ML20211E187

Second Set of Interrogatories Re Contention 1 Concerning Proposed Reracking of Spent Fuel Pools.Related Correspondence

ML20211E187
Person / Time
Site:	Diablo Canyon
Issue date:	10/20/1986
From:	Mcgurren H NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	SAN LUIS OBISPO MOTHERS FOR PEACE
Shared Package
ML20211E160	List: ML20211E152 ML20211E172 ML20211E187 ML20211E212
References
OLA, NUDOCS 8610220374
Download: ML20211E187 (2)

Text

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HELATED COftRESPONDM DOLKEILD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING B .D OFFILL . n - .A n In the Matter of ) 00C41g. ! cvtri

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

Units 1 and 2) )

NRC STAFF SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM SAN LUIS OBISPO MOTHERS FOR PEACE The NRC staff hereby requests that San Luis Ohlspo Mothers for Peace (Mothers for Peace) pursuant to 10 C.F.R. Il 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-1 rics below. Each response to the intermgatories 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 is was written, the qualifications of the author relevant to this pro-eceding, and where a copy of the document may be obtained.

Mothers for Peace Contention 1 The Applicant has not adequately considered alternatives to the pro.josed reracking of the spent fuel pools. In particu-lar, because of the increased danger posed by the close proximity of the Ilosgri fault, alternatives should be consid-cred. Some alternatives include:

8610220374 861020 PDR ADOCK 05000275 0 PDR ,

a. The contracting out or transshipment 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.

Interrogatories 2-la. Identify what person or persons you now rely upon to substantiate in whole or in part your position on i Contention 1.

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.

2-2. Provide summaries of the- views, positions or proposed testimony on Contention 1 of all persons named in re-

! sponse to Interrogatory 2-1, that you intend to present as witnesses during this proceeding.

2-3. State the specific bases and references to any documents upon which the persons named in response to Interroga-tory No. 2-1 rely to substantiate their views regarding Contention 1.

2-4. With regard to Contention 1, identify all documentary or other material that you intend to use during this pro-ceeding to support this contention and that you may offer as exhibits on this contention or refer to during your cross-examination of witnesses presented by the Licensee and/or the NRC staff.

Respectfully submitted, I

t f rfienry J.f rren j () Counsel for NRC Staff Dated at Bethesda, Maryland this 20th day of October,1986 I

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