ML19276G578

Interrogatories & Document Requests to Nrc,Submitted by Intervenors Skagitonians Concerned About Nuclear Power. Requests Include Info Re Thermal Pollution & Salmonids, Earthquakes & Generic Safety Issues Raised by TMI

ML19276G578
Person / Time
Site:	Skagit
Issue date:	05/29/1979
From:	Leed R LEED, R.M.
To:
References
NUDOCS 7907130045
Download: ML19276G578 (6)

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NRC PImLIC ImCmfENT ROmf k p W 7 UNITED STATES OF AMERICA gJg> p NUCLEAR REGULATORY COMMI SSION REFOPE THE ATOMIC SAFETY AND LICENSING APPEAL B0ARD In the Matter of )

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PUGET SOUND PONER & LIGHT ) DOCKET NOS. STN 50-522 COMPANY, et al., ) 50-523

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(Skaai t Nuclear Power P roject , )

Units 1 and 2) )

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INTERVENOR SCAND' S INTEPROGATORIES AND REOURSTS P3 R PRODUCTION TO STAFF OF MAY 29, 1979.

In accordance with 10 CFR, S2.740R and 10 CFR S2.741, clease answer the followina Interroaatories and respond to the accompanvino Pequests for Production.

Documents to be. produced should be presented at the offices of undersioned counsel at 9:00 a.m. on the 20 th day af ter service of this discovery, or at such other time and olace as may be acreed upon.

INTERROGATORY NO. 1. Since Januarv 1, 1978, has eny information concerning research or studies come to the at-tention of the S taf f, or any of its consultants regardina any of the followina:

(a) The svneraistic, lethal, or sublethal effects of thermal nollution, chlorine, or heavv metals uoon sa.1monids at anv staae of their lif e evcle?

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(b) Whether an attraction phenomenon has been ob-served with resoect to salmonids, particularly juveniles, and thernal discharaes.

I f so, olease describe such information, study or re-oort in detail, and state whether such information justi-fies alterino anv of the conclusions regardino fisheries irroacts of the project stated in the EIs, or in the tes ti-mony on fisberies presented by Staff.

ANSWER:

2. Please describe in detail and with particular-ity, all studies, reports, information, data anel other information of any kind which S taf f has re ce i ve<34 , other than in this docket, and which certain in any way to the Strait Creek Pault and the 1972 earthquake in the state of Washington. You may furnish cocies of documents in lieu of describing them.

ANSWER:

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3. Please describe all oublications and other docu-ments, whether or not publi clv disseminated, which certain to staf f and commission review and analvsis of the follow-inq subjects:

(a) The Three Mile Island accident of 1979.

(b) Actual or potential generic safety questions affecting the desian of the type of General Electric re-actor which is proposed for the Skagi t Plants.

(c) Evacuation plans and emercency plannina.

AN SWE R:

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4 Please describe speci fically all documents, nans, photocraphs, and other data or information of any kind which was furnished to you at, or displayed to you at, the conf erence between S taf f, USGS, and the Applicant, which took place in Landover, Maryland on April 18, 1979.

ANSWER:

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5. Request for Production No. 1. Please produce for inspection and copyino on the 21st dav after the date of service of these requests for production uoon you, at the offices of intervenor's counsel all documents described in your answers to the forecoing interroaatories at 9 :0 0 a. m.

or at such other time or place as may mutually be agreed upon.

6. Peauest for P roduction No. 2 Please produce for inspection and copying at the of fi ce of intervenor 's counsel on the 21st day after the service of these inter-rocatories and requests for production upon you, at 9:00 a.m., or at such other time and nlace as may be mutually aareed uoon the following:

All work paners , work ing files, notes, memoranda, includino intra-aaency memoranda, of voor consultants, employees of the US Geolooical Survey, who hava reviewed and who are reviewino the site safety asnects of the Skaci t Plant, including Dr. William Havs and Mr. D evi ne.

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Interrocatorv No. 5. How many drafts have been pre-pared for the PSEP and the SER for the Skacit Project, and who has custody of those drafts? Please describe the date of each such drafts, and oive the number of paces it contains. Also, please produce each draft for inspection and copying in accordance with Recuest for Production No.

I above.

AN SWE R :

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Interrocatorv No. 6. Please describe all notes, work-ino papers, calculations, tables, data, and other materials of any kind or nature relied upon by Dr. J acques Read in connection with the oreparation of the testimony which he offered herein. Please produce all such documents for in-spection and copvino in accordance with Recuest for Pro-duction No. 1 above.

ANSWER:

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Interrnaatory No. 7 Please describe all documents and records, includina maps, chotoaraohs, memoranda, corresoon-dence, and field notes, which certain in any way to the staf f's analysis and review of alternative sites for the Skapi t project. Please produce all such documents for inspection and conving in accordance with Request for Production No. 1.

DATED thi s "? day of flav , 1979.

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/$bt ROGER M. LEED Counsel for Intervenor SCANP

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