ML20052D349

Interrogatories & Request for Production of Documents,Second Set.Certificate of Svc Encl

ML20052D349
Person / Time
Site:	Perry
Issue date:	05/03/1982
From:	Willmore R CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	SUNFLOWER ALLIANCE
References
NUDOCS 8205060452
Download: ML20052D349 (10)

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May 3, 19E2 M7 -A my 1

UNITED STATES OF AMERICA  ;

t NUCLEAR REGULATORY COMMISSION

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O Before the Atomic Safety and Licensing Board ,n f9 /

D 7 In the Matter of ) ( , d .c-j;f-f3) 9 jjz CLEVELAND ELECTRIC ILLUMINATING

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p y f1 COMPANY, et al. ) Do c k e t No s . 50 44 0_-,ct,s '

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) 50 441'Ii~

(Perry Nuclear Power Plant ) (Operating LicenseT~~

Units 1 and 2) )

APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENORS SUNFLOWER ALLIANCE, INC., ET AL. (SECOND SET)

These Interrogatories and Request for Production of Documents are filed by The Cleveland Electric Illuminating Company, et al., (" Applicants") pursuant to the Atomic Safety and Licensing Board's ("the Board") Special Prehearing Conference Memorandum and Order, LBP-81-24, 14 NRC 175 (July 28, 1981), as amended by the Board by its Memorandum and Order of September 9, 1981, and the Nuclear Regulatory Commission's l ("NRC") Rules of Practice. The Interrogatories and document 1)6o3 3

l requests are directed to Intervenors Sunflower Allia'nce, Inc.,

j et al., and pertain to Issue #4 admitted in the Board's Special

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Prehearing Conference Memorandum and Order, LBP-81-24, 14 NRC at 215-16.

8205060452 820503 PDR ADOCK 05000440 0 PDR

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• The Interregatories submitted herein, are filed pursuant to 10 CFR S 2.740b, which requires that the.' Interrogatories be answered separately and fully in writing under oath or affirma-tion, 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 diffbring information responsive to the Interrogatories.

The Request for Production of Documents is filed pursuant l

l 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 l

Request for Production of Documents is also continuing in nature and the Intervenors must produce immediately any i 1

additional documents they obtain which are responsive to the i Request.

For purposes of these Interrogatories, the term "docu-ment (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 4

I the originals thereof are not in the possession, custody, or control of the Intervenors. l For purposes of these Interrogatories, a document shall be i 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 froa- any person or public or private entity having physical possession thereof.

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, I 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 purpose of these Interrogatories is to determine whether Intervenors have any objections to the 30* Sector Steam Methodology Confirmation Tests performed by General Electric in 1979, or any basis for believing that Applicants have not met their commitment to confirm General Electric's methodology

! through full scale 30* sector steam tests. The Interrogatories i

also seek to determine whether Intervenors have any basis for disagreeing with the NRC's approval of the 30' Sector Steam Methodology Confirmation Tests. The General Electric document

. (NEDO-24712) and the two NRC letters referred to in the.

l Interrogatories were supplied to Intervenors with " Applicants' l

l Answers to Sunflower Alliance, Inc. First Round Discovery

! Requests," dated February 5, 1982.

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INTERROGATORIES

1. State with specificity any objections you have to the 30* Sector Steam Methodology Confirmation Tests performed by General Electric in 1979, as described in General Electric document NEDO-24712 (" Core Spray Design Methodology Confirmation Tests," August, 1979).- Also state with spe-cificity the bases for your objections.

2. If you have stated any objections in response to Interrogatory #1, identify and provide all documents upon which you base your objections. If your objections are not based on any documents, or are based only in part on any documents, identify with specificity both the nature and the source of the information upon which you base your objections.

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3. If you have identified any person in response to Interrogatory #2, whether or not you intend to call such person as a witness, state the name, address, title, employer and educational and professional qualifications of that person.

4. State with specificity any reasons you have to believe that the 30' Sector Steam Methodology Confirmation Tests performed by General Electric in 1979, as described in

-General Electric document NEDO-24712 (" Core Spray Design

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i 0 l Methodology Confirmation Tests," August, 1979) have .not met the l commitment set forth in Applicants' Final ~ Safety Analysis Report, S1.5.1.2, to confirm through full scale 30' sector steam tests the methodology of General Electric's program to study BWR/6 core spray distributions. Also state with spe-cificity the bases for your reasons.

5. If you have stated ~any reasons in response to Interrogatory #4, identify and provide all documents upon which you base your objections. If-your objections are not based on  ;

'any documents, or are based only in part on any documents, identify with specificity both the nature and the source of the information upon which you base your reasons.

6. If you have identified any person in response to Interrogatory #5, whether or not you intend to call such person as a witness, state the name, address, title, employer and  !

educational and professional qualifications of that person.

7. State with specificity any disagreements you have with any assertion, conclusion or any other statement made in l the NRC letter of February 3, 1978, from Darrell G. Eisenhut and Denwood F. Ross to G. G. Sherwood. Also state with l specificity the bases for your disagreements.

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8. If you have stated any disagreements in response to Interrogatory #7, identify and provide all documents upon which you base your objections. If your objections are not based on any documents, or are based only in part on any documents, identify with specificity both the nature and the source of the inforination upon which you base your disagreements.

9. If you have identified any person in response to Interrogatory #8, whether or not you intend to call such person as a witness, state the name, address, title, employer and

'ducational e and professional qualifications of that person.

10. State with specificity any disagreements you have with any assertion, conclusion or any other statement made in the NRC letter of January 30, 1981, from Robert L. Tedesco to G. G. Sherwood. Also state with specificity the bases for your disagreements.

11. If you have stated any disagreements in response to Interrogatory $10, identify and provide all documents upon which you base your objections. If your objections are not based on any documents, or are based only in part on any

- documents, identify with specificity both the nature.and.the source of the information upon which you base your disagreements.

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12. If you have identified any person in response to Interrogatory ill, whether or not you intend to call such r.

person as a witness, state the name, address, title, employer .

and educational and professional qualifications of that person. t Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

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By: / -

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' Jay' B./Silbb fg , P.C.

Robert L. Willmore i Counsel for Applicants [

1800 M Street, N.W. ,

Washington, D.C. 20036 ,

(202) 822-1000 ,

i May 3, 1982 t

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c UNITED STATES OF AMERIC]A NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ~) ,

ILLUMINATING COMPANY, et al. ) Docket Nos. 50-440

) 50-441 (Perry Nuclear Power Plant, . , ) (Operating License)

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Interrogatories And Request For Production Of Documents To Inter-venors Sunflower Alliance, Inc., et al. (Second Set) ", were served by deposit in the U. S. Mail, first class, postage pre-paid, this 3rd day of May, 1982, to all those on the attached Service List.

Robert L. Willmore Dated: May 3, 1982 O

.. l UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ,

~ ILLUMINATING COMPANY, et al. )

50-441  !

). ,

(Perry Nuclear Power Plant, )

Units 1 and 2 ) .

SERVICE LIST e

Peter B. Bloch, Chairman

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Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel .

U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l' Washington, D.C. 20555 .

Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section  !

Atomic Safety and Licensing Board- Office of the Secretary l U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory. Commission L Washington, D.C. 20555 Washington, D.C. 20555 James H. Thessin, Esquire Mr. Frederick J. Shon Atomic Safety and Licensing Board Office of the Executive t

_U,. S . Nuclear Regulatory Commission Legal Director  ;

U.S. Nuclear. Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 i i Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim Representative U.S. Nuclear Regulatory Commissica 8275 Munson Avenue Washington,, D.C. 20555 Mentor, Ohio 44060 Dr. John H. Buck Daniel D. Wilt, Esquire ,

Atomic Safety and Licensing Wegman, Hessler & Vanderburg  ;

Appeal Board Suite 102 l i

U.S. Nuclear Regulatory Commission 7301 Chippewa Road Washington, D.C. 20555 Brecksville, Ohio 44141

. Gary J. Edles, Esquire Terry Lodge, Esquire Atomic Safety and Licensing 915 Spitzer Buildin'g  ;

r Appeal Board Toledo, Ohio 43604

, I U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Tod J. Kenney 228 South College, Apt. A Atomic Safety and Licensing Bowling Green, Ohio 43402 Board Panel l U.S. Nuclear Regulatory Commission Washington, D.C. 20555

The Cleveland Electric .

Illuminating Company, et al. .

Service List Page Two Donald.T. Ezzone, Esquire Assistant Prosecuting Attorney Lake County Administration Center -

105 Center Street

• Painesville, Ohio 44077 John G. Cardinal, Esquire Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047 O

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