ML20210B670

Interrogatories & Request for Documents Re Contention That Applicant Has Not Adequately Considered Alternatives to Proposed Reracking of Spent Fuel Pools

ML20210B670
Person / Time
Site:	Diablo Canyon
Issue date:	09/16/1986
From:	Mcgurren H NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	SAN LUIS OBISPO MOTHERS FOR PEACE
Shared Package
ML20210B637	List: ML20210B632 ML20210B670 ML20210B734
References
OLA, NUDOCS 8609180139
Download: ML20210B670 (3)

Text

.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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 SAN LUIS OBISPO MOTHERS FOR PEACE The NRC staff hereby requests that the San Luis Obispo Mothers for Peace (Mothers for Peace) pursuant to 10 C.F.R. 55 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 interrogato-ries 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 published, 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 pro-ceeding, and where a copy of the document may be obtained.

Mothers for Peace Contentions:

1. The Applicant has not adequately considered alternatives to the proposed reracking of the spent fuel pools. In particular, because of the increased danger posed by the close proximity of the Hosgri fault, alternatives should be considered. Some alternatives include:

8609180139 860916 5 PDR ADOCK 0900 G

K

/ -

a. ~ The contracting out or trans-shipment of spent fuel for storage at a government owned spent fuel facility;

b. Derating the facility or reducing the plant output and thereby reducing the generation of spent fuel.

c. Closing or shutting.down the facilities.

2. The Applicant failed to evaluate the overall cost (in terms of both health effects and potential associated medical costs) associated with the additional exposures o' the plant personnel during normal operation to increase 6 ra-dioactivity levels due to the increased spent fuel storage.

3. No analysis has been made of the overall costs (in terms of both health effects and potential associated medical costs associated with the additional exposures of persons off the Diablo Canyon site to increased radioactivity levels during normal operation due to the increased spent fuel storage.

Interrogatories For each of the foregoing content 6 ions separately:

1-la. Upon what person or persons do you rely to sub-stantiate in whole or in part your position on Contentions 1-3?

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

l

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-l posed testimony on Contentions 1-3 of all persons 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 Contentions 1-3.

i 1-4. With regard to Contentions 1-3 identify all documen-tary or other material that you intend to use during this proceeding to support these contentions and/or that you may offer as exhibits on these contentions

-v. - -. , .-, -,, - - - - - - -. ---.--y-

d .

-- or refer to or utilize during your cross-examination .

of witnesses presented by the Licensee and/or the NRC staff.

Respect fully subnitted, L'.t d ry b kourren Counsel for NRC Staff Dated at Bethesda, Maryland this 16th day of Septmber,1986 l

4 i

_ _ - _ . - - . ._, _ . . , . . . - . . . , _ . . . . , . _ . . . _ , , . __ - - - - .--___m.____._____-,_____._______._____._.,-_-- , - _ _ _ _ _ _ _ , _ _ . _ . _ . .