ML20214Q352

First Set of Interrogatories & Request for Production of Documents Re Contentions 1-3 Concerning Reracking of Spent Fuel Pools.Related Correspondence

ML20214Q352
Person / Time
Site:	Diablo Canyon
Issue date:	09/16/1986
From:	Norton B PACIFIC GAS & ELECTRIC CO.
To:	SAN LUIS OBISPO MOTHERS FOR PEACE
Shared Package
ML20214Q354	List: ML20214Q352 ML20214Q362 ML20214Q378
References
CON-#386-780 OLA, NUDOCS 8609240320
Download: ML20214Q352 (6)

Text

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DOLMETED 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 '86 SEP 19 P5 :40 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ff0CNTN G - Wbhf.

) DocketNos.50-275Sh i 5 In the Matter of '

) 50-323 - l

)

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

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7 (Diablo Canyon Nuclear Power )

Plant Units 1 and 2) ) >

8 ) ,

9 LICENSEE PACIFIC GAS AND ELECTRIC COMPANY'S 10 FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE SAN LUIS OBISPO MOTHELS FOR PEECE <

11 12 Pursuant to 10 CrR 2.740b, Licensee PACIFIC GAS AND ELECTRIC COMPANY 13 hereby propounds the following interrogatori,es and document requests to the 14 San Luis Obispo Mothers for Peace on its Contidions 1, 2, and 3.

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

l 20 2. Where you have incomplete information that precludes your fully 21 answering an interrogatory, give such information as you have and state what 22 information ycu do not have. If you are unable to give the information in the 23 form sought but have the information aggregated differently, give the 24 information in the form in which you have it and explairsthe reason for the 25 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; i 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, 2C 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 s 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 1 3 video recordings. "Mritings" 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 Contention 1 10 1.. State each and every fact upon which you base your contention 11 that the applicant has not adequately considered raracking alternatives.

12 2. What would constitute " adequate consideration" of reracking 13 alternatives?

14 3. You list three alternatives that should be included as "some 15 alternatives" to be considered. List each and every other alternative you 16 believe should be considered.

17 4. State each and every fact that supports your belief that the 18 alternatives listed in Contention la through Ic are reasonable and should be 19 considered?

20 5. State each and every fact that supports your statement that 21 alternatives should be considered because of the increased danger posed by the 22 close proximity of the Hosgri fault.

23 6. What regulations require consideration of reracking alternatives 24 due to proximity of an earthquake fault?

25 7. What regulations require reracking alternatives to be considered?

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1 1 8. What regulations specify the type or number of reracking 2 alternatives that should be considered?

3 9. Identify the " government owned spent fuel facility" stated in 4 part a. of Contention 1.

5 10. How would derating the facility reduce the generation of spent 6 fuel?

7 11. How would reducing plant output reduce the generation of spent 8 fuel?

9 12. Provide a list of contractors who accept spent nuclear fuel 10 assemblies.

11 13. Provide a list of other nuclear plants that are contracting for 12 the storage of spent fuel or the shipping of same to a government owned 13 storage facility.

14 14. Provide a list of nuclear facilities that have derated or 15 shutdown to reduce the generation of spent fuel.

16 Contentions 2 and 3 17 15. State each and every fact upon which you base your contention 18 that the applicant failed to evaluate or analyze costs associated with 19 increased spent fuel storage (for plant personnel and for offsite individuals).

20 16. What are the specific health effects that you allege would 21 result from the additional exposures?

22 17. Define " normal operation" as used in the contention.

23 18. What would constitute "overall costs" of the alleged health 24 effects or medical costs?

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1 19. State each and every fact upon which you base your allegation 2 that there will be increased radioactivity levels during normal operation due 3 to increased spent fuel storage?

4 20. State each and every fact that supports your belief that such 5 increased levels will lead to additional exposures at the plant and offsite?

6 21. Identify the radiological release sequence during normal 7 operation that may result in additional exposures of plant personnel and of 8 individuals offsite.

9 22. Up to what distance from the site would you contend must be 10 included in an analysis of overall costs associated with any alleged 11 additional exposures due to increased spent fuel storage?

12 General 13 23. For each answer to these interrogatories, and all subparts 14 thereto, identify each person who participated in the preparation of your 15 answers pursuant to 10 CFR 2.740b(b).

16 24. Provide the professional qualifications, if any, of each such 17 person identified.

18 25. Please identify each and every document which you claim supports ,

19 each fact set forth in your responses to the preceding interrogatories and 20 correlate each such document as specifically as possible (page and paragraph  !

21 number) with each specific response.

22 RE00EST FOR PRODUCTION OF DOCUMENTS 23 1. Pursuant to 10 CFR 2.241, you are requested to produce each 24 document identified in your answers to the preceding interrogatories.

25 2. You are requested to produce all documents you intend to use or 26 rely upon in written testimony or oral argument.

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1 3. You are requested to produce all documents you intend to have 2 marked for identification at the hearing of this matter or which you will 3 attach to any written testimony.

4 4. The documents should be produced on October 22, 1986 at 5 9:30 a.m. at the 31st floor conference room, 77 Beale Street, San Francisco.

6 7 Respectfully submitted, 8 BRUCE NORTON c/o P. A. Crane 9

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10 ROBERT OHLBACH PHILIP A. CRANE, JR.

11 RICHARD F. LOCKE Pacific Gas and Electric Company 12 P. O. Box 7442 San Francisco, California 94120 13 (415) 781-4211 14 Attorneys for Pacific Gas and Electric Company 15 16 17 By y uan k Bruce Norton 18 19 DATED: September 16, 1986 20 21 22 23 l

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