ML20052E510
| ML20052E510 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/07/1982 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CAROLINA ENVIRONMENTAL STUDY GROUP |
| Shared Package | |
| ML20052E507 | List: |
| References | |
| NUDOCS 8205110178 | |
| Download: ML20052E510 (6) | |
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STAFF 5/7/82 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket Nos. 50-413
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50-414 (Catawba Nuclear Station,
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Units 1 and 2)
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NRC STAFF'S FIRST SET OF INTERR0GATORIES AND DOCUMENT PRODUCTION REQUESTS TO CAROLINA ENVIRONMENTAL STUDY GROUP In accordance with 10 CFR Sections 2.740, 2.740b and 2.741, the NRC Staff hereby serves Carolina Environmental Study Group (CESG) as an intervenor in the above-captioned proceeding with NRC Staff's First Set of Interrogatories and Document Requests to CESG. These interrogatories and document requests relate to CESG contentions 13 and 17 as conditionally admitted in the Licensing Board's Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference), dated March 5, 1982.
Each interrogatory shall be answered separately and fully in writing under oath or affirmation, and shall include all pertinent information available to the CESG, its officers, directors, members, employees, advisors, or counsel, based upon the personal knowledge of the person answering. Answers to these interrogatories are required to be served upon all parties to the proceeding within 14 days after service of the interrogatories. - By each request for production of documents, the NRC Staff seeks to inspect and copy pertinent documents which are in the possession, custody, or control of CESG, its officers, directors, members, employees, advisors or counsel.
e20511017e 820507 PDR ADOCK 05000 0
As used herein, the term " documents" shall include any writings, drawings, graphs, charts, and schedules, however produced; photographs or other pictorial representations; recordings and tapes, whether sound or visual; and data compilations of whatever form.
Each interrogatory should be answered in six parts as follows:
(1) Answer the direct question asked or provide the information requested (separately as to each subpart as applicable).
(2)
Identify fully any documents (a) used as the basis for the answer to the interrogatory or (b) related to the subject of the interrogatory upon which you intend to rely in establishing the pertinent contention.
(3) Give the name, address, occupation and employer of the person or persons (a) answering each interrogatory, or (b) who have served, presently serve, or it is anticipated will serve as consultants or advisors to CESG on the subject matter of the interrogatory.
(4)
Identify each person whom you expect to call as a witness to testify as to the issue addressed in the pertinent interrogatory. As to each such person, please state (a) the subject matter of his or her testimony and (b) the substance of the testimony.
(5)
Is the answer based on a calculation? If so, describe (a) the calculation, b) identify any documents setting forth such calculation, c) identify the person who performed each calculation, d) when it was performed, (e) each parameter used in such calculation, each value assigned to the parameters, and the source of your data, (f) the results of each calculation, and (g) how each calculation provides basis for the answers.
(6)
Is the answer based on conversations, consultations, correspondence or any other type of comunications with one or more individuals?
If so, (a) identify each such individual by name and address, (b) state the educational and professional background of each such individual, (c) describe the information received from such individual and its relation to your direct answer, (d) identify each writing or record related l
to each such conversation, consultation, correspondence or other communication with such individual.
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In addition, CESG is requested, pursuant to 10 CFR Section 2.740(e),
to supplement its responses as necessary with respect to the identity of each person expected to be called as an expert witness at the hearing in this proceeding, the subject matter on which he or she is expected to testify, and the substance of such testinony. Similarly, CESG is requested to amend its responses if CESG subsequently learns that any response made to the interrogatories herein was incorrect when made, or that the response though correct when made is no longer correct.
If the answer to any interrogatory or portion thereof is fully provided in a response to any other interrogatories which have been previously served in this proceeding, you may answer by so indicating, with specific reference to the portion of the interrogatory addressed in such other answers. You are requested, however, to answer the interrogatories below based on all information in your possession at the time of answering, including any information received subsequent to answering any other interrogatories.
INTERROGATORIES l
CESG Contention 13 1.
What do you mean by " irregularities in the welding practices" in Contention 137 2.
Identify each such " irregularity."
3.
Identify each such " welding practice."
4.
For each " irregularity" and " welding practice" identified in your answers to Interrogatories 2 and 3, state each fact, occurrence, report, deficiency or other information upon which it is based, by whom it was identified and/or reported, when it was identified, the specific location of the weld or place at which the practice occurred, the specific " safety-related systems" affected, to whom it was reported, and any action taken by any person to correct such
" irregularity" or " welding practice."
5.
Do you contend the welding practices at the Catawba facility are not in compliance with any NRC regulation or regulatory guide, or other standard?
6.
If your answer to Interrogatory 5 is yes, identify each such regulation, regulatory guide or other standard, the " welding practices" or " irregularities" which give rise to such non-compliance, the " safety-related systems" involved, and how "the public health and safety" will be endangered thereby.
. E CESG Contention 17 7.
What are the " effects" on the performance of the cool'ng tower system which form the basis for Contention 17?
8.
Describe fully the factual basis for each "effect" described in your answer to Interrogatory 7.
9.
Describe the health and safety concern (s) or impact (s) on the environment, if any, which form the basis for Contention 17.
- 10. With respect to any health and safety concern, or environmental impact described in your answer to Interrogatory 9, identify any NRC regulatory requirement, regulatory guidance, or other authority which you contend is not satisfied, and the reasons therefor.
- 11. Are you aware of any known occurrences of Corbicula fouling of l
closed cycle cooling towers at steam-electric power plants? If so, identify each such plant, and describe fully any observed degradation of the cooling system due to such fouling.
Request for Documents Pursuant to 10 C.F.R. Section 2.741, the NRC Staff requests you to make available for inspection and copying at a time and location to be designated any and all documents, of whatever description, identified in the responses to the above Staff interrogatories, including, but not limited to:
l (1) any written record of any oral communication between or among Intervenors, their advisors, consultants, agents, attorneys, and/or any other persons, including but not limited to the Applicants, and their advisors, consultants, agents, attorneys and/or any other persons; and (2) any documents, correspondence, letter, memorandum, notes, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts, and notes of meetings.
If CESG maintains that some documents should not be made available for inspection, it should specify the documents and explain why such documents are not being made available. This request extends to any such document, described above, in the possession of CESG,its advisors, consultants, agents, or attorneys.
Respectfully submitted,
.YpeS w George E. Johnson Counsel for NRC Staff Dated at Bethesda, Maryland this 7th day of May, 1982.
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