ML20058J688
| ML20058J688 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/09/1982 |
| From: | Mcgarry J DEBEVOISE & LIBERMAN, DUKE POWER CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8208110166 | |
| Download: ML20058J688 (20) | |
Text
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RELATED COPJTSPO mmTcn 00CKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COHMISSION
,,-1._,
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.
~
In the Matter of
)
)
DUKE POWER COMPANY, --et al.
)
Docket Nos. 50-413
)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
APPLICANTS' INTERROGATORIES TO PALMETTO ALLIANCE AND REQUEST TO PRODUCE REGARDING PALMETTO ALLIANCE'S CONTENTIONS 16 AND 27 Pursuant to 10 CFR $$2.740b and 2.741, Duke Power Company, et al.
(" Applicants") hereby serve Applicants' Interrogat'ories and Requests to Produce upon Intervenor, Palmetto Alliance.
These interrogatories involve Palmetto Alliance's Contentions 16 and 27.
Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to Palmetto Alliance, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel.
Each request to produce applies to pertinent documents which are in the possession, custody or control of Palmetto Alliance, its officers, directors or members as well as its employees, advisors or counsel.
In answering each interrogatory R2OO110166 820809 PDR ADOCK 05000413 G
, and in responding to each request, recite the interrogatory or request preceeding each answer or response.
Also, identify the person providing each answer or response.
These interrogatories and requests shall be continuing in nature.
Thus, any time Palmetto Alliance obtains information l
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which renders any previous response incorrect or indicates that a response was incorrect when made, Palmetto Alliance should sup-plement its previous response to the appropriate interrogatory or request to produce.
Palmetto Alliance should also supplement its responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness,
[
the subject matter of his or her testimony, and the substance of that testimony.
Applicants are particularly interested in the names and areas of expertise of Palmetto Alliance's witnesses, if any.
Identification of such witnesses is necessary if Applicants are to be afforded adequate time to depose them.
The term "docu-ments" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information l
can be obtained.
We request that at a date or dates to be agreed l
upon, Palmetto Alliance make available for inspection and copy-1 l
ing, all documents subject to the requests set forth below.
REQUESTS FOR DOCUMENTS Pursuant to 10 CFR $2.741, Applicants request Palmetto Alliance by and through its attorney, to make available for in-spection and copying at a time and location to be designated, any
, and all documents, of whatsoever description, identified in the responses to the Applicants' interrogatories, below, including, but not limited to:
(1) any written record of any oral communication between or i
among Intervenors, their advisors, consultants, agents, attorneys, and/or any other persons, including but not limited to the NRC Staff, 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 Palmetto Alliance maintains some documents should not be made available for inspection, it should specify the documents and explain why such are not being made available.
This require-ment extends to any such documents, described above, in the possession of Palmetto Alliance, its advisors, consultants, agents, or attorneys.
, GENERAL INTERROGATORIES Pursuant to 10 CFR $2.740b, the Applicants request Palmetto Alliance, by and through its attorney, to answer separately and fully in writing under oath or affirmation, by persons having knowledge of the information requested, the following interro-gatories.
A.
General Interrogatories The following interrogatories apply severally to each of the contentions admitted as issues in controversy in this proceeding.
1.
State the full name, address, occupation and employer of each person answering the interrogatories and designate the interrogatory or the part thereof he or she answer-ed.
2.
Identify each and every person you are considering to call as a witness at the hearing in this matter on this contention, and with respect to each such person:
a.
State the substance of the facts and opinions to which the witness is expected to testify; b.
Give a summary of the grounds for each opinion; and c.
Describe the witness' educational and professional background.
3.
Is the contention based on one or more calculations?
If so:
Describe epch calculation and identify any docu-a.
ments setting forth such calculation.
. b.
Who performed each calculation?
c.
When was each calculation performed?
d.
Describe each parameter used in such calculation and each value assigned to the parameter, and des-cribe the source of your data, e.
What are the results of each calculation?
f.
Explain in detail how each calculation provides a basis for the issue.
4.
Is the contention based upon conversations, consulta-tions, correspondence or any other type of communica-tions with one or more individuals?
If so:
a.
Identify by name and address each such individual, b.
State the educational and professional background of each such individual, including occupation and institutional affiliations.
c.
Describe the nature of each communication with such individual, when it occurred, and identify all other individuals involved.
d.
Describe the information received from such indi-viduals and explain how it provides a basis for the issue.
e.
Identify each letter, memorandum, tape, note or i
other record related to each conversation, consul-l tation, correspondence, or other communication with l
such individual.
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. 4 B.
Palmetto Alliance Contention No. 16 1.
What do you mean by "have not demonstrated?"
2.
Do you contend by "have not demonstrated" that NRC regula-tory requirements have not been adequately complied with?
3.
If your answer to Interrogatory 2 is affirmative, identify those NRC regulatory requirements.
Provide specific refer-ence to all provisions of statutes, regulations, regulatory guides, or any other NRC regulatory requirement upon which you rely.
4.
With regard to Interrogatory 3, specify in what manner you contend each of those NRC requirements has not been met.
5.
If your answer to Interrogatory 2 is negative, state what you believe to be the requisite elements for Applicants to
" demonstrate" their ability to store spent fuel safely.
6.
With regard to Interrogatory 5, specify in what manner you contend Applicants have not met each of those elements.
7.
What are the bases for your responses to Interrogatories 1 through 6?.
8.
With regard to Interrogatory 7, identify and submit copies of all documents, testimony, or oral statements by any person on which you rely in support of your position.
9.
What do you mean by the term " ability"?
10.
Specify each activity which you contend constitutes any or all aspects of the term " ability" as you define it.
11.
Do you contend that " ability" is defined by certain NRC l
regulatory requirements?
If so, identify those require-I ments.
Provide specific reference to all provisions of l
statutes, regulations, regulatory guides, or any other NRC L
regulatory requirement upon which you rely.
i 12.
If your answer to Interrogatory 11 is affirmative, what level of " ability" do you contend is necessary to satisfy applicable NRC regulatory requirements?
j 13.
With regard to Interrogatory 12, state why you contend each I
of those NRC requirements has not been met.
14.
If your answer to Interrogatory 11 is negative, what level
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of " ability" do you contend is necessary to ensure the l
public health and safety?
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. 15.
With regard to Interrogatory 14, specify Why you contend that Applicants have not demonstrated that level of
" ability".
16.
What are the bases for your responses to Interrogatories 9 through 157 Identify and submit copies of all documents, testimony or oral statements by any person on Which you rely in support of your position.
17.
What do you mean by " safely"?
18.
Specify each activity which you contend constitutes any or all aspects of the term " safely."
19.
Do you contend that NRC requirements have not been met when you say " safely"?
20.
If your answer to Interrogatory 19 is affirmative, identify those NRC regulatory requirements. Provide specific refer-ence to all provisions of statutes, regulations, regulatory guides or any other NRC regulatory requirement on Which you rely.
21.
With regard to Interrogatory 20, specify in what manner you contend each of those NRC requirements has not been met.
22.
If your answer to Interrogatory 19 is negative, state What you believe is necessary for Applicants to store " safely" irradiated fuel assemblies.
Identify specifically each element of the storage of such assemblies you contend is necessary to store them " safely".
23.
With regard to Interrogatory 22, specify in what manner you contend Applicants will not store irradiated fuel assemblies
" safely".
24.
What are the bases for your responses to Interrogatories 17 through 23?
Identify and submit copies of all documents, testimony, or oral statements by any person on Which you rely in support of your position.
25.
What do you mean by the term " store"?
26.
Identify specifically each activity which you contend con-stitutes any or all of the term " store," as you define it.
27.
With regard to Interrogatory 26, identify all those NRC regulatory requirements which you contend relate to any or all elements of the term " store" as you use it.
Provide i
. specific reference to all provis*ans of statutes, regula-tions, regulatory guides or any other NRC regulatory requirement on which you rely.
28.
What are the bases for your responses to Interrogatories 25 through 277 Identify and submit copies of all documents, testimony, or oral statements by any person on Which you rely in support of your position.
29.
What do you mean by the phrase " irradiated fuel assemblies"?
30.
Specifically, do you contend that " irradiated fuel assem-blies" are defined within applicable NRC regulatory requir-ements?
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31.
If your answer to Interrogatory 30 is affirmative, identify those NRC regulatory requirements.
Provide specific refer-ence to all provisions of statutes, regulations, regulatory guides or any other NRC regulatory requirement on which you rely.
32.
With regard to Interrogatory 31, do any of those require-ments define procedures for " safe" storage of " irradiated fuel assemblies" within the meaning you ascribe to those terms?
33.
If your answer to Interrogatory 32 is affirmative, identify specifically each of those NRC requirements and explain how each relates to the " safe" storage of " irradiated fuel assemblies."
34.
With regard to Interrogatory 33, specify why you contend that those NRC requirements have not been met.
35.
If your answer to Interrogatory 32 is negative, state What you contend to be the requirements for " safe" storage of
" irradiated fuel assemblies".
36.
With regard to Interrogatory 35, specify why you contend Applicants have not met each of those requirements.
37.
What are the bases for your responses to Interrogatories 29 through 367 Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
38.
What do you mean by the phrase "other Duke nuclear facili-ties"?
. 39.
With regard to Interrogatory 38, identify each of those "other Duke nuclear facilities" which is the subject of this contention.
40.
For each of the facilities identified in your response to Interrogatory 39, explain why you contend that their "irra-diated fuel assemblies" might not be " safely stored" at the Catawba facility.
41.
With regard to Interrogatory 40, do you contend that "irra-diated fuel assemblies" cannot be safely stored at Catawba because the Catawba spent fuel pool facility is somehow defective or inadequate?
42.
If your answer to Interrogatory 41 is affirmative, do you contend that the Catawba spent fuel pool is somehow defec-tive or inadequate because it does not meet NRC regulatory requirements applicable to the storage of spent fuel?
43.
If the answer to Interrogatory 42 is affirmative, identify each of those NRC regulatory requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other NRC regulatory requirement on which you rely.
44.
With regard to Interrogatory 43, explain why you contend that the Catawba spent fuel pool fails to meet each of those NRC regulatory requirements.
45.
If your answer to Interrogatory 42 is negative, state what you believe should be the criteria to determine whether Catawba has the ability to safely store the " irradiated fuel assemblies" of "other Duke nuclear facilities".
46.
With' regard to Interroaatory 45, identify specifically those circumstances which you contend demonstrate Applicants lack of ability to safely store " irradiated fuel assemblies" from "other Duke nuclear facilities" at the Catawba spent fuel storage pool.
For each such circumstance, explain why you contend it demonstrates Applicants lack the ability to safely store " irradiated fuel assemblies" from "other Duke nuclear facilities" at the Catawba spent fuel storage pool.
47.
With regard to Interrogatories 41 and 46, what features of the Catawba spent fuel storage pool do you contend need improvement before it can safely store the " irradiated nuclear fuel assemblies" of "other Duke nuclear facilities"?
. 48.
What are the bases for your responses to Interrogatories 38 through 47?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
49.
With regard to Interrogatory 47, are those improvements which you contend are necessary mandated by applicable NRC regulatory requirements?
50.
If the answer to Interrogatory 49 is affirmative, identify those NRC regulatory requirements.
Provide specific refer-ence to all provisions of statutes, regulations, regulatory guides, or any other NRC regulatory requirement upon which you rely.
51.
With regard to Interrogatories 49 and 50, state why you contend these NRC requirements are unmet.
52.
If the answer to Interrogatory 49 is negative, explain why you contend the features which you identified in response to Interrogatory 47 are necessary before the Catawba spent fuel storage pool can safely store the " irradiated nuclear fuel assemblies" of "other Duke nuclear facilities".
53.
With regard to Interrogatory 52, explain how the improve-ments you suggest will rectify the deficiencies which you allege exist in the Catawba spent fuel storage pool.
C.
PALMETTO ALLIANCE CONTENTION 27 1.
What do you mean by the phrase "should be required"?
2.
Specifically, do you contend by "should be required" that regulatory requirements (state or federal) have not been met?
3.
If answer to Interrogatory 2 is affirmative, identify the those regulatory requirements.
Provide specific reference l
to provisions of statutes, regulations, regulatory guides, l
or any other regulatory requirement on which you rely.
4.
With regard to Interrogatory 3, please explain in what man-ner you contend that regulatory requirements have gone unmet.
5.
If answer to Interrogatory 2 is negative, explain on what criteria you rely in asserting the phrase "should be required," and specify the origin of such criteria.
6.
With regard to Interrogatory 5, specify in what manner those criteria have gone unmet.
7.
What are the bases for your responses to Interrogatories 1 through 6?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
8.
What do you mean by "real time monitors"?
9.
What do you maintain is the function of "real time moni-tors"?
10.
Is the function described in response to Interrogatory 9 a regulatory requirement (state or federal)?
11.
If the answer to Interrogatory 10 is affirmative, identify those regulatory requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other regulatory requirement on which you rely.
12.
If the answer to Interrogatory 10 is negative, explain why you maintain such "should be required."
13.
Is the installation of "real time monitors" themselves a regulatory requirement (state or federal)?
14.
If answer to Interrogatory 13 is affirmative, identify those regulatory requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or l
any other regulatory requirement on which you rely.
l 15.
If answer to Interrogatory 13 is negative, is it because other means exist which you believe also satisfy applicable regulatory requirements?
16.
If answer to Interrogatory 15 is affirmative, identify all other available means which you believe satisfy applicable regulatory requirements.
17.
With regard to Interrogatories 15 and 16, identify the regu-latory requirements (state or federal) which were the bases of your answers.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other l
regulatory requirement on which you rely.
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18.
Explain the precise nature of the information you contend will be provided by "real time monitors."
19.
With regard to Interrogatory 18, do you believe that the information provided by "real time monitors" can be provided by other means?
If so, identify each of those other means.
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. 20.
If the answer to Interrogatory 19 is negative, specify what information you contend would be available from a "real time monitor" which would not also be available from other means.
21.
With regard to Interrogatory 20, do you contend that such information is necessary to satisfy applicable regulatory requirements (state or federal)?
22.
If the answer to Interrogatory 21 is affirmative, identify those regulatory requirements and demonstrate how such other means fail to meet the applicable requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other regulatory requirement on which you rely.
23.
If the answer to Interrogatory 19 is affirmative, identify those other available means.
24.
Explain why you believe that "real time monitors" are pre-ferable to those other available means.
25.
What are the bases for your responses to Interrogatories 8 through 24?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
26.
What do you mean by " capable of"?
l 27.
Specifically, what level of accuracy demonstrates "capa-bil ity ?
l 28.
With regard to Interrogatory 27, is this level of accuracy mandated by applicable regulatory requirements (state or federal)?
l 29.
If the answer to Interrogatory 28 is affirmative, identify these applicable regulatory requirements.
Provide specific l
reference to provisions of statutes, regulations, regulatory I
guides, or any other regulatory requirement on which you rely.
30.
If answer to Interrogatory 28 is negative, explain why you l
contend that this level of accuracy is necessary to " assure l
the health and safety of the public."
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31.
With regard to Interrogatory 27, are there means available other than "real time monitors" which you believe can attain l
this level of accuracy?
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. 32.
If the answer to Interrogatory 31 is affirmative, identify the other available neans which you believe attain this level of accuracy.
33.
What are the bases for your responses to Interrogatories 26 through 32?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
34.
If level of accuracy is not your criteria for determining
" capability," or level of accuracy is not your sole criteria for such a determination, please answer Interrogatories 35 through 41.
35.
Identify and explain what your criteria for the determin-ation of " capability" are.
36.
With regard to Interrogatory 35, are these criteria mandated by applicable regulatory requirements (state or federal)?
37.
If the answer to Interrogatory 36 is affirmative, identify these applicable regulatory requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other regulatory requirement on which you rely.
38.
If the answer to Interrogatory 36 is negative, explain why you contend that " capability," as determined by your criteria, is necessary to " assure the health and safety of the public."
39.
With regard to Interrogatory 35, are there devices available l
other than "real time monitors" which meet your criteria for capability?
40.
If the answer to Interrogatory 39 is affirmative, identify the other available devices which meet your criteria for capability.
41.
What are the bases for your responses to Interrogatories 35 through 40?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
42.
What do you mean by " gamma radiation levels"?
l 43.
Is the monitoring of " gamma radiation levels" mandated by applicable regulatory requirements (state or federal)?
l
. 44.
If the answer to Interrogatory 43 is affirmative, identify these regulatory requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other regulatory requirement on which you rely.
45.
If the answer to Interrogatory 43 is negative, explain 'dhy you contend that monitoring " gamma radiation levels" is necessary to assure the public health and safety.
46.
What are the bases for your responses to Interrogatories 42 through 45?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
47.
What do you mean by the phrase " place...around the site"?
48.
With regard to Interrogatory 47, specify how many real time monitors you contend are necessary "to assure public safety and health."
49.
With regard to Interrogatory 48, explain why you contend that that number of monitors is necessary.
50.
In responding to Interrogatory 47-49, identify the regula-tory requirements (state or federal) which you rely upon.
Provide specific reference to provisions of statutes, regu-lations, regulatory guides, or any other regulatory require-ment on which you rely.
51.
With regard to Interrogatory 47, specify the configuration of real time monitors which you contend is necessary "to assure public safety and health."
52.
With regard to Interrogatory 51, explain why you contend that that configuration is necessary.
53.
In responding to Interrogatory 51, specify the locality of and distance at which you contend each unit should be "placed around the site."
54.
In responding to Interrogatories 51-53, identify the regula-tory requirements (state and federal) on which you rely.
Provide specific reference to provisions of statutes, regu-(
lations, regulatory guides or any other regulatory require-l ment on which you rely.
55.
What do you mean by " site"?
56.
With regard to Interrogatory 55, identify what you contend are the relevant boundaries of the " site" with respect to your Contention 27.
. 57.
In responding to Interrogatory 56 identify the regulatory requirements (state or federal) upon Which you rely.
Pro-vide specific reference to provisions of statutes, regula-tions, regulatory guides, or any other regulatory require-ment on which you rely.
58.
What are the bases for your responses to Interrogatories 47 through 57?
Identify and submit copies of all documents, testimony or oral statements by any person on Which you rely in support of your position.
59.
Identify specifically the " emergency operations personnel" you refer to in your contention?
60.
Explain why you contend that the " emergency operations per-sonnel" referenced in your contention will be aided by the information you contend will be provided by real time moni-tors.
61.
What are the bases for your answers to Interrogatories 59 and 60?
Identify and submit copies of all documents, testi-mony or oral statements by any person on Which you rely in support of your position.
62.
What do you mean by "information required"?
63.
Do you mean by "information required" that applicable regu-latory requirements (state or federal) will not be met?
64.
If the answer to Interrogatory 63 is affirmative, identify these regulatory requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other regulatory requirement on which you rely.
65.
With regard to Interrogatory 64, explain in What manner you contend those regulatory requirements have gone unmet.
66.
If the answer to Interrogatory 63 is negative, explain why you feel that such information is " required" to assure public safety and health.
67.
Do you believe that this information, which you contend is required, is available from other sources?
68.
If the answer to Interrogatory 67 is affirmative, identify those sources.
69.
If the answer to Interrogatory 67 is negative, explain what informational advantage you contend will be gained from using real time monitors rather than other available means.
. 70.
What are the bases for your responses to Interrogatories 62 through 697 Identify and submit copies of all documents, testimony or oral statements by any person and legal requirements on Which you rely in support of your position.
71.
What do you mean by " decisions necessary"?
72.
Specify the type of decisions you contend will be made based upon the information available from the use of real time monitors.
73.
With regard to Interrogatory 72, do you believe that those type of decisions could be made based upon the information available from other available means?
74.-
If the answer to Interrogatory 73 is affirmative, identify those other available means.
75.
If the answer to Interrogatory 73 is negative, explain why you contend those "necessary decisions" can only be made based upon the information available from the use of real time monitors.
76.
With regard to Interrogatory 72, explain Why you contend that decision-making capabilities are inadequate under existing or planned means.
77.
What are the bases for your responses to Interrogatories 71 through 76?
Identify and submit copies of all documents, testimony or oral statements by any person on Which you rely in support of youi position.
78.
What do you mean by "to reasonably assure"?
79.
Specify the criteria you contend one must meet in order to
" reasonably assure the health and safety of the public."
80.
With regard to Interrogatory 79, if regulatory requirements comprise part or all of your criteria, please identify these regulatory requirements (state or federal).
Provide speci-fic reference to provisions of statutes, regulations, regu-l latory guides, or any other regulatory requirement on which you rely.
81.
Explain why you contend that public safety and health is not reasonably assured by the devices planned for use at Catawba.
82.
Do you believe that " reasonable assurance" can be obtained by measures through the use of means other than placing real time monitors around the site?
$ 83.
If the answer to Interrogatory 82 is affirmative, identify those means.
84.
If the answer to Interrogatory 82 is negative, explain why you contend that no other means will " reasonably assure" the public safety and health.
85.
What " conditions of radiological release" do you contemplate in this contention?
86.
What are the bases for your answers to Interrogatories 78 through 85?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
87.
What do you contend is the " accuracy" of the real time moni-tors?
Use the same technique you us.ed to derive the accu-racy of thermoluminescent dosimeters in your Contention 27.
88.
With regard to answer to Interrogatory 87, do you contend that the difference in accuracy is significant?
89.
If the answer to Interrogatory 88 is affirmative, explain why you contend that the difference in " accuracy" between a real time monitor and a thermoluminescent dosimeter is sign-ificant.
90.
Explain why you contend that thermoluminescent dosimeters "only provide a post hoc assessment of conditions."
91.
Do you contend that a " post hoc assessment of conditions" is contrary to regulatory requirements (state or federal)?
92.
If the answer to Interrogatory 91 is affirmative, identify l
those regulatory requirements.
Provide specific reference to provisions of statutes, regulations, regulatory guides, or any other regulatory requirement on which you rely.
For each such regulatory requirement identified, explain why you contend that a "pos3 hoc assessment of c$nditions" is not l
suitable.
93.
If the answer to Interrogatory 91 is affirmative, do you contend that an adi hoc assessment of conditions is required.
If so, explain why.
94.
Do you contend that real time monitors can provide an ad hoc assessment of conditions?
95.
If the answer to Interrogatory 94 is affirmative, explain why you contend that an ad hoc assessment is possible with a real time monitor.
. 96.
Explain why you contend that an ad, hoc assessment is neces-sary to " reasonably assure" the public health and safety.
97.
Do you believe that other means are available to provide an ad hoc assessment of conditions?
98.
If the answer to Interrogatory 97 is affirmative, list those devices.
99.
With regard to Interrogatory 98, explain why you contend that real time monitors are better suited for use at Catawba than those other means which you believe can also provide an ad hoc assessment of conditions.
100. What are the bases for your answers to Interrogatories 87 through 99?
Identify and submit copies of all documents, testimony or oral statements by any person on which you rely in support of your position.
Respectfully submitted, f')
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[J. Michael McGarry, IIIjf DEBEVOISE & LIBE M N 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 i
(202) 857-0833 William L.
Porter Albert V.
Carr, Jr.
Ellen T.
Ruff DUKE POWER COMPANY P.O.
Box 33189 Charlotte, North Carolina 28242 Attorneys for Duke Power Company, et al August 9, 1982
UNITED STATES OF AMERICA Ctsili.
NUCLEAR REGULATORY COMMISSION M
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD) g,y In the Matter of
)
Orr!Cd 0F SEL. /
)
00CtETI% & SLRV Lt DUKE POWER COMPANY, et al.
)
Docket Nos. 550 KIT
)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Interrogatories to Palmetto Alliance and Request to Produce Regarding Pa] netto Alliance's Contentions 16 and 27" in the above captioned maiter, has been served upon the folicwing by deposit in the United States mail this 6th day of August, 1982.
James L.
Kelley, Chairman George E. Johnson, Esq.
Atomic Safety and Licensing Office of the Executive Legal Board Panel Director U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.-
20555 Dr.
A.
Dixon Callihan William L.
Porter, Esq.
Union Carbide Corporation Albert V.
Carr, Jr., Esq.
l P.O.
Box Y Ellen T.
Ruff, Esq.
Oak Ridge, Tennessee 37830 Duke Power Company l
P.O.
Box 33189 l
Dr. Richard F.
Foster Charlotte, North Carolina 28242 P.O.
Box 4263 l
Sunriver, Oregon 97701 Richard P. Wilson, Esq.
l Assistant Attorney General Chairman State of South Carolina l
Atomic Safety and Licensing P.O.
Box 11549 Board Panel Columbia, South Carolina 29211 U.S. Nuclear Regulatory Commission Robert Guild, Esq.
Washington, D.C.
20555 Attorney-at-Law 314 Pall Mall Chairman Columbia, South Carolina 29201 Atomic Safety and Licensing Appeal Board Palmetto Alliance U.S. Nuclear Regulatory 2135 1/2 Devine Street l
Commission Columbia, South Carolina 29205 Washington, D.C.
20555 l
l l
l
., Jesse L.
Riley Scott Stucky 854 Henley Place Docketing and Service Station Charlotte, North Carolina 28207 U.S. Nuclear Regulatory Commission Henry A.
Presler Washington, D.C.
20555 Charlotte-Mecklenburg Environmental Coalition 943 Henley Place Charlotte, North Carolina 28207 s
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f.MichaelMcGarr / III
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