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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20094H7321984-08-10010 August 1984 Supplemental Response to Joint Interrogatories & Requests to Produce Documents on Diesel Generator Contentions & to Carolina Environ Study Group Interrogatories.Prof Qualifications Encl.Related Correspondence ML20094H7651984-08-10010 August 1984 Interrogatories Re Identification,Qualifications & Role of Expert on Diesel Generator Contention.Certificate of Svc Encl.Related Correspondence ML20094A6331984-08-0101 August 1984 Response to Palmetto Alliance & Carolina Environ Study Group Seven Interrogatories for Which ASLB Granted Motion to Compel.Certificate of Svc Encl.Related Correspondence ML20090E5801984-07-18018 July 1984 Interrogatories & Requests for Production Directed to R Anderson on Newly Admitted Contention Re Diesel Generator Engine Problems.Certificate of Svc Encl.Related Correspondence ML20092K7121984-06-25025 June 1984 Supplemental Response to Joint Interrogatories & Requests to Produce Documents on Diesel Generators Contentions & Interrogatories Re Admitted Emergency Diesel Contentions. Related Correspondence ML20084D2201984-04-27027 April 1984 Supplemental Answers to Carolina Environ Study Group & Palmetto Alliance First Round of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20087P4201984-04-0606 April 1984 Response to Palmetto Alliance & Carolina Environ Study Group Interrogatories & Requests to Produce Documents on Diesel Generator Contentions.Related Correspondence ML20087P1141984-04-0101 April 1984 Palmetto Alliance & Carolina Environ Study Group Responses to Util Interrogatories & Requests to Produce Documents on ASLB Contention Re Certain Diesel Generator Problems. Certificate of Svc Encl.Related Correspondence ML20087N6661984-03-29029 March 1984 Supplemental Answers to Carolina Environ Study Group & Palmetto Alliance 840329 First Set of Interrogatories Re Emergency Planning.Certificate of Svc Encl.Related Correspondence ML20087M4741984-03-25025 March 1984 Responses to Util Interrogatories & Request to Produce Documents on Diesel Generator Contention.Certificate of Svc Encl.Related Correspondence ML20087J4841984-03-22022 March 1984 Interrogatories & Requests to Produce Documents Re Diesel Generator Contentions to Applicant & NRC Staff.Certificate of Svc Encl.Related Correspondence ML20087J4901984-03-19019 March 1984 Supplemental Interrogatories to Util Re Emergency Diesel Contentions Admitted by Aslb.Certificate of Svc Encl.Related Correspondence ML20087G4121984-03-19019 March 1984 Interrogatories & Requests to Produce Documents to Carolina Environ Study Group & Palmetto Alliance on ASLB Contention Re Diesel Generator Reliability.Certificate of Svc Encl. Related Correspondence ML20087C4751984-03-11011 March 1984 Interrogatories & Requests to Produce Documents on Diesel Generator Contention to Carolina Environ Study Group & Palmetto Alliance.Certificate of Svc Encl.Related Correspondence ML20080G0121984-02-0606 February 1984 Responses to Second Round of Interrogatories Re Emergency Planning Contentions 1,3,6,7,8,9,11,15 & 18.Certificate of Svc Encl.Related Correspondence ML20079P7201984-01-26026 January 1984 First Round of Interrogatories Re Emergency Planning Contentions 1,3,6,7,8,9,11,14,15 & 18.Affirmation of Svc Encl ML20079J3631984-01-20020 January 1984 Second Round of Interrogatories Re Palmetto Alliance & Carolina Environ Study Group Emergency Planning Contentions 1,3,6-9,11,14,15 & 18.Certificate of Svc Encl.Related Correspondence ML20079L4551984-01-17017 January 1984 Response to First Round of Interrogatories & Requests to Produce Re Emergency Planning Contentions 1,3,6-9,11,14,15 & 18.Certificate of Svc Encl.Related Correspondence ML20083E5061983-12-22022 December 1983 First Round Interrogatories & Requests to Produce Re Emergency Planning Contentions 1,3,6-9,11,14-15 & 18. Certificate of Svc Encl ML20078A3981983-09-19019 September 1983 Supplemental Responses to Interrogatories & Requests to Produce Re Contention 6.Certificate of Svc Encl ML20077P2911983-09-0808 September 1983 Supplemental Responses to Interrogatories & Requests to Produce Re Contention 6.Certificate of Svc Encl.Related Correspondence ML20072F1731983-06-20020 June 1983 Response to Interrogatories & Requests to Produce Re Carolina Environ Study Group Contention 13.Affirmation of Svc Encl.Related Correspondence ML20072A5951983-06-0808 June 1983 Supplemental Response to Interrogatory 17 on Contention 7 ML20072A5921983-06-0606 June 1983 Responses to Util 830523 Followup Interrogatories on Des Contentions 11,17 & 19 ML20071N1701983-05-27027 May 1983 Further Supplementary Responses to Util Interrogatories Re Contentions 6,7,8,16 & 44 & NRC Interrogatories Re Contention 7 & Responses to Util & NRC Followup Interrogatories.Certificate of Svc Encl ML20071H0641983-05-18018 May 1983 Followup Interrogatories Re Des Contentions 11,17 & 19. Certificate of Svc Encl.Related Correspondence ML20073T1251983-05-0404 May 1983 Followup Interrogatories to Palmetto Alliance Contentions 6, 7,8,16 & 27.Answer Must Be Filed by 830520.Certificate of Svc Encl.Related Correspondence ML20023B7531983-05-0202 May 1983 Responses to 830418 Interrogatories & Requests to Produce Re Des Contentions 11,17 & 19.Related Correspondence ML20069L1451983-04-25025 April 1983 Interrogatories & Requests to Produce Re Contentions 1,2,3 & 4.Certificate of Svc Encl ML20073P1121983-04-20020 April 1983 Responses to 830401 Discovery & Document Production Requests Re Carolina Environ Study Group Contention 18 & Des Contention 17.Certificate of Svc Encl ML20073P6061983-04-19019 April 1983 Supplementary Responses to Interrogatories Re Contention 6, 7,8,16,27 & 44.Certificate of Svc Encl.Related Correspondence ML20073K4261983-04-18018 April 1983 Interrogatories & Requests to Produce Re Palmetto Alliance & Carolina Environ Study Group Joint Des Contentions 11,17 & 19.Certificate of Svc Encl.Related Correspondence ML20073G8301983-04-12012 April 1983 Addl Info to Initial & Followup Interrogatories.Related Correspondence ML20072R7361983-04-0101 April 1983 Discovery & Document Production Requests on Contention 18 Re Reactor Weld Cracks & Contention 17 Re Sandia Study Comparing Injury & Mortality Rates for Serious Accidents. Certificate of Svc Encl.Related Correspondence ML20072L5351983-03-28028 March 1983 Response to 830308 First Set of Interrogatories & Document Requests on Contention DES-17.Affirmation of Svc Encl. Related Correspondence ML20072N6081983-03-25025 March 1983 Responses to Palmetto Alliance 830316 Followup Interrogatories & Requests to Produce Documents Re Contentions 6,7,8,16,27 & 44.List of Major Plant Differences,Affidavits & Certificate of Svc Encl ML20072G3411983-03-17017 March 1983 Response to 821215 Second Set of Interrogatories & Document Production Requests.Affidavit of Svc Encl.Related Correspondence ML20069F5071983-03-16016 March 1983 Followup Interrogatories & Requests to Produce Re Palmetto Contentions 6,7,8,16,27 & 44.Certificate of Svc Encl.Related Correspondence ML20079P1331983-02-28028 February 1983 Supplemental Response to Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 6,7,8,27 & 44,in Response to ASLB 830209 Memorandum & Order.Certificate of Svc Encl.Related Correspondence ML20028C8801983-01-10010 January 1983 Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 8 & 27.Certificate of Svc Encl ML20064C4131982-12-31031 December 1982 Response to 820420 First Set of Interrogatories & Requests to Produce & 820927 Third Set of Interrogatories & Requests to Produce.Related Correspondence ML20028B9031982-12-0303 December 1982 Interrogatories & Requests to Produce Re Carolina Environ Study Group Contention 18/Palmetto Alliance Contention 44. Certificate of Svc Encl.Related Correspondence ML20028B4141982-11-22022 November 1982 Supplemental Responses to Third Set of Interrogatories & Requests to Produce.Certificate of Svc Encl.Related Correspondence ML20066C6301982-11-0606 November 1982 Supplementary Response to NRC & Util Interrogatories on Palmetto Alliance Contentions 8,16 & 27.Certificate of Svc Encl ML20069J3611982-10-19019 October 1982 Responses to Palmetto Alliance 820927 Third Set of Interrogatories & Requests to Produce.Related Correspondence ML20027B8811982-09-27027 September 1982 Third Set of Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 16 & 44.Certificate of Svc Encl ML20063M2051982-09-0303 September 1982 Second Set of Interrogatories & Requests to Produce. Certificate of Svc Encl.Related Correspondence ML20063J5121982-08-30030 August 1982 Responses to Applicant Interrogatories & Requests to Produce Re Palmetto Alliance Contentions 8,16 & 27 & NRC Second Set of Interrogatories & Document Production Requests.Certificate of Svc Encl ML20062L5311982-08-16016 August 1982 Interrogatories & Requests to Produce Re Palmetto Alliance Contention 8.Certificate of Svc Encl.Related Correspondence ML20058J6881982-08-0909 August 1982 Interrogatories & Request to Produce Re Palmetto Alliance Contentions 16 & 27.Certificate of Svc Encl.Related Correspondence 1984-08-10
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20197J2871998-12-11011 December 1998 Initial Decision (Application for Senior Reactor Operator License).* Appeal of R Herring of NRC Denial of Application for SRO License Denied.With Certificate of Svc.Served on 981211 ML20151W5721998-09-11011 September 1998 NRC Staff Presentation in Support of Denial of Senior Reactor Operator License for Dl Herring.* Staff Decision to Fail Dl Herring on Category a of SRO Exam,Clearly Justified. Staff Denial of Herring SRO License Should Be Sustained ML20151W5941998-09-11011 September 1998 Affidavit of Cd Payne.* Affidavit Re NRC Staff Proposed Denial of Rl Herring Application for Senior Reactor Operator License for Use at Catawba Nuclear Station,Units 1 & 2 ML20151Y0601998-09-11011 September 1998 Affidavit of DC Payne.* Supports Denial of Application of Rl Herring for SRO License ML20151W6131998-09-0808 September 1998 Affidavit of Mn Leach in Support of NRC Staff Response to Rl Herring Written Presentation.* ML20151W6311998-09-0808 September 1998 Affidavit of ET Beadle.* Affidavit Relates to Denial of Senior Reactor Operator License Application for Rl Herring. with Certificate of Svc ML20237B6931998-08-13013 August 1998 Rl Herring (Denial of Operator License for Plant).* Rl Herring Submitted Written Presentation Arguments,Data, Info Matl & Other Supporting Evidence,Per Presiding Officer 980630 Order & 10CFR2.1233.W/one Oversize Drawing ML20237A3831998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Staff Respectfully Requests Motion for Extension of Time of 2 Wks to Respond to Herring Presentation Be Granted.W/Certificate of Svc ML20237B5571998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Granted by C Bechhoefer on 980818.W/Certificate of Svc.Served on 980818 ML20236T8511998-07-21021 July 1998 Specification of Claims.* Rl Herring Claims That Answer Given on Exam Was Correct When TSs Are Considered & When Design Basis Document Considered in Conjunction W/Duke Power Nuclear Sys Div.W/Certificate of Svc.Served on 980727 ML20236F5391998-06-30030 June 1998 Memorandum & Order (Hearing File & Spec of Claim).* Orders That Brief Spec of Claims Should Be Filed by Herring,Telling Why He Believes Staff Erred in Grading Exam.Staff Must Furnish Hearing File.W/Certificate of Svc.Served on 980630 ML20236F5631998-06-30030 June 1998 Notice of Hearing.* Presiding Officer Has Granted Request of Rl Herring for Hearing on NRC Denial of Application for Operator License for Plant.W/Certificate of Svc.Served on 980630 ML20149K8221997-07-29029 July 1997 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements. Exemption Granted TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20065P4491994-04-21021 April 1994 Comment Opposing Proposed Rule 10CFR50.55 Recommendation to Incorporate Proposed Rule to Adopt ASME Code Subsections IWE & Iwl ML20044G7371993-05-25025 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20101R5931992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Opposes Rule ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20087F7471992-01-15015 January 1992 Comment Opposing Rev 1 of NUREG-1022, Event Reporting Sys ML20246J6571989-08-31031 August 1989 Order Imposing Civil Monetary Penalty on Licensee in Amount of $75,000 for Violations Noted in Insp on 881127-890204. Payment of Civil Penalty Requested within 30 Days of Order Date.Evaluations & Conclusions Encl ML20247J8921989-08-31031 August 1989 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Violations Noted in Insp on 881127-890204,including Operation in Modes 1-4 W/One Independent Containment Air Return & Hydrogen Skimmer Sys Inoperable for 42 Days ML20205N1471988-10-20020 October 1988 Comment on Petition for Rulemaking PRM-50-50 Re Provision That Authorizes Nuclear Power Plant Operators to Deviate from Tech Specs During Emergency.Request by C Young Should Be Denied ML20234D2821987-09-15015 September 1987 Joint Intervenors Emergency Motion to Continue Hearing for 2 Wks & for Immediate Prehearing Conference.* Urges That Hearing Re Offsite Emergency Planning at Plant,Scheduled for 870928,be Continued Until 871013.Certificate of Svc Encl ML20198C5771986-05-14014 May 1986 Transcript of 860514 Discussion/Possible Vote on Full Power OL for Catawba 2 in Washington,Dc.Pp 1-86.Viewgraphs Encl ML20203N4561986-02-20020 February 1986 Unexecuted Amend 6 to Indemnity Agreement B-100,replacing Item 3 of Attachment to Agreement W/Listed Info ML20151P2231985-12-31031 December 1985 Order Extending Time Until 860110 for Commissioners to Review ALAB-825.Served on 851231 ML20136H7231985-11-21021 November 1985 Decision ALAB-825,affirming Remaining Part of ASLB OL Authorization,Permitting Applicant to Receive & Store Spent Fuel Generated at Duke Power Co Oconee & McGuire Nuclear Power Facilities.Served on 851121 ML20138B3611985-10-11011 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-813.Served on 851011 ML20137W4311985-10-0202 October 1985 Order Extending Time Until 851011 for Commission to Act to Review ALAB-813.Served on 851003 ML20134N5761985-09-0404 September 1985 Order Extending Time Until 851004 for Commission to Act to Review ALAB-813.Served on 850904 ML20126M2091985-07-30030 July 1985 Order Amending First Paragraph of Footnote 126 Re Need for Power & Financial Qualifications in ALAB-813 . Served on 850731 ML20126K7701985-07-26026 July 1985 Order Extending Time Until 850730 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850729 ML20129C2351985-07-26026 July 1985 Decision ALAB-813 Affirming Aslab Authorization of Issuance of Full Power Ol,Except Insofar as Receipt & Storage Onsite of Spent Fuel Generated at Other Facilities.Served on 850729 ML20129K1651985-07-19019 July 1985 Order Extending Time Until 850726 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850719 ML20129H9361985-07-10010 July 1985 Unexecuted Amend 5 to Indemnity Agreement B-100,changing Items 1 & 3 of Attachment ML20128K2171985-07-0808 July 1985 Order Extending Time Until 850719 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850709 ML20127P0991985-06-28028 June 1985 Transcript of 850628 Supplemental Oral Argument in Bethesda, Md.Pg 99-169 ML20133C5201985-06-26026 June 1985 Undated Testimony of PM Reep Re Welding Inspector Concerns. Rept of Verbal Harassment Encl ML20127K7171985-06-24024 June 1985 Order Extending Time Until 850709 for Commission to Act to Review Director'S Decision DD-85-9 ML20126K6391985-06-17017 June 1985 Order Advising That Counsel Be Familiar W/Content of Commission Request for Public Comment on Decision to Exercise Discretionary Price-Anderson Act Authority to Extend Govt Indemnity to Spent.... Served on 850618 ML20126B8101985-06-13013 June 1985 Order Scheduling Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md Re Public Notice of Hearing Concerning Use of Facility for Receipt & Storage of Spent Fuel from Oconee & Mcguire.Served on 850613 ML20126E4601985-06-13013 June 1985 Notice of Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md.Served on 850613 ML20125B4251985-06-0707 June 1985 Responds to Aslab 850603 Order Requesting Response to NRC 850529 Filing Re Whether Notice of Proposal to Use Catawba to Store Oconee & McGuire Spent Fuel Discretionary or Required.Certificate of Svc Encl ML20126A7631985-06-0404 June 1985 Director'S Decision DD-85-9 Granting & Denying in Part Palmetto Alliance Request for Mod,Suspension or Revocation of CPs for Facilities Due to Harassment & Intimidation of QC Inspectors ML20129A6381985-06-0303 June 1985 Order Allowing Applicant to File & Serve Response to NRC 850529 Assertion Re Storage of Spent Fuel Generated at Another Facility Constituting Use of Commercial Utilization Facility No Later than 850607.Served on 850604 ML20128P0001985-05-29029 May 1985 NRC Views on Whether Notice of Proposal to Use Facility to Store Oconee & McGuire Spent Fuel Required or Discretionary. Certificate of Svc Encl ML20128P1031985-05-29029 May 1985 Memorandum Responding to Palmetto Alliance/Carolina Environ Study Group & Staff 850517 Memoranda Asserting That Fr Notice Not Reasonably Calculated to Inform of Requests Re Spent Fuel.Certificate of Svc Encl ML20127K0231985-05-20020 May 1985 Order Extending Time Until 850529 for Aslab to Act to File & Svc Reply Memoranda.Served on 850521 ML20127G2281985-05-17017 May 1985 Memorandum Responding to 850425 Aslab Order Addressing Four Questions Re Receipt & Storage of Spent Fuel.Certificate of Svc Encl ML20127H0041985-05-17017 May 1985 Response to Aslab Questions on Adequacy of Notice of Proposed Use of Facility to Store Spent Fuel from Oconee & McGuire Facilities.Aslab Has No Jurisdiction Over Proposal. Certificate of Svc Encl 1998-09-08
[Table view] |
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00LKETED UNITED STATES OF AMERICA MW NUCLEAR REGULATORY C0!?tISSION BEFORE THE AT0!!IC SAFETY AND LICENSING BOAR -9 A10:56 U$f CF 5ELFmov In the "atter of "C
DUKE POWER C0'1PANY, et al . )
) Docket No. 50-413 (Catawba Nuclear Station, ) 50-414 Units 1 and 2) )
) November 5, 1982 PAU1ETTO ALLIANCE SUPPLE'!ENTARY RESPONSES TO APPLICANTS' AND STAFF'S INTERROGATORIES REGARDING PAUtETTO CONTENTIONS 8, 16, and 27.
Intervenor Palmetto Alliance herewith submits supplementary responses to discovery by Applicants and Staff as directed by the Board at the most recent Prehearing Conference of October 8,1982 and reaffirms its previous Responses and Motion for Protective Order of August 30, 1982.
Applicants assert in their Motion to Compel of September 9,1932, that their interrogatories are designed to enable Applicants to understand how Palmetto Alliance defines the material terms in its contentions; what the areas of safety concern (if any) raised by Palmetto Alliance encompass; what actions (if any) Applicants should take, according to Palmetto Alliance, to assure the safe operation of Catawba; and what the technical bases (if any) for Palmetto Alliance's positions are.
Applicants' Motion to Compel at p. 647.
Palmetto Alliance does not dispute the legitimacy of these areas of inquiry or that such information is properly discoverable. Palmetto asserts no objection to responding to any of these questions by Duke Power Company on relevance grounds. But Palmetto does insist on its right to say "we don't know" at this stage of litigation and to be free 8211100192 821106 PDR ADOCK 05000413 2)S03
from sheer harassment at the hands of either Duke o the NRC Staff. Defining such terms as "sufficiert", Applicants' Interrogatory No. 7, " reactor operators", Interrogatory ?!o. 22, and "have experience", Interrogatory flo.
61, beyond stating that the wo, is' common meaning should control, represents at least sheer make-work if not harassment.
By contrast Applicants and Staff have asserted numerous objections to answering questions by Palmetto Alliance on these same contentions.
Palmetto Allaince Motions to Compel and to Require Answers from Applicants and Staff respectively on contentions 8,16 and 27 remain pending.
The flRC Appeal Board has approved the following Licensing Board formulation of a party's duty to respond to discovery.
In responding to discovery requests, a party is not required to engaged in extensive research. It need only reveal information in its possession or control (although it may be required to perform some investigation to deter-mine what information it actually possesses.) Assuming truthfulness of the statement, lack of knowlcige is always an adequate response.
Pennsylvania Power and Light Company,'elal. (Susquehanna Steam Electric Station, Units 1 and 2), ALAB 613, 12 NRC 317 at 334 (1980).
l Palmetto Alliance has agreed to produce for inspection all non-privileged documentary information in its possession on tne subjects in question; and in the body of its contentions, on the record of the Pre-hearing Conference and in its previous responses has endeavored to the best of its ability to disclose what it knows on the questions asked. The following answers supplement that information.
APPLICANTS' INTERR0GATORIES Contention No. 8
- 1. Active participation in operation.
- 7. As much as is needed.
- 14. Do not have.
- 20. A power reactor of a size comparable to Catawba in which heat is trans-ferred from the core to a heat exchanger by high temperture water kept under high pressure in the primary system.
- 22. Any individual who either manipulates a control of a reactor or directs another to manipulate a control of a reactor.
- 24. Same meaning as employed by Applicants.
- 27. Capable of functioning.
- 40. While Intervenor no longer has copy of FSAR examined in preparation of this contention, the FSAR at the South Carolina State' Library reflects as follows: Table 13.1.3-1, pp. 2-7-40 sumarizes the quali-fications of Shift Supervisors and Assistant Shift Supervisors William H. Miller, James F. Beattie, Gail B. Ice, B.A. Sigmon, John M. Hill, Reginald E. Kimroy, 'lichael J. Brady, Phillip J. Loss, Thomas Baumgardner, Robert W. Smith, Stacy S. Cooper, and Charlie Skinner.
- 41. See answer to No. 40,
- 43. See answer to No. 40.
- 47. Principal duty to direct.
- 53. Funtioning of the facility in a manner so as not to endanger.
- 61. Participation in operation.
- 72. While Intervenor no longer has copy of FSAR examined in preparation of this contention, the FSAR at the South Carolina State Library l sets out License Requirements, Section 13.2.3, and License Variances, Section ~13.2.4, reflecting experience requirements for Reactor Opera-tors and Senior Reactor Operators. No names of operators are set out in this copy of the FSAR.
- 73. See answer to No. 72.
- 78. Nearly but not exactly the same absence of participation.
l !
t
Contention No.16
- 1. Have not shown by reasoning, proved, or made clear.
- 9. Skill, power to do, expertness, talent.
- 17. So as not to endanger.
- 25. To put aside, accumulate, safekeep as is reflected by Applicants' plans and application.
- 29. Clusters of fuel rods which have been exposed to radiation as is reflected by Applicants' plans and application.
- 38. Other power reactors owned or operated by Duke Power Company as is reflected by Applicants' plans and application.
Contention No. 27
- 1. Call for as necessary.
- 26. Having the qualities necessary for.
- 47. Position in various places near the location of the facility.
- 55. The location of the facility.
- 78. To give an acceptable level of confidence.
STAFF It! TERR 0GATORIES Palmetto Alliance has previously responded to the questions of NRC Staff in its August 30, 1982 Res ponses by asserting
... answers to Interrogatoes of the NRC Staff are fully provided in the following answers to Appli-cants' interrogatories.
Id. at p. 3.
In its Motion to Compel, NRC Staff has identified three of its interrogatories not the same as Applicants:
...although there is some overlap between Applicants' and Staff's interrogatories on these contentions, there are
~
several Staff interrogatories which are clearly not included in Applicants' interrogatories (e.g. Interrogatories 6,10, 14), as to which there is no response whatsoever.
1 NRC Staff Motion to Compel Answers to Staff Interrogatories and Response to Palmetto Alliance Motion for Protective Order, dated 9/15/82 at p. 3.
Palmetto Alliance provides the following supplementary responses to these interrogatories.
- 6. - Not to our knowledge.
i 10. Intervenor lacks sufficient knowledge to answer.
- 14. Intervenor lacks sufficient knowledge to answer.
1
- I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of DUKE POWER COMPANY, et al. ) Docket Nos. 50-413
) 50-414 (Catawba Nuclear Station, )
Units 1 and 2 )
AFFIDAVIT OF MICHAEL F. LOWE I, flichael F. Lowe, do affirm as follows:
- 1. I am employed as Staff by Palmetto Alliance, Inc. at 21351s Devine Street, Columbia, South Carolina, 29205.
- 2. I an duly authorized to participate in answering interrogatories and requests for production regarding Palmetto Alliance contentions 8,16, and 27, and I affirm that the responses given are true to the best of my knowledge.
gichaelF.L'og l
l AFFIRMED AND SUBSCRIBED I B ME THIS DAY OF NOTARY PUBLI 'F j0RS@THCAROLINA V
UNITED STATES OF A?! ERICA NUCLEAP, REGULATORY C0!?ilSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) >
DUKE POWER COMPANY, et al.
Docket No. 50-413
) 50-414 (Catawba Nuclear Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of Palmetto Alliance Supplementary Responses to Applicants' and Staff's Interrogatories Regarding Palmetto Contentions 8, 16 and 27 in the above captioned matters, have been served upon the follow-ing by deposit in the United States mail this 6th day of November,1982.
James L. Kelley, Chairman William L. Porter, Esq.
Atomic Safety and Licensing Albert V. Carr, Jr., Esq.
Board Panel Ellen T. Ruff, Esq.
U.S. Nuclear Regulatory Duke Power Company Commission P.O. Box 33189 Washington, D.C. 20555 Charlotte, North Carolina 28242 Dr. A. Dixon Callihan Chairman Union Carbide Corporation Atomic Safety and Licensing P.O. Box Y Appeal Board Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Commission Dr. Richard Foster Washington, D.C.20555 P.O. Box 4263 Sunriver, Oregon 97701 Henry A. Presler Charlotte-Mecklenburg Environmental Chairman Coalition Atomic Safety and Licensing 943 Henley Place Board Panel Charlotte, North Carolina U.S. Nuclear Regulatory Commission J. Michael McGarry, III, Esq.
Washington, D.C. Debevoise & Liberman I
1200 Seventeenth St., N.W.
George E. Johnson, Esq. Washington, D.C. 20036 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Richard P. Wilson Scott Stucky Assistant Attorney General Docketing and Service Station State of South Carolina U.S. Nuclear Regulatory Comission Washinton, D.C. 20555 Jesse L. Riley 854 Henley Place Charlotte, North Carolina 28207 Rollprt Guild j Attorney for( tto Alliance l
. _ . _ _ , _ . _ . _ _ _ . _ . . _ ._. ..-.- __ .-.-. __ _____,._ -..._,, ..._.--___.~ ____, _ _ _ _ _ _ , - - _ . _ , . , - . _ . . . . _ . _ .