ML20210B632

Interrogatories & Request for Documents Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses to Structural Integrity of Spent Fuel Ponds

ML20210B632
Person / Time
Site:	Diablo Canyon
Issue date:	09/16/1986
From:	Mcgurren H NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL
Shared Package
ML20210B637	List: ML20210B632 ML20210B670 ML20210B734
References
CON-#386-729 OLA, NUDOCS 8609180124
Download: ML20210B632 (2)

Text

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DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ~86 SEP 17 A10:28 BEFORE TIIE ATOMIC SAFETY AND LICENSINQ$BOARDt y rev

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URI!k In the Matter of )

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PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA (Diablo Canyon Nuclear Power Plant ) (Spent Fuel Pool)

Units 1 and 2) )

NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY REGARDING CONTENTION 14 The NRC staff hereby requests that Consumers Organized for De-fense of Environmental Safety (CODES) pursuant to 10 C.F.R. Il 2.740b and 2.741, answer separately and fully, in writing under oath or affirma-tion, the following interrogatories and produce or make available for in-spection and copying, all documentary material identified in responses to interrogatories below. Each response to the interrogatories below shall be under oath or affirmation of the individual (s) who contributed thereto.

For all references requested in these interrogatories, identify them by author, title, date of publication and publisher if the reference is pub-lished, and if it is not published, identify the document by the author, title, the date it was written, the qualifications of the author relevant to this proceeding, and where a copy of the document may be obtained.

CODES Contention 14 Neutron embrittlement and other metallurgical deterioration and environmental stresses to the structural integrity of the spent fuel ponds have not been adequately analyzed and determined for the. period of the license.

8609180124 860916 PDR G

ADOCK 05000275 O$09 V

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Interrogatories .

1-la. Upon what person or persons do you rely to sub-stantiate in whole or in part your position on CODES Contention 14?

b. Provide the addresses and education and professional qualifications of any persons named in your response to a. above.

c. Identify which of the above persons or any other person you may call as witnesses on this contention.

1-2. Provide summaries of the views, positions or pro-posed testimony on CODES Contention 14 of all per-sons named in response to Interrogatory 1-1, that you intend to present as witnesses during this proceeding.

1-3. State the . specific bases and references to any docu-ments upon which the persons named in response to Interrogatory No . 1-1 rely to substantiate their views regarding CODES Contention 14.

1-4. With regard to CODES Contention 14 identify all doc-umentary or other material that you intend to use during this proceeding to support these contentions and that you may offer as exhibits on these conten-tions or refer to during your cross-examination of witnesses presented by the Licensee and/or the NRC staff.

1-5. With regard to CODES Contention 14, specifically identify the structures of the " spent fuel ponds" that you assert will be affected by "[n]eutron embrittlement and other metallurgical deterioration and environmental stresses."

1-6. With regard to CODES Contention 14 identify what you mean by " environmental stresses."

Respectfully subnitted,

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Hent J McGurren Counse for NRC Staff Dated at Bethesda, Maryland this 16th day of Septenber,1986

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