ML20210T022

Response to NRC Interrogatories & Request for Documents Re Contention 14.Related Correspondence

ML20210T022
Person / Time
Site:	Diablo Canyon
Issue date:	10/03/1986
From:	Mcdermott L CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL
To:	Atomic Safety and Licensing Board Panel, NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20210T028	List: ML20210T022 ML20210T054
References
CON-#486-0982, CON-#486-982 86-523-03-LA, 86-523-3-LA, OLA, NUDOCS 8610080285
Download: ML20210T022 (3)

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?: 1 72 WTen COMEEPONDENC5 UNITED STATES OF AMERICA DOCHETED USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINGf? -6 P5 :28

)

In the Matter of: )

) Docket anc @SbM23-OLA'd9[5D4275 PACIFIC GAS AND ELECTRIC COMPANY )

) ASLBP No. 86-523-03-LA (Diablo Canyon Nuclear Power Plant, )

Units 1 and 2) )

INTERVENOR CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY ANSWER TO NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS REGARDING CONTENTION 14 ANSWER 1-la, b, c. Persons who work with C.O.D.E.S. in relation to Diablo Canyon Power Plant have found anonymity to be a necessity for a variety of compelling legal, financial and personal safety reasons.

C.O.D.E.S. refers the interrogator to 10CFR2.740(c) protective order and gives notice that this protection is invoked.

ANSWER 1-2. Premature in this proceeding, no witnesses have been designated at this time.

The official record is deficient and does not provide the infor-mation that is the duty of the regulator and obligation of the applicant /

licensee to provide for credable evaluation of this License Amendment Request. Section 182a of the Atomic Energy Act of 1954 as amended, states:

Applications for, and statements made in. connection with, licenses under section 103 and 104 shall be made under oath or affirmation.

The only proffered material from the applicant / licensee or NRC Staff in this matter which meets the above criterion is the Oct 30, 1985 LAR 85-13, Reracking of Spent Fuel Pools.

Therefore, this question is premature at this time.

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, 4 ANSWER 1-3. See answer to 1-2.

ANSWER l-4. The official record in this matter does not allow for public review of the legal and technical issues involved with this L.A.R. Intervenors who are supposed to supplement the Staff's review in this matter, and provide another facet and dimention to the public health and safety evaluation, have a deficient application with which to work, an application that will not support this proceeding. This imperfection must be rectified before a meaningful answer can be given to this question. If the review process is defective, Radiological Response Planning is the alternative.

ANSWER l-5. The official record is silent with respect to st-ructures that have been represented by the applicant / licensee to be involved and evaluated by the NRC in this regard.

See also, answer to 1-4 above.

ANSWER 1-6. The deterioration of safety related components to the point of not functioning for their intended purpose or to the detriment of public hea' th and safety, by whEtever c Ause, cAnnot be specified at this time. Interrogatories $re intended to simplify the issues. Simplific$ tion c$nnot t$ke place becAuse of the defective application we have to work with.

REQUEST FOR DOCUMENTS, RESPONSE: C.O.D.E.S. objects to the re-quest for documents as being premature in this proceeding. The thresh-hold imperfection in this matter makes it impossible to respond to this request. There is not sufficient documentation in the official record

cre to prepare an adequate evaluation of the License Amendment Request

~

application as submitted.

Respectfully submitted

- -L YVE-(0 Laurie McDermott, Co-Ordinator for C.O.D.E.S.

Date I do declare and affirm that the above response is true and accu ate to the best of my knowledge and ability.

_ _/E_ , _f AjM/b Laurie McDermott Sk k u 4 IWid)D._ ,_ W Date County State O 4 4 9 x

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