ML20055A998

First Set of Interrogatories & Request for Documents Re Commission Questions 2 & 5.Certificate of Svc Encl

ML20055A998
Person / Time
Site:	Indian Point
Issue date:	07/16/1982
From:	Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	WEST BRANCH CONSERVATION ASSOCIATION
Shared Package
ML20055A991	List: ML20055A990 ML20055A996 ML20055A998
References
ISSUANCES-SP, NUDOCS 8207200231
Download: ML20055A998 (8)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSOLIDATED EDISON COMPANY OF ) Docket Nos. 50-247 SP NEW YORK, INC. (Indian Point, ) 50-286 SP Unit No. 2) )

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POWER AUTHORITY OF THE STATE OF ) July '16, 1982 NEW YORK (Indian Point, Unit No. 3))

NRC STAFF FIRST SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM WBCA CONCERNING THE COMMISSION'S QUESTIONS 2 AND 5 INTRODUCTION The NRC Staff hereby requests that West Branch Conservation Association (WBCA) pursuant to 10 C.F.R. 95 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying all documentary material identified in responses to the interrogatories below.

INSTRUCTIONS AND DEFINITIONS

1. Information sought in these Interrogatories shall include infomation within the knowledge, possession, control or access of any agents, employees and independent contractors of WBCA.

2. Answer each Interrogatory separately (by part) in writing under oath or affirmation of the individuals who contributed thereto.

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_2 Documents produced shall indicate in response to which specific request the documents are being produced, i.e., 1(a). For all references requested in these interrogatories, identify them by author, title, date of publication and publisher if the reference is published; and if it is not published, identify the document by the author, title, the date it was written, the qualification of the author relevant to this proceeding, and where a copy of the document may be obtained.

3. In your answer, repeat each Interrogatory set forth herein and then set forth an answer thereto separately and fully. As to any Interrogatory, section or subsection of said Interrogatory that you refuse to answer for any reason, separately state the grounds for any such refusal. Where a complete answer to a particular Interrogatory, section or subsection of said Interrogatory is not possible, such Interrogatory, section or subsection of said Interrogatory should be answered to the extent possible and a statement made indicating the reason for the partial answer.

4. Identify any documents used as the basis for the answer to the Interrogatory.

5. If any Interrogatory or part thereof is objected to, state separately (by part) the objection and basis therefor.

6. If privilege is claimed as to any document, identify what is being withheld, the date of the document, the sender (s), the receipient(s) of all copies, the privilege claimed, the basis for the assertion of privilege, and the present location of the document.

7. If any document requested is unavailable, explain the circumstances of such unavailability.

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8. In accordance with 10 C.F.R. 5 2.740(e) these Interrogatories and requests for documents require prompt supplemental answers should WBCA obtain or identify supplemental infomation or documents which call into question the correctness of earlier answers. l

9. In the event any word, term, or phrase is unclear to WBCA it is requested that oral clarification be requested of the undersigned Staff counsel. Any word, term, or phrase is to have its generally accepted meaning.

10. " Documents" mean all writings and records of every type in the possession, control or custody of WBCA its directors, officers, attorneys, employees or agents, including, but not limited to, memoranda, correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agenda, diaries, logs, transcripts, microfilm, accounting statements, telephone and telegraphic comunications, speeches, and all other records, written, electrical, mechanical or otherwise.

" Documents" shall also mean copies of documents, even though the l originals thereof are not in the possession, custody or control of WBCA.

INTERR0GATORIES j Interrogatory 1 Identify all documentary or other material that you intend to use during this proceeding to support Contentions 2.2 and 5.1 and that you may offer as exhibits on this contention or refer to during your cross-examination of witnesses presented by Consolidated Edison Company of New York, Inc., Power Authority of the State of New York, or the NRC l Staff.

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Interrogatory 2 a) Upon what person or persons do you rely to substantiate in ,

D whole or in part your case on Contentions 2.2 and 5.1? -

b) Provide the address and education and professional 3 qualifications of any persons named in your response to 22 above.

c) Identify which of the above persons or any other persons you may call as witnesses on the contentions referenced in 2a above.

Interrogatory 3 (Refer to Contention 2.2)

Please provide the basis for your contention that brackish Hudson River cooling water in the cooling system has caused serious corrosion problems and that the cooling system should be changed to combat those problems. Identify all documents referenced or relied upon in response to this interrogatory.

Interrogatory 4 (Refer to Contention 2.2)

Please define the term " steam system" as used in your statement in WBCA 2 (filing of January 11,1982).

Interrogatory 5 (Refer to Contention 2.2)

Please provide the basis for your conclusions in WBCA 2 (filing of January 11,1982) that " cement lined pipes are bound to corrode again at the welding joints because of the unique use of brackish water."

Interrogatory 6 (Refer to Contention 2.2)

Identify the dates and report numbers, if any, which discuss the history of fines by the NRC and New York State Public Service Consnission on the Licensees of the Indian Point plants.

Interrogatory 7 (Refer to Contention 2.2)

Please provide the basis for your contention that a resolution of the radiation embrittlement problem in the Units' reactor pressure vessels must be found and implemented.

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Interrogatory 8 (Refer to Contention 2.2)

Please provide the basis for your conclusions in WBCA 2 (filing of January 11,1982) that "the embrittlement of the vessels of both IP stations has proven to be beyond design specs" and that "the parts cannot last for the design life of the plant."

Interrogatory 9 (Refer to Contention 2.2)

Please provide the basis for your contention that a resolution of the steam generator tube deterioration problem is necessary as a condi-tion of operation for both Indian Point units.

Interrogatory 10 (Refer to Contention 2.2.)

Please provide the basis for your contention that a complete review of quality assurance and quality control in construction and operation is necessary as a condition of operation for both Indian Point units.

a) Please give a brief description of each incident relied upon in formulating this contention.

b) Identify all reports relating to these incidents if any by date and report number.

Interrogatory 11 (Refer to Contention 5.1)

Please provide the basis for your statement in WBCA letter of December 2,1981 which states "the risks surrounding Indian Point are greater than that af many other operating stations due to the design and condition of the stations." Identify all documents referenced or relied upon in response to this interrogatory.

DOCUMENT REQUESTS

1. Provide for inspection and copying by the NRC Staff all documents identified in WBCA's answer to Interrogatories I through 11 above.

2. Provide for inspection and copying by the NRC Staff all documents within the possession or control of WBCA which relate to the use of brackish Hudson River water in the cooling system at the Indian Point Plants.

3. Provide for inspection and copying by the NRC Staff all documents within the possession or control of WBCA which relate to the history of fines by the NRC and New York State Public Service Comission on the Licensees of the Indian Point plants.

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4. Provide for inspection and copying by the NRC Staff all documents within the possession or control of WBCA which relate to the reactor embrittlement problem.

5. Provide for inspection and copying by the NRC Staff all documents within the possession or control of WBCA which relate to the steam generator tube deterioration problem.

6. Provide for inspection and copying by the NRC Staff all documents within the possession or control of WBCA which relate to quality assurance and quality control in construction and operation.

7. Provide for inspection and copying by the NRC Staff all documents within the possession or control of WBCA which relate to the risk of Indian Point Units 2 and 3 are greater than other operating stations due to the design and condition of Indian Point Units 2 and 3.

. Respectfully submitted, O N\_ll E. [W Janice E. Morre Counsel for NRC Staff Dated at Bethesda, Maryland this 16th day of July, 1982.

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l l' UNITED STATES OF AMERICA m NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD , .

)

In the Matter of )

) Docket Nos. 50-247-SP a CONSOLIDATED EDISON COMPANY 50-286-SP 0F NEW YORK (Indian Point, Unit 2 )

)

) July 16, 1982 POWER AUTHORITY OF THE STATE )OF NEWYORK(IndianPoint, Unit 3)

CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF FIRST SET OF INTERR0GATORIES ES - T DOCUMENTS FROM PARENTS CONCERNING COMMISSION QUESTION 1,NRC AND REQUEST FOR DOCUMENTS FROM UCS/NYPIRG CONCERNING COMMISSI STAFF FIRST SET OF INTERR0GATORIES AND REQUEST FOR COMMISSION'S QUESTIONS 2 ANC 5, in the day above copti through deposit in the Nuclear Regulatory Commission's internal mail system, this 1 of July, 1982.

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Paul F. Colarulli, Esq.

Louis J. Carter, Esq., Chairman Joseph J. Levin, Jr. , Esq.

Administrative Judge Pamela S. Horowitz, Esq.

Atomic Safety and Licensing Board Charles Morgan, Jr. , Esq.

7300 City Line Avenue Morgan Associates, Chartered Philadelphia, PA 19151-2291. 1899 L Street, N.W.

Dr. Oscar H. Paris Charles M. Pratt, Esq.

Administrative Judge Atomic Safety and Licensing Board Thomas R. Frey, Esq.

U.S. Nuclear Regulatory Commission Power Authority of the State Washington, D.C. 20555 of New York 10 Columbus Circle New York, N.Y. 10019 Mr. Frederick J. Shon Administrative Judge Atomic Safety and Licensing Board Ellyn R. Weiss, Esq.

U.S. Nuclear Regulatory Comission William S. Jordan, III, Esq.

Washington, D.C. 20555 Hannon & Weiss 1725 I Street, N.W., Suite 506 Washington, D.C. 20006 Brent L. Brandenburg, Esq. ,

Assistant General Counsel Consolidated Edison Co. of Jonathan D. Feinberg New York, Inc. New York State Public Service 4 rv n P Cortraission 0003 Three Empire State Plaza Albany, New York 12223 Mayor George V. Begany Village of Buchanan DESIGNATED ORIGIrg 236 Tate Avenue ~

• Buchanan, N.Y. 10511 Certitgeg gy m:\Q _.

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John Gilroy, Westchester Coordinator Stanley B. Klimberg Indian Point Project General Counsel New York Public Interest New York State Energy Office Research Group 2 Rockefeller State Plaza 240 Central Avenue Albany, N.Y. 12223 White Plains, N.Y. 10606 Marc L. Parris, Esq.

Jeffrey M. Blum, Esq. Eric Thorsen, Esq.

New York University Law School County Attorney, County of Rockland

, 423 Vanderbilt Hall 11 New Hempstead Road '{

l 40 Washington Square South New City, N.Y. 10956 New York, N.Y. 10012 t ion o' nd a o nt Coordinator The Port Authority of New York City Audubon Society New York and New Jersey 71 West 23rd Street, Suite 1828 -

One World Trade Center New York, N.Y. 10010 New York, N.Y. 10048 Greater New York Council on Ezra I. Bialik, Esq. Energy Steve Leipsiz, Esq. c/o Dean R. Corren, Director Environmental Protection Bureau New York University New York State Attorney 26 Stuyvesant Street General's Office New York, N.Y. 10003 '

Two World Trade Center New York, N.Y. 10047 Honorable Richard L. Brodsky Member of the County Legislature Alfred B. Del Bello Wes Westchester County Executive gu t ce ding White Plains, N.Y.

10601 s e r ounty 148 Martine Avenue Pat Posner, Spokesperson White Plains, New Yo u.. 10601 Parents Concerned About Andrew S. Roffe, Esq. Indian Point New York State Assembly P.O. Box 125 Albany, N.Y. 12248 Croton-on-Hudson, N.Y. 10520 Ruthanne G. Miller, Esq. . , Charles A. Scheiner, Atomic Safety and Licensing Board Co-Chairperson Panel . . Westchester People's Action U.S. Nuclear Regulatory Commission Coalition, Inc.

Washington, D.C. 20555

• P.O. Box.488 White Plains, N.Y. 10602 Honorable Ruth Messinger Richard M. Hartzman, Esq.

Member of the Council of the Lorna Salzman City of New York Friends of the Earth, Inc.

District #4 208 West 13th Street City Hall New York, N.Y. 10011 1 New York, N.Y. 10007

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Donald Davidoff Director Radiological Emergency Alan Latman, Esq. Preparedness Group 44 Sunset Drive Empire State Plaza Croton-on-Hudson, N.Y. 10520 Tower Building, Rm. 1750 Albany, New York 12237 Zipporah 5. Fleisher -

West Branch Conservation Renee Schwartz, Esq. -

Association Paul Chessin, Esq.

443 Buena Vista Road Laurens R. Schwartz, Esq.

New City, N.Y.. 10956 Margaret Oppel, Esq.

Botein, Hays, Sklar & Hertzberg Judith Kessler, Coordinator 200 Park Avenue Pockland Citizens for Safe Energy New York, NY 10166 300 New Hempstead Road New City, N.Y. 10956 Amanda Potterfield, Esq.

Joan Holt, Project Director ~

David H. Pikus, Esq. New York Public Interest Research Richard F. Czaja, Esq. ,

Group, Inc. -

330 Madison Avenue 9 Murray Street New York, N.Y. 10017 New York, New York 10007 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comr '-don Washington, D.C. 20555

• David B. Duboff Vestchester Peoples' Action Coalition Ato Safety and Licensing Appeal 25 G e ain , NY 10601 U.S. Nuclear Regulatory Comission Craig Kaplan, Esq.

Washington, D.C. 20555

• National Emergency Civil Committee Docketing and Service Section 175 Fifth Avenue, Suite 712 , , -

Office of the Secretary New York, NY 10010 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 *

• I DlZ A /WX0 /V1D7thO Janice E. Moore Counsel for NRC Staff n