ML20008E397

First Set of Interrogatories & Requests for Production of Documents Directed to E Cumings,R Griffith,L Johnston & R Lemmer Re Consolidated Contention on Effects of low-level Radiation.W/Certificate of Svc.Related Correspondence

ML20008E397
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	10/22/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Cumings E, Griffith R, Johnston L AFFILIATION NOT ASSIGNED
References
ISSUANCES-CP, NUDOCS 8010270522
Download: ML20008E397 (7)

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Octob0r 22, 1980

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A UNITED STATES OF AMERICA Cir NUCLEAR REGULATORY COMMISSION cc , f %g ,g

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BEFORE THE ATOMIC SAFETY AND LICENSING BC)rRD- 2 aj IFg In the Matter of S 4 h/3

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HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-4'6 F

' S (Allens Creek Nuclear Generating S Station, Unit 1) S FIRST SET OF INTERROGATORIES AND REQUESTS FOR

, PRODUCTION OF DOCUMENTS FROM HOUSTON LIGHTING

& POWER COMPANY TO INTERVENORS ELINORE CUMINGS, ROBIN GRIFFITH, LEOTIS JOHNSTON AND ROSEMARY LEMMER RELATING TO THE CONSOLIDATED CONTENTION ON HEALTH EFFECTS OF LOW LEVEL RADIATION Preface Pursuant to Section 2.740b and 2.741 of the Com-mission's Rules of Practice, Houston Lighting & Power Company propounds the following Interrogatories and Re-quests for Production of Documents to Elinore Cumings, Robin Griffith, Leotis Johnston and Rosemary Lemmer (here-inafter "Intervenors"). Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person or persons making them no later than fourteen (14) days after service of these Interroga-tories and Requests for Production, and each document requested should be produced no later than thirty (30) days after service of these Interrogatories and Requests for Production.

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Interrogatories

1. a. Have you reviewed Section S.S.4 of the NRC Staff's Final Supplement to the Final Environmental State-ment (hereinafter "FSFES") dated August, 1978 entitled

" Radiological Impacts from Routine Operation"?

b. Do you claim that releases of radioactive materials from the routine and normal operation of the proposed Allens Creek plant ("ACNGS") will be different from the releases of such material calculated by the NRC Staff in Tables S.S.10 and S.S.16 of the FSFES?

c. If yen claim that the expected releases of radioactive materials during routine or normal operation of ACNGS are different from those calculated by the NRC Staff in Section 5.4 of the FSFES, identify specifically the amount of radioactive material which you claim will be released.

Identify all documents which you rely upon to support your calculations as to the amount of the releases of radioactive materials during normal or routine operation of ACNGS. Pro-duce these documents for inspection and copying.

d. Do you agree with the NRC Staff's calculations of meteorological factors "or ACNGS set forth in Table S.S.11 of the FSFES? If not, specifically explain in what way you disagree with the Staff's calculations. Provide a copy of any calculations you have performed relating to meteorological dispersion characteristics at ACNGS.

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e. Do you agree with the NRC Staff's calculations of dose commitments to the population surrounding ACNGS set forth in Table S.5.14 of the FSFES? If not, specifically explain in what aspect you disagree with the Staff's calculations. Provide a copy of any calculations you have performed relating to dose commitments to the population surrounding ACNGS.

2. a. In Section S.S.4.4 of the FSFES, the Staff concludes that "there will be no measurable radiological impact on man from routine operation of the ACNGS." Do you agree with the Staff's conclusion?

b. If you do not agree with the Staff's conclu-sion in 2.a. above, describe specifically in what way you disagree with this conclusion. Identify each and every document which you rely upon to support your assertion that the Staff's conclusion in Section S.S.4.4 of the FSFES is erroneous. Produce for inspection and copying all such documents.

3. a. In Section S.S.4.5 of the FSFES, the Staff concludes that "no measurable radiological impact on populations of biota is expected as a result of the routine operation of this plant." Do'you agree with the Staff's i

conclusion? I l

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b. If you do not agree with the Staff's conclu-sion in 3.a. above, describe specifically in what way you disagree with this conclusion. Identify each and every document which you rely upon to support your claim that the Staff's conclusion in Section S.4.5 of the FSFES is erroneous.

Produce for inspection and copying all such documents.

4. a. Identify each witness, other than an expert witness, who Intervenors may call in this proceeding, and provide a summary of the testimony which each such witness is expected to offer,

b. Identify all documents upon which each such witness may rely in any way, and provide for inspection and copying all such documents.

5. a. Identify each expert witness who Intervenors expect to call in this proceeding,

b. State the qualifications and credentials of each such expert witness.

c. Provide a summary of the testimony which each such witness is expected to offer.

d. State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony,

e. Identify all documents prepared by, for, or under the supervision of each such expert witness, or reviewed

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or relied upon by such expert in formulating the expert's opinions and conclusions, including workpapers, preliminary outlines ~and memoranda, and communications between such expert and Intervenors. Provide for inspection and copying all such documents.

Respectfully submitted, OF COUNSEL: J Gregorf Cppel&nd Thomas Bdddle, Jr.

BAKER & BOTTS D rrell Hancock 3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. David Raskin Washington, D. C. 20036 1025 Connecticut Ave., N.W.

Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING &. POWER COMPANY I

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

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing First Set of Interrogatories and Requests for Production of Documents from Houston Lighting & Power Company to Intervenors Elinore Cumings, Robin Griffith, Leotis Johnston and Rosemary Lammer Relating to the Consolidated Contention on Health Effects of Low Level Radiation in the above-captioned proceed-ing were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 22nd day of October, 1980.

Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing . Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 Mr. Gustave A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Mr. Chase R. Stephens Atomic Safety and Licensing i Docketing and Service Section Appeal Board Office of the Secretary U.S. Nuclear Regulatory of the Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 Susan Plettman Ricaard Black David Preister Staff Counsel l Texas Attorney General's Office U.S. Nuclear Regulatory P. O. Box 12548, Capitol Station Commission ,

Austin, Texas 78711 Washington, D. C. 20555  ;

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• Bryan L. Baker Brenda McCorkle 1118 Montrose 6140 Darnell Houston, Texas 77019 Houston, Texas 77074 J. Morgan-Bishop W. Matthew Perrenod 11418 Oak Spring 4070 Merrick Houston, Texas 77043 Houston, Texas 77025 Stephen A. Doggett F. H. Potthoff P. O. Box 592 7200 Shady Villa, No. 110 Rosenberg, Texas 77471 Houston, Texas 77055 John F. Doherty Wayne E. Rentfro 4327 Alconbury P. O. Box 1335

. Houston, Texas 77021 Rosenberg, Texas 77471 Carro Hinderstein William Schuessler 609 Fannin, Suite 521 5810 Darnell Houston, Texas 77002 Housten, Texas 77074 D. Marrack James M. Scott 420 Mulberry Lane 13935 Ivy Mount Le11 aire, Texas 77401 Sugar Land, Texas 77478

+ , hR b' J. Gregory C eland 9

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