ML20101D042

Request for Production & Interrogatories to NRC Re Spent Fuel Pool.Certificate of Svc Encl.Related Correspondence

ML20101D042
Person / Time
Site:	North Anna
Issue date:	12/15/1984
From:	Jay Dougherty CONCERNED CITIZENS OF LOUISA COUNTY
To:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML20101D036	List: ML20101D034 ML20101D037 ML20101D042
References
OLA-1, NUDOCS 8412210282
Download: ML20101D042 (5)

Text

.

CCLC, 12/15/84 L

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

)

In the Matter of )

) Docket Nos.

VIRGINIA-ELECTRIC AND POWER CO. ) 50-338 OLA-1

) 50-339 OLA-1 (North Anna Power Station, )

Units 1 and 2) )

)

)

CONCERNED CITIZENS OF LOUISA COUNTY REQUEST FOR PRODUCTION AND.

INTERROGATORIES TO THE NRC STAFF Pursuant to 10 CFR S 2.740b, Intervenor Concerned Citizens of Louisa County requests that the following interrogatories be answered fully, in writing and under oath, by one or more employees of the Nuclear Regulatory Commission ("NRC") who has personal knowledge thererof of, or is the closest to having personal knowledge thererof. These interrogatories impose upon the NRC Staff a continuing obligation. If, af ter answering a question, additional pertinent information comes to the attention of the Staf f or its consultants, the previous answer should be amended.

Each question is to be answered in six parts, as follows:

A. Provide the direct answer to the question.

B. Identify all documents and studies, and the particular parts thererof, relied upon as the basis for the answer.

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C. Identify all other documents in the Staff's posses-sion which pertain to the subject matter of the question.

D. Please make a copy of each document identified in parts C and D available in the Public Document Room. If any such document is not and will not be available for inspection in the Public Document Room, please provide a copy.

E. Identify the person providing the answer to the question. If more than one person answered the question, indi-cate the respective portions answered by each. In addition, identify all other NRC Staf f or consultants who have the expert knowledge required to answer the question.

F. Explain whether the Staff is aware of any ongoing or planned research bearing on the question. Please identify

~

such research.

G. Identify the employee (s) or consultant (s), if any, whom the Staff intends to have testify on the subject matter of the question. Provide a statement of the qualifications of such persons.

The term document is to be construed broadly to include all writings, whether handwritten or not. It includes documents from all sources, including those which were not prepared by or for the Staff, as well as those which were intended only for limited distribution, e.g., memos to the file and telecon notes. It also includes graphs, charts, and drawings of every kind.

Question 1. Please state the Staff's position on Contention 1 and set out the oasis for this position.

i l

2. To the Staf f's knowledge, are there any other NRC licensing proceedings now pending in which a contention has been raised regarding the transportation of spent fuel? If so, please i

identify them.

3. Is it the Staf f's position that it is important for VEPCO (for any reason) to maintain a " full core reserve" in its spent fuel pools? If not, why not? If so, please explain.

4. The following questions relate to VEPCO's application to the NRC for authority to construct a dry-cask storage facility at Surry.

a. What is the status of VEPCO's application?

b. What steps remain to be taken, by VEPCO or the Staff, before VEPCO's application can be granted?

c. When does the S taf f expect that its review of VEPCO's application will be completed?

, d. What is the planned capacity of facility?

e. Summarize the projected construction schedule for the facility, assuming that full NRC approval is received on (1)

February 1, 1985 and (2) Augus t 1, 1985.

f. Please identify all correspondence between VEPCO and the NRC pertaining to dry cask storage of spent fuel.

5. Has the Staff examined the proposed Surry-to-North Anna o

transportation route (s) t.o identify population centers, safe havens, traffic ~1evels, road hazards, or environmentally sensi-

b tive areas'(such as drinking water supplies)? If so, please identify all documents pertaining to such examinations.

6. Has the Staff examined the proposed transportation route (s) to determine what kind of emergency response skills and equipment are possessed by the governmental departments and agen-cies that might be expected to respond in the event of an acci-

-dent? If so, please identify all pertinent documents.

7. Please identify the shipping casks that VEPCO plans to use to transport spent fuel f rom Surry to North Anna. Have any defects or safety hazards ever been associated with these casks?

If so, please explain. -

8. In an affidavit dated December 21, 1982 and submitted to

'the Licensing Board by VEPCO on December 22, 1982, Marvin L.

, Smith referred to two " windows" during which it was important for VEPCO to make the proposed spent fuel shipments. Is it the i Staf f's position that. similar windows will exist in ,the future?

If so, please explain.

Respectfully submitted,

s

j. p.

{ i.- . v. ., s

! James B. Dougherty 1

Counsel for Concerned Citizens of Louisa County

December 15, 1984 l 3045 Porter St. NW Washington DC 20008 l (202)362-7158 i

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NUCLEAR REGULATORY COMMISSION O Z nii m ... E f r.;

, 3.D ACH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

)

In the Matter of )

) Docket Nos.

, VIRGINIA ELECTRIC AND POWER CO. ) 50-338 OLA-1

' ) 50-339 OLA-1 (North Anna Power Station, )

Units 1 and 2) )

)

)

CERTIFICATE OF SERVICE f I certify that copies of the foregoing CONCERNED CITIZENS OF LOUISA COUNTY REQUEST FOR PRODUCTION AND INTERROGATORIES TO THE I NRC STAFF were served, this 15st day of December,1984, by de-posit in the United States Mail, First Class, upon the following

i Secretary Sheldon J. Wolfe, Chairman

U.S. ~ Nuclear' Regulatory Comm' n Atomic Safety & Licensing Board Washington DC 20555 U.S. Nuclear Regulatory Comm'n Washington DC 20555 Dr. Jerry Kline Atomic Safety and Dr. George A. Ferguson Licensing Board School of Engineering U.S. Nuclear Regulatory Comm'n Howard University Washington DC 20555 2300 5th Street, NW Wachington DC 20059 Henry J. McGurren, Esq.

U.S. Nuclear Regulatory Comm'n Washington DC 20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comm'n Atomic Safety and-Washington DC 20555 Licensing Appeal Board U.S. Nuclear Regulatory Comm'n Michael W. Maupin, Esq. Washington DC 20555 Hunton & Williams P.O. Box 1535 . . ,

Richmond VA 23212 .

.i f. -., ..

James B. Dougherty.