequately prepare its response to the issue for presentation at the hearing to be
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convened on October 29, 1981.
2.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee and/or the NRC Staff on Contention 3 at the hearing to be convened on October 29, 1981^.
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See purpose statement for Interrogatory No. 1.
Contention 4 (Environment in Annulus Between Tube and Sleeve) 3.
(a)
State the substance of the facts and opinions to which each person you intend to call as a witness on Contention 4 at the hearing to be convened on October 29, i
1981 is expected to testify.
(b)
State a summary of the grounds for such opinions, and identify all documents upon which each such person relies to substantiate such opinions.
The purpose of this Interrogatory is to-clarify the scope of Contention 4 and to ascertain the factual bases for each element of Contention 4, so Licensee can adequately prepare its response to the issue for presentation at the hearing to be convened on October 29, 1981.,
4.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee and/or the NRC Staff on Contention 4 at the hearing to be convened on October 29,'1981.
See purpose statement for Interrogatory No. 3.
Contention 5 (Interpretation of Eddy Current Test Results) 5.
(a)
State the substance of the facts and opinions to which each person you intend to call as a witness on Contention 5 at the hearing to.be convened on October 29, 1981 is expected to testify.
(b)
State a summary of the grounds for such opinions, and identify all documents upon which each such person relies to substantiate such opinions.
The purpose of this Interrogatory is to clarify the scope of Contention 5 and to ascertain the factual bases for each element of Contention 5, so Licensee can adequately prepare its response to the issue for presentation at the hearing to be convened on October 29, 1981.
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6.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensea and/or the NRC Staff on Contention 5 at the hearing to be convened on October 29, 1981.,-
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See purpose statement for Interrogatory No. 5.
Contention 7 (Quality Assurance) 7.
(a)
State the substance of the facts and op,inions to which each. person you intend to call.as a witness on Contention 7 at the hearing to be convened en October 29, 1981 is expected to testify.
(b)
State a summary of the grounds for such opinions, and identify all documents upon which each such person relies to substantiate such opinions.
The purpose of this Interrogatory is to clarify the scope of Contention 7 and to ascertain the factual bases for each element of Contention 7, so Licensee can adequately prepare its response tc the issue for presentation at the hearing to be convened on October 29, 1981.
8.
Identify all documents, including ell relevant page citations, which you intend to use during your cross-examination of witr. esses presented by Licensee and/or the NRC Staff on Contention 7 at the hearing to be convened on October 29, 1981.
1 See purpose statement for Interrogatory No. 7.
Other Issues 9.
(a)
State the substance of the facts and opinions to which each other person you intend to call as a witness at the hearing to be convened on October 29, 1981 is expected to testify. l
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(b)
State a summary of the grounds for such opinions, and identify all documents upon which each such person relies to substantiate such opinions.
The purpose of this Interrogatory is to clarif;r the scope of such other issues and to ascertain the factual bases for each element of any such issues, so Licensee can adequately prepare its response to such issues for presentation at the heering to be convened on October 29, 1981.
10.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee and/or the NRC Staff on each such issue at the hearing to be convened on October 29, 1981.
See purpose statement for Interrogatory No. 9.
REQUEST FOR PRODUCTION OF DOCUMENTS Licensee requests that Decade 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 David K.
Porter at the Wisconsin Electric Power Company or at a place mutually convenient to the parties, not later than 9:30 a.m. on October 27, 1981.
The term " document (s)" means all writings and records of every type in the possession, control or custody of Decade or of Decade's 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 or any kind.
" Document (s)" shall also mean' copies of documents even though' the originals thereof are not in the possession, custody, or control of Decade.
A document shall be deemed to be within the " control" of Decade or Decade's 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 posses'sion thereof.
Licensee requests that Decade produce each and every a
document identified or described in the answers to the above Interrogatories 1 through 10.
Respectfully submitted, SHAW, P TMAN, POTTS & T RCWBRIDGE
(
By L
s-Bdde W. OtrafcM1 Delissa A. Ridgway Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
October 20, 1981 t
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Before the Atomic Safety and Licensing Board In the Matter of
)
)
WISCONSIN ELECTRIC POWER COMPANY ) Docket Nos. 50-266
)
50-301 (Point Beach Nuclear Plant,
) (OL Amendment)
Units 1 and 2)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Licensee's Interrogatories and Regh,.ist For Production of Documents To Intervenor Decade Relative To Sleeving Demonstration Program" were this day served, by' deposit in the U.S. Mail, first class, postage prepaid, to all those on the attached service list, except that Decade has been served by deposit with Federal Express, this 20th day of October, 1981.
b enMin V T3elissa % Ridewa$
f Dated:
October 20, 1981
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Board In-the Matter of
)
)
WISCONSIN ELECTRIC POWER COMPANY
)
Docket Nos.,50-266
-)
50-301 (Point Beach Nuclear Plant,
)
( L Amendment)
O Units 1 and 2)
)
SERVICE LIST Peter B.
Bloch, Chairman Charles A. Barth, Esquire Atomic Safety and Licensing Office of the Executive Board Panel Legal Directoe' O.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Hugh C. Paxton Kathleen M. Falk, Esquire 1229 - 41st Street Wisconsin's Environmental Los Alamos, New Mexico 87544 Decade.
114 North Carroll Street' Dr. Jerry R.
Kline-Suite 208 Atomic Safety and Licensing Madison, Wisconsin 53703 Board Panel Stuart A. Treby, Esquire U.S. Nuclear Regulatory Office f the Executive Commission Legal i
Washington,.D.C.
20555 g,
c Regulatory Atomic Safety and Licensing Wa h g
n D.C.
20555 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel IT; S. Nuclear Regulatory Commission Washington, D.C..
20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555
,