ML20040D569
| ML20040D569 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 01/25/1982 |
| From: | Farris J CITIZENS ACTION FOR SAFE ENERGY |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-CP, NUDOCS 8202020030 | |
| Download: ML20040D569 (7) | |
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UNITED STATES OF AMERICA f
NUCLEAR. REGULATORY COMMISSION.
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,'BEFORE THE-ATOMIC SAFETY AND LICENSING BOA p
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.In the Matter of the Application of.
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-Associated Electric Cooperative, Inc.
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. hA Public Service Company of Oklahoma,
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and
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Western Farmers Electric Cooperative
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STN.50-556CP (Black Fox Units:1 and 2)
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STN 50-557CP 4
INTERVENORS' INTERROGATORIES AND' REQUEST FOR PRODUCTION OF DOCUMENTS TO NRC STAFF l
Pursuant to 10 C.F.R..S 2.740b, Intervenors direct the i
following interrogatories to the. NRC. Staff pursuant tog the
= Atomic Safety and Li~ censing Board's (the " Board")' Order of October 14, 1981, and Order of December'17, 1981, (following prehearing conferen'ce).
Further, pursuant'to 10 C.F.R. 5 2.'741, the Intervenors hereby. request that the NRC_ Staff i
furnish copies of or permit'the Intervenors to inspect and-copy any documents responsive to the following requests and i
and which are in the possession, custody or control of the NRC Staff.
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Both the Interrogatories and.the Requst for Documents e
are continuing in nature.
The NRC Staff must supplement or
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amend, as appropriate, their Answers, should.the NRC Staff obtain any new or differing information responsive to the of J
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Interrogatories; and must also produce any additional documents they obtain which are responsive to the requests.
When identification of a document is requested, describe the document by title, author, addressee, date, and relevant page citations.
For the purposes of these Interrogatories and Requests, the term " contention" means a subject matter admitted by the Board in its Order of December 17, 1981, whether originally advanced as a contention by Intervenors or as a Motion by one of the parties to reopen the closed evidentiary record.
GENERAL QUESTIONS:
(a)
Each question is to be answered in five parts as follows:
(i)
Provide the direct answer to the question.
(ii)
Identify all documents and studies, and the particulars thereef, relied upon by the Staff, now or in the past, which serve as the basis for the answer.
In lieu thereof, at Staff's option, a copy of such document and study may be attached to the answer.
(iii)
Identify all documents and studies, and the particular parts thereof, examined but not relied upon by the Staff, which pertain to the subject matter ques-tioned.
In lieu thereof, at Staff's option, a copy of each such document and study may be attached to the answer.
(iv)
Explain whether the Staff and/or any inde-pendent contractor are presently engaged in or intend 2
f s.
to. engage in further research or work which may bear on the issues covered in the interrogatory.
If so, please identify such 'research or work and the person (s) responsible therefor.
(v) Identify the expert (s), if any, whom the Staff intends to have testify on the subject matter covered in the interrogatory.
State the qualifications of each such expert.
(2) Present a summary of each expert's proposed testimony on each Staff contention.
(3) Identify all cases in which any such expert has previously testi-fled and state the subject matter of such testimony.
(b)
Answer each of the following five preliminary questions for every contention:
(i)
Explain the present Staff position on each of the Intervenors' contentions.
(ii)
Does the current position differ from the position of the Staff in any prior proceedings?
If so, identify the proceeding (s), explain the prior position, and explain the basis for the change in position.
(iii)
Identify any officers or employees of, or con-sultants to, the Staff who dissent from the present position on Intervenors' contentions.
(iv)
Identify the specific sections and page numbers of the PSAR for Black Fox Station and the NRC Staff's SER 3
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and SER Supplements for Black Fox Station which are relied upon in formulating the Staff's position on Intervenors' contentions.
(v)
Identify all sections and page numbers of the PSAR, SER and SER Supplements which contain subject matter pertaining to Intervenors' contentions.
SPECIFIC INTERROGATORIES AND DOCUMENT REQUESTS:
Motion to Reopen - IGSCC 1.
Please provide a list of all piping systems to be used atLBlack Fox classified as important to safety where 304 stainless material will still be used.
2.
Please provide all background information and other information as specified in the five-part lists concerning the background information, analyses, etc., that led to the l
decision to replace the recirculation piping material.
i 3.
Please provide any probabilistic studies supporting l
l the change.
4.
Please provide reports of environmental testing of 316K stainless material relevant to its selection for this application.
5.
Please provide information on any future changes to the PSAR that you anticipate will be required as a result of this change.
4
Motion to Reopen - Load Combination 1.
Please provide a copy of NUREG-04 84, Revision 1.
2.
Please provide all information relevant to PSO or Black & Veatch studies or analyses of possible changes that may result from the change in load combination methodology and the impact of that change on the Black Fox plant.
3.
Please provide any anticipated changes that may be required to the PSAR that has not already been accomplished in Amendment 17.
4.
Please provide details of any exemptions that may be required in order for the plant to be in compliance with the leak testing requirements as specified in Appendix J.
Respectfully submitted, FELDMAN, HALL, FRANDEN & WOODARD f
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By oseph R.
Far'ris l
816 terprise Building Tulsa, OK 74103 l
ATTORNEYS FOR INTERVENORS i
l
(
s-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of the Application of
)
Public Service Company of Oklahoma,
)
Associated Electric Cooperative, Inc.
)
and
)
Western Farmers Electric Cooperative
)
Docket Nos.
)
STN 50-556CP (Black Fox Units 1 and 2)
)
STN 50-557CP CERTIFICATE OF SERVICE I, Joseph R. Farris, one of the attorneys for Citizens Action for Safe Energy (C.A.S.E.), certify that copies of the following:
"Intervenors' Interrogatories and Request for Production of Documents to Applicants" have been served on the persons shown on the attached list by United States Mail, postage prepaid, this SS74 day of TMugv 1982.
/
l l
Farris GosepM R.
l Date:
January 25, 1982 i
(
Sheldon J. Wolfe, Esq.
Mr. Gregory _ Minor Atomi~c Safety and Licensing MIIB Technical Associates Board Panel 1723 Ilamiton Ave.
United States Nuclear Suite K Regulatory Commission San Jose, CA 95125 Washington, D.C.
20555 Andrew T.
Dalton, Esq.
Mr. Frederick J.
Shon Attorney at Law Atomic Safety and Licensing 14 37 South Main Street Board Panel Room 302 United States Nuclear Tulsa, Oklahoma 74119 Regulatory Commission Washington, D.C.
20555 Mrs. Ilene Younghein 3900 Cashion Place Dr. Paul W.
Purdom Oklahoma City, OK 73112
- Director, Environmental Studies Group Mrs. Carrie Dickerson Drexel University Citizens Action for 32nd and Chestnut Streets Safe Energy Philadelphia, PA 19104 P.
O.
Box 924 Claremore, Oklahoma 74017 Docketing and Service Section Office of the Secretary of the Joseph Gallo, Esq.
Commission Martha E.
Gibbs United States Nuclear Frederick C. Williams Regulatory Commission Isham, Lincoln & Beale Washington, D.
C.
20555 1120 Connecticut Ave.,N.W.
(3 copies)
Washington, D.C.
20036 Mr. Clyde Wisner Michael I. Miller NRC Region 4 Phillip P.
Steptoe Public Affairs Officer Isham, Lincoln &_Beale 611 Ryan Plaza Dr.,
Suite 1000 One First National Plaza, Arlington, Texas 76011 Suite 4200 Chicago, Ill. 60603 James II. Thessin, Esq.
Office of the Executive Mr. Maynard liuman Legal Director General Manager U.S. Nuclear Regulatory Comm.
Western Farmers Electric Coop.
Washington, D.C.
20555 P.
O.
Box 429 Anadarko, Oklahoma 73005 Dr. John Zink Public Service Company of Okla.
Mr. Gerald F.
Diddle P. O. Box 201 Associated Electric Tulsa, Oklahoma 74102 Cooperative, Inc.
P.
O.
Box 754 Ilon. Michael Bardrick Springfie'a, Missouri 65801 Assistant Attorney General State of Oklahoma Mr. Lawrence Burrell State Capitol Building Rt. 1, Box 197 oklahoma City, Oklahoma 73105 Fairview, Oklahoma 73737
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