ML20101A226

Requests Production of Documents & Interrogatories to Concerned Citizens of Louisa County Re Consolidated Contention I.Certificate of Svc Encl.Related Correspondence

ML20101A226
Person / Time
Site:	North Anna
Issue date:	12/14/1984
From:	Maupin M VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	CONCERNED CITIZENS OF LOUISA COUNTY
References
CON-#484-676 OLA-1, NUDOCS 8412180275
Download: ML20101A226 (8)

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~ December 14, 1984 84 DEC 17 N152 UNITED STATES OF AMERICA- CFFICE OF SEChf' NUCLEAR REGULATORY COMMISSION 00CKEig Before the Atomic Safety and Licensing Board t: In the Matter of )

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VIRGINIA ELECTRIC.AND POWER COMPANY) . Docket Nos. 50-338/339

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(North Anna Power-Station, )

Units 1 and 2) )

APPLICANT'S REQUEST FOR PRODUCTION

'OF DOCUMENTS'AND INTERROGATORIFS TO CONCERNED CITIZENS OF LOUISA COUNTY Virginia Electric and Power Company (the Applicant) hereby requests Concerned Citizens of Louisa County. (CCLC) to produce at 2000 Pennsylvania Ave., N.W., Washington, D.C.,_or at-another mutually agreed upon location, each of l the documents-described below, within thirty days after' -

service of this request, in accordance with 10 C.F.R.

S 2.741. In addition, the Applicant propounds the inter-rogatories set forth below to which CCLC is asked.to respond within fourteen days in accordance with S 2.740b. These y discovery. requests pertain to Consolidated Contention 1 L~

. admitted by.the Atomic Safety and Licensing Board in its.

Memorandum and Order of October 15, 1984 in the North Anna l

license; amendment proceedings (OLA-1).

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o! ooh 338 'N PDR _ .

DEFINITIONS A. "CCLC" means any member, employee, representative, i

consultant, agent, technical advisor, attorney or other person acting for or on behalf of CCLC or at CCLC's direc-tion, or in concert with CCLC or assisting CCLC. I

b. " Document" means any handwritten, typewritten, printed or recorded graphic matter.however produced or re-produced, whether or not in the possession, custody or con-trol of CCLC and whether or not claimed to be privileged agair st discovery on any ground, including but not limited to, reports, records, li.sts, memoranda, correspondence, telegrams, schedules, photographs, sound recordings, brochures and written statements of any person.

If CCLC considers any document called for in this re-quest to be privileged from production, CCLC must include in-its response to this request a list of documents with-L l'

held from production, identifying each document by date, l

addressee (s) , author, title and subject matter. In addi-tion, CCLC should identify those persons who have seen the document or who were sent copies and state the grounds upon which each such document is considered privileged.

C. The words " pertaining to" include referring to, relating to, connected with, concerning, comprising, memoria-lizing, commenting on, regarding, discussing, showing,

describing,. reflecting, analyzing, supporting and contra-dicting.

SUPPLEMENTATION OF RESPONSES CCLC-must supplement its responses in accordance with 10 C.F.R. S 2.740 (e) .

DOCUMENT REQUEST

1. All documents pertaining to the risk of accidents, including accidents associated with sabotage or human error, resulting from the transportation of spent nuclear fuel by truck.

2. All documents pertaining to dry-cask storage of spent fuel.

INTERROGATORIES

1. Identify the person or persons whom CCLC reli~es upon to substantiate in whole or in part CCLC's positions with respect to Consolidated Contention 1.

2. Provide the-addresses and educational and profes-sional qualifications of each person identified in CCLC's response to Interrogatory 1.

3. Identify those persons listed in response to Inter-rogatory 1 whom CCLC will or may call as a witness in this proceeding.

4. Provide a summary of the views, positions or pro-posed testimony of each person listed in response to Inter-1 rogatory 1.

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'-5. - Identify all documents and other material thatL CCLC' intends to use during this-proceeding to support. Con-solidated Contention l'and that CCLC may offer as an exhibit in this' proceeding or refer to in connection with the exami-nation in this proceeding of any witness.

6. Identify each document'upon which a person listed i

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in CCLC's response to Interrogatory l'may rely to substanti . l l

ate-his or her views regarding Consolidated' Contention 1.  !

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7. Describe the' accidents that could occur during

. Lthe transportation of spent fuel casks from Surry to North

. Anna, the probability of each such accident and the conse-quences CCLC.would expect-to result from each such accident.

8. Describe the basis for and any dat'a or analyses that tend to support CCLC's responses to Interrogatory 7.

9. Describe the forms of sabotage that could result in accidents occurring during the transportation of spent fuel- caska from Surry to North Anna, the probability of each such form of sabotage and the consequences CCLC would expect.to result from each such form of sabotage.

10. Describe the basis for and any data or analyses, a

that tend-to support-CCLC's responses to Interrogatory 9.

11. Describe, for each form of sabotage listed in response to Interrogatory'9, what would be required of the

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saboteurs in terms of planning, equipment, personnel skills, staffing and execution.

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12. Describe the ways in which, and the extent to which', compliance with 10 C.F.R. S 73.37 would'be inadequate to prevent .a successful sabotage effort.

13. Describe precisely'the respects in which human error by Applicant's employees in preparing casks for ship-ment could result in accidents occurring during the transpor-tation of spent fuel casks from the Surry Station.to the

- . North Anna Station,'the probability of each such error and the consequences CCLC would expect to result from each such

-error.

. 14. Describe the basis for and any data or_ analyses that tend to support CCLC's responses to Interrogatory 15.

15 . - Indicate the ways in which, and the extent to which, compliance with Applicant's procedures governing the loading, unloading and -handling of spent fuel casks would lun inadequate to prevent the errors described in CCLC's response to-Interrogatory 13.

16. Indicate whether there are any unresolved conflicts over the use of available resources involved in .this pro-ceeding and, if there are any, list them.

i 17. Specify why dry cask storage at Surry is the " safest",

l method for spent fuel disposal.

18. .Specify the basis for CCLC's contention that dry cask storage can be " effected in a timely manner."

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19. Indicate the basis for CCLC's contention that dry l

. cask storage-is " feasible." '

20. Identify the documents. named in CCLC's responses i

fto Interrogatories 5 and 6 by author, title, date of publica-

! . tion and_ publisher if-the reference is published, if the

' reference is not published, identify the document by the author, title, date it was written and qualifications of the author relevant to this proceeding, and indicate where l a copy of the document may be obtained.

21. Indicate whether.the Staff has erroneously con-cluded in its Safety _ Evaluation Report that the probability of a sabotage event is remote and that attempted sabotage, if successful, would not produce serious radiological con-sequences. If the response is "yes," state the basis for CCLC's response.

22. Indicate in what_significant ways' Applicant's L proposal is.different from the proposal in the Dukt_trans--

, shipment case where the Commission held that the transpor-l tation by truck of 300 spent fuel assemblies over a 170 mile distance neither presented a substantial national re-sources commitment question nor significant environmental

(- impacts -(14 NCR at 322)

Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY By_/s/ Michael W. Maupin Michael W. Maupin, Counsel

Of Counsel Michael W. Maupin-Marcia E. Gelman HUNTON & WILLIAMS P. O. Box 1535

-Richmond, Virginia 23212 Dated: December 14, 1984 CERTIFICATE OF SERVICE I hereby certify that I_have this day served Applicant's Request for Production of Documents and Interrogatories to Concerned Citizens of Louisa County upon each of the persons named below'by depositing a copy in the United States mail, properly stamped and addressed to him at the address set out with his name:

Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Chief Docketing and Service Section Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory-Commission Washington, D.C. 20555 Dr. Jerry Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. George A. Ferguson School of Engineering Howard University 2300 5th Street Washington, D.C. 20059 Henry J. McGurren, Esq.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James B. Dougherty, Esq.

3045 Porter Street, N.W.

Washington, D.C. 20008

1 Atomic Safety and Licensing Board Panel

- U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Atomic, Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 By: /s/ Michael W. Maupin-Michael W. Maupin, Counsel for Virginia Electric and Power Company Dated: December 14, 1984 Y

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