ML20214Q362

First Set of Interrogatories & Request for Production of Documents Re Contention 14 Concerning Reracking of Spent Fuel Pools.Related Correspondence

ML20214Q362
Person / Time
Site:	Diablo Canyon
Issue date:	09/16/1986
From:	Norton B PACIFIC GAS & ELECTRIC CO.
To:	CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL
Shared Package
ML20214Q354	List: ML20214Q352 ML20214Q362 ML20214Q378
References
OLA, NUDOCS 8609240331
Download: ML20214Q362 (5)

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-6 1 UNITED STATES OF AMERICA cft9 N g g Z NUCLEAR REGULATORY COMMISSION g Gn BEFORE THE ATOMIC SAFETY AND LICENSING ARD 3  % g 4 ) Docket Nos. 50-275 In the Matter of ) 50-323 5 )

PACIFIC GAS AND ELECTRIC COMPANY ) (Reracking of Spent Fuel Pools) 6 )

(Diablo Canyon Nuclear Power )

7 Plant Units 1 and 2) )

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8 9 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION .

10 0F DOCUMENTS TO CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY 11 12 Pursuant to 10 CFR 2.740b, Licensee PACIFIC GAS AND ELECTRIC COMPANY 13 hereby propounds the following interrogatories and document requests to 14 Consumers Organized for Defense of Environmental Safety (CODES) on its ,

15 Contention 14.

16 INSTRUCTIONS 17 1. All information is to be divulged which is in the possession of 18 the individual, association, or corporate party, their attorneys, consultants, 19 investigators, agents, employees, witnesses or other representatives of the 20 named party.

21 2. Where you have incomplete information that precludes your fully 22 answering an interrogatory, give such information as you have and state what 23 information you do not have. If you are unable to give the information in the 24 form sought but have the information aggregated differently, give the 25 information in the form in which you have it and explain the reason for the i

26 deviation.

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1 3. When asked in the interrogatories below to identify or to give 2 the identity of a person, please give the following information about him or 3 her:  ;

4 (a) full name; 5 (b) present job title, employer, and telephone number.

6 4. When asked in the interrogatories below to identify or to give 7 the identity of a document or writing, please give the following information

8 about the document:

9 (a) its title, if any; 10 (b) its nature (e.g., letter, memorandum, chart, computer.

11 printout, ledger, notes, etc.);

12 (c) the date, if any, stated on the document; 13 (d) the identity of each person who signed it; 14 (e) the identity of each person to whom it is addressed; 15 (f) the present location of the document.

16 5. Where an individual interrogatory calls for an answer which 17 involves more than'one part, each part of the answer should be clearly set out 18 so that it is understandable.

19 6. These interrogatories are intended as continuing interrogatories.

20 requiring you to answer by supplemental answer, setting forth any information 21 within the scope of the interrogatories as may be acquired by you, your 22 agents, attorneys or representatives following your original answers up to the 23 time of hearing.

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1 7. " Documents" include printed material, writings, calculations, 2 worksheets, handwritten notes, photographs, xerox reproductions, and audio or c 3 video recordings. "Hritings" and " recordings" consist of letters, words, or 4 numbers, or their equivalent, set down by handwriting, typewriting, printing, 5 photostating, photographing, magnetic impulse, mechanical or electronic 6 recording, or other form of data compilation, as defined in Rule 1001 of the 7 Federal Rules of Evidence, 28 U.S.C.

8 INTERROGATORIES 9 1. State each and every fact upon which you base your contention ,

10 that neutron embrittlement and other metallurgical deterioration and 11 environmental stresses' to the structural integrity of the spent fuel ponds 12 have not been adequately analyzed and determined for the period of the license.

13 2. State with specificity the type of analysis that would 14 constitute adequate analysis of the stated effects of the integrity of the 15 " ponds"?

16 3. Identify the structures or the portions of the " ponds" that 17 should be included in a structural integrity analysis.

18 4. Identify the types of environmental stresses that would occur.

19 5. What would be the causes of these environmental stresses?. l I

20 6. How would these environmental stresses affect the structural '

21 integrity of the " ponds"?

22 7. Identify each and every portion of the " ponds" that would be ,

23 affected by neutron embrittlement, by metallurgical deterioration, or by 24 environmental stresses.

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1 8. State each and every fact upon which you base your allegation 2 that neutron embrittlement is a form of, or causes, metallurgical 3 deterioration.

1 4 9. Identify all of the "other" types of metallurgical deterioration 5 you believe would occur and should be analyzed, and set forth each and every 6 fact upon which you base 'each such allegation and the type of analysis that 7 should be conducted for each.

8 10. Define " neutron embrittlement" as applied to spent fuel pools or 9 " ponds."

10 11. For each answer to these interrogatories, and all subparts 11 thereto, identify each person who participated in the preparation of your j 12 answers pursuant to 10 CFR 2.740b(b).

13 12. Provide the professional qualifications, if any, of each such 14 person identified.

15 13. Please identify each and every document which you claim supports 16 each fact set forth in your responses to the preceding interrogatories and 17 correlate each such document as specifically as possible (page and paragraph 18 number) with each specific response.

19 RE00EST FOR PRODUCTION OF DOCUMENTS 20 1. Pursuant to 10 CFR 2.241, you are requested to produce each 21 document identified in your answers to the preceding interrogatories.

22 2. You are requested to produce all documents you intend to use or 23 rely upon in written testimony or oral argument.

24 3. You are requested to produce all documents you intend to have i

25 marked for identification at the hearing of this matter or which you will 26 attach to any written testimony.

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t 1 4. The documents should be produced on October 22, 1986 at 2 10:00 a.m. at the 31st floor conference room, 77 Beale Street, San Francisco.

3 1 4 Respectfully submitted, 5 BRUCE NORTON c/o P. A. Crane 6

7 ROBERT OHLBACH PHILIP A. CRANE, JR.

8 RICHARD F. LOCKE Pacific Gas and Electric Company 9 P. O. Box 7442 San Francisco, California 94120 -

10 (415) 781-4211 11 Attorneys for Pacific Gas and Electric Company 12 By Bruce Norton 15 16 DATED: September 16, 1986 17 18 19 20 21 22 23 24 25 26

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