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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20045D8561993-06-21021 June 1993 San Luis Obispo Mother for Peace Supplemental Response to First & Second Sets of Interrogatories & Requests for Production of Documents Filed by Pacific Gas & Electric Co.* W/Certificate of Svc.Related Correspondence ML20045D8291993-06-18018 June 1993 Response to Third Set of Suppl Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6751993-06-0404 June 1993 Intervenor San Luis Obispo Mothers for Peace Third Set of Supplementary Interrogatories & Requests for Production of Documents to PG&E Re Aging.* W/Certificate of Svc.Related Correspondence ML20045A6401993-05-26026 May 1993 PG&E Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) Filed by San Luis Obispo Mothers for Peace. * W/Certificate of Svc.Related Correspondence ML20044F7701993-05-21021 May 1993 Intervenor San Luis Obispo Mothers for Peace Second Set of Supplemental Interrogatories & Requests for Production of Documents to Pge Cable Failures at Diablo Canyon Nuclear Power Plant.* W/Certificate of Svc.Related Correspondence ML20056C1891993-03-10010 March 1993 Pacific Gas & Electric Co Response to First Set of Interrogatories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc. Related Correspondence ML20128P2251993-02-16016 February 1993 Intervenor San Luis Obispo Mothers for Peace First Set of Written Interrogatories & Requests for Production of Documents to Pg&E.* PG&E Should Answer Interrogatories within 14 Days.W/Certificate of Svc.Related Correspondence ML20213E5791986-11-0606 November 1986 Response to Util Second Set of Interrogatories Re Reracking of Spent Fuel Pools.Equations of Motion Appear in Encl Computer Program.W/Proof of Svc ML20213E6091986-11-0606 November 1986 Response to NRC Second Set of Inerrogatories Re Proposed Reracking of Spent Fuel Pools.Not Possible to Either Identify or Supply All Ref Documentation Supporting Contentions.W/Proof of Svc.Related Correspondence ML20213E6201986-11-0606 November 1986 Response to NRC Second Set of Interrogatories.Contentions Re Proposed Reracking & Alternatives Based on Understanding of Existing Industry Practice & Currently Available Technology. W/Proof of Svc.Related Correspondence ML20213F5851986-11-0505 November 1986 Suppl to 861003 Response to Intervenors 860916 First Set of Interrogatories Re Metals Used in Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20213F5011986-11-0505 November 1986 Response to 861017 Second Set of Interrogatories Re Seismic Analysis of High Density Fuel Racks for PG&E for Diablo Canyon Nuclear Power Station & Request for Production of Documents.W/Certificate of Svc.Related Correspondence ML20211E2121986-10-20020 October 1986 Second Set of Interrogatories Re Contentions 1 & 2 Concerning Proposed Reracking of Spent Fuel Pools. Certificate of Svc Encl.Related Correspondence ML20215H6691986-10-20020 October 1986 Second Set of Interrogatories & Request for Production of Documents on Contentions I & Ii.Certificate of Svc Encl. Related Correspondence ML20211E1721986-10-20020 October 1986 Second Set of Interrogatories Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses on Spent Fuel Pool.Related Correspondence ML20211E1871986-10-20020 October 1986 Second Set of Interrogatories Re Contention 1 Concerning Proposed Reracking of Spent Fuel Pools.Related Correspondence ML20210S8921986-10-0606 October 1986 Response to Util Interrogatories Re Preparation for Upcoming Safety Hearings on Reracking of Spent Fuel Pools.Safety Issues Should Be Considered Before Amend Accepted.W/ Certificate of Svc.Related Correspondence ML20210S9651986-10-0606 October 1986 Answers to Sierra Club 860915 First Set of Interrogatories Re Reracking of Spent Fuel Pools.W/Certificate of Svc. Related Correspondence ML20210T2611986-10-0606 October 1986 Response to NRC Interrogatories on Contention 1 Re Util Responsibility to Demonstrate Safety of High Density Reracking.Intervenors Not Responsible for Solving Waste Storage Problem.W/Certificate of Svc.Related Correspondence ML20210S9711986-10-0303 October 1986 Response to Util & NRC First Set of Interrogatories & Request for Production of Documents.Interrogatories Opposed for Reasons Indicated.Certificate of Svc Encl.Related Correspondence ML20210T0731986-10-0303 October 1986 Response to Interrogatories & Request for Production of Documents Re Alternatives to High Density Reracking of Spent Fuel Pool at Facilities.Certificate of Svc Encl.Related Correspondence ML20210T0221986-10-0303 October 1986 Response to NRC Interrogatories & Request for Documents Re Contention 14.Related Correspondence ML20210S9241986-10-0303 October 1986 Response to San Luis Obispo Mothers for Peace First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20206U7481986-10-0303 October 1986 Response to 860916 Interrogatories & Request for Production of Documents Re Licensing Proceedings.Certificate of Svc Encl.Related Correspondence ML20210S9931986-10-0303 October 1986 Response to Consumers Organized for Defense of Environ Safety First Set of Interrogatories Re Reracking of Spent Fuel Pools.Certificate of Svc Encl.Related Correspondence ML20210T0541986-10-0303 October 1986 Response to Util First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20210B7341986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Util Submittals to NRC Fail to Contain Date Necessary for for Independent Verification of Claims on Consistency of Public Health & Safety & Environ.W/Certificate of Svc ML20214P8291986-09-16016 September 1986 Requests Response to Listed Interrogatories Re Design & Const of Fuel Ponds.Certificate of Svc Encl.Related Correspondence ML20214Q3521986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions 1-3 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210B6321986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention 14 Concerning Neutron Embrittlement & Other Metallurgical Deterioration & Environ Stresses to Structural Integrity of Spent Fuel Ponds ML20214Q3781986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contentions I & II Concerning Reracking of Spent Fuel Pools.Notice of Change of B Norton Address & Certificate of Svc Encl.Related Correspondence ML20210B6701986-09-16016 September 1986 Interrogatories & Request for Documents Re Contention That Applicant Has Not Adequately Considered Alternatives to Proposed Reracking of Spent Fuel Pools ML20214Q2981986-09-16016 September 1986 First Round of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20214Q3621986-09-16016 September 1986 First Set of Interrogatories & Request for Production of Documents Re Contention 14 Concerning Reracking of Spent Fuel Pools.Related Correspondence ML20210E1781986-09-15015 September 1986 Interrogatories & Request for Production of Documents Re Theoretical Work Concerning Displacement of High Density Spent Fuel Racks Due to Hypothetical Seismic Excitation. W/Certificate of Svc.Related Correspondence ML20214R1401986-09-15015 September 1986 Interrogatories Requesting All Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools, Dry Cask Onsite Storage & Cost/Benefit Assessment on Reracking.Certificate of Svc Encl.Related Correspondence ML20214R2341986-09-15015 September 1986 Interrogatories Requesting Documents Re Evaluation of Alternatives to High Density Reracking of Spent Fuel Pools & Dry Cask Onsite Storage as Alternative to High Density Reracking.Certificate of Svc Encl.Related Correspondence ML20081D7851983-10-26026 October 1983 Request for Production of Documents by NRC at 831107 Hearing in Avila Beach,Ca.Certificate of Svc Encl ML20080S2831983-10-14014 October 1983 Second Supplemental Response to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20080Q3741983-10-0707 October 1983 Second Supplemental Answers to First Set of Interrogatories. Certification of Counsel & Prof Qualifications Encl ML20080Q3851983-10-0707 October 1983 First Supplemental Answers to Second Set of Interrogatories. Certification of Counsel Encl ML20080Q3951983-10-0707 October 1983 First Supplemental Answers to Fourth Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl ML20085J5951983-10-0707 October 1983 Fifth Supplemental Response to First Set of Interrogatories. Portions of RB Hubbard & Fj Samaniego 821221 Direct Testimony & Certificate of Svc Encl ML20080Q4441983-10-0505 October 1983 Response of Idvp to Interrogatory 57 in Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20078E1861983-10-0303 October 1983 Fourth Supplemental Response to First Set of Interrogatories.Certificate of Svc Encl ML20078D5091983-09-29029 September 1983 Supplemental Response to Second Set of Interrogatories. Certification of Counsel & Certificate of Svc Encl.Related Correspondence ML20080M8521983-09-28028 September 1983 First Supplemental Answers to Third Set of Interrogatories. Prof Qualifications & Certificate of Svc Encl.Related Correspondence ML20078E1331983-09-28028 September 1983 First Supplemental Response to Third Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20080L5721983-09-26026 September 1983 Response to Fourth Set of Interrogatories.Certification of Counsel & Certificate of Svc Encl ML20078B8021983-09-23023 September 1983 Idvp Answers to First Set of Interrogatories.Certificate of Svc Encl 1993-06-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059C7361993-08-24024 August 1993 Intervenor Exhibit I-MFP-88,consisting of NRC Insp of Diablo Canyon Units 1 & 2 IR 05000275/19920161993-08-24024 August 1993 Intervenor Exhibit I-MFP-137,consisting of Insp Rept Re Dockets 50-275/92-16 & 50-323/92-16,dtd 920707 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059M5041993-08-24024 August 1993 Staff Exhibit S-2,consisting of Re Notice of Violation ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 1999-09-20
[Table view] |
Text
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?d
-. .. UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
-In the Matter of )
)
PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA (Diablo Canyon Nuclear Power Plant ) (Spent Fuel Pool)
Units 1 and 2) )
NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM TliE SIERRA CLUB, SANTA LUCIA CHAPTER The NRC staff hereby requests that the Sierra Club, Santa Lucia Chapter (Sierra Club) pursuant to 10 C.F.R. II 2.740b and 2.741, an-swer separately and fully, in writing under oath or affirmation, the fol-lowing interrogatories and produce or make available for inspection and copying, all documentary material identified in responses to interrogato-ries below. Each response to the ' interrogatories below shall be under oath or affirmation of the individual (s) who contributed thereto. For all references requested in these interrogatories, identify them by author, title, date of publication and publisher if.the reference is published, and if it is not published, identify the document by the author, title, the date it was written, the qualifications of the author relevant to this pro-ceeding, and where a copy of the document may be obtained.
Sierra Club Contention I(A) It is the contention of the Sierra Club, Santa Lucia Chap-ter (Sierra Club), that the report submitted to the Nucle-ar Regulatory Commission (NRC) entitled Reracking Spent Fuel Pools Diablo Canyon Units 1 and 2 and other commu-nications between Pacific Gas and Electric Company (PG&E) and the NRC which are available to the public on g6091eo157860916 R
O ADOCK 05000275 PDR
- the same subject (the Reports) fail to contain certain rel-
~
evant date necessary for independent verification of the claims made in the Reports regarding consistency of the proposed reracking with the protection of the public health and safety, and the environment.
In particular, the reports fall to contain data regarding:
- 3) the expected velocity and displacement of the spent fuel pools (pools) as a function of time in three di-mensions during the postulated Hosgri earthquake (PHE);
- 4) the expected maximum velocity and displacement of the racks obtained from the computer modeling of rack behavior during the PHE; 1(B). It is the contention of the Sierra Club that the Reports fail to include consideration of certain relevant conditions, l phenomena and alternatives necessary for independent verification of claims made in the Reports regarding con-sistency of the proposed reracking with public health and safety, and the environment, and with federal law.
In particular, the Reports fail to consider:
- 2) the resonant behavior of the spent fuel assemblies in the racks in response to the PHE and the conse-quences of such behavior;
- 7) alternative on-site storage facilities including:
(i) construction of new or additional storage facili-ties and/or; (ii) acquisition of modular or mobile spent nuclear fuel storage equipment, including spent nuclear fuel storage casks;
- 8) the use of anchors, braces, or other structural mem-f l bers to prevent rack motion and subsequent damage during the PHE;
- 9) the use of "boroflex" neutron absorbing material for all spent fuel racks.
l
- 11. It is the contention of the Sierra Club that the proposed reracking is inconsistent with the protection of the public health and safety, and the environment, for reasons which in-clude the following:
l (A) during the PHE, collisions between the racks and the pool walls are expected to occur resulting in:
f .
-- - (1) impact forces on the racks significantly larger .
than those estimated in the reports; (2) impact forces on the racks significantly larger than those expected to damage the racks; (3) significant permanent deformation and other damage to the racks and pool walls; (4) reduction of the spacings between fuel assemblies; (5) increase in the nuclear criticality coefficient k(eff) above 0.95; (6) release of large quantities of heat and radiation; (7) radioactive contamination of the nuclear power plant and its employees above the levels permit-ted by federal regulations; (8) radioactive contamination of the environment in the vicinity of the nuclear power plant above the levels permitted by federal regulations, and (9) radioactive contamination of humans and other living things in the vicinity of the nuclear pow-er plant above the levels permitted by federal regulations.
l (B) during the PHE, collisions between groups of racks with each other and/or with the pool walls are ex-l.
pected to occur with results similar to those de-scribed in II(A) above.
Interrogatories For each of the foregoing contentions separately:
1-la. Upon what person or persons do you rely to sub-stantiate in whole or in part your position on Contentions I and II?
- b. Provide the addresses and education and professional qualifications of any persons named in your response to a. above,
- c. ' Identify which of the above persons or any other person you may call as witnesses on this contention.
t 1-2. - Provide summaries of the views, positions or pro-posed testimony on Contentions I and II of all per-
. sons named in response to Interrogatory 1-1, that you intend to present as witnesses during this proceeding.
1-3. State the specific bases and references to any docu-ments upon which the persons named in response to Interrogatory No . 1-1 rely to substantiate their views regarding Contentions I and II.
1-4. With regard to Contentions I and II identify all doc-umentary or other material that you intend to use during this proceeding to support these contentions and that you may offer as exhibits on these conten-tions or refer to during your cross-examination of witnesses presented by the Licensee and/or the NRC staff.
1-5. With regard to Contention II(A)(6) identify the spe-cific source and cause of the ~ "large quantities of heat and radiation".
Respeetfully sulmitted, IcGurren Counsel for NRC Staff-Dated at Bethesda, Maryland this 16th day of Septerber,1986
e DOCKETED USNRC
-. - UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION '86 SEP 17 A10:28 BEFORE Tile ATOMIC SAFETY AND LICENSINGrBOARD r. 3 - '
00Ch: 1:mi ^ ' "
In the Matter of )
)
PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 OLA COMPANY ) 50-323 OLA
) (Spent Fuel Pool)
(Diablo Canyon Nuclear Power Plant )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS FROM CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY REGARDING CONTENTION 14", "NRC STAFF INTERROGATORIES AND RE-
_ QUEST FOR DOCUMENTS FROM SAN LUIS OBISPO MOTIIERS FOR PEACE" and "NRC STAFF INTERROGATORIES AND REOUEST FOR DOCUMENTS FROM THE SIERRA CLUB, SANTA LUCIA CHAPTER" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indi-cated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 16th. day of September,1986:
B. Paul Cotter, Jr. , Chairman Bruce Norton, Esq.
Administrative Judge Norton, Berry, French Atomic Safety and Licensing Board Panel & Perkins, P.C.
U.S. Nuclear Regulatory Commission P.O. Box 10569 Washington, D.C. 20555* Phoenix, AZ 85064 Glenn O. Bright, Esq. Nancy Culver Administrative Judge 192 Luneta Street Atomic Safety and Licensing Board Panel San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission Washington, D.C. 20555*
Mrs. Jacquelin Wheeler Dr. Jerry Harbour 2455 Leona Street Administrative Judge San Luis Obispo, CA 93401 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission l Washington, D.C. 20555*
Richard E. Blankenburg Philip A. Crane, Jr. , Esq.
Co-publisher (77 Beale Street, 31st Floor)
Wayne A. Soroyan, News Reporter P.O. BOX 7442 South County Publishing Company San Francisco, CA 94120 (94106)
P.O. Box 460 Arroyo Grande, CA 93420 / DESIGNAT ORIGINAIJ Q *[
i l
e Docketing and Service Section Mr. Lee M. Gustafson Office of the Secretary Pacific Gas and Electric Co.
U.S. Nuclear _ Regulatory Commission Suite 1100 Washington, D.C. 20555* 1726 M Street, N.W.
Washington, D.C. 20036-4502 Atomic Safety and Licensing Dr. Richard Ferguson Board Panel Vice-Chairman U.S. Nuclear Regulatory Commission Sierra Club Washington, D.C. 20555* Rocky Canyon Star Route Creston, CA 93432 Atomic Safety and Licensing Appeal Board Panel Laurie McDermott, Co-ordinator U.S. Nuclear Regulatory Commission C.O.D.E.S Washington, D.C. 20555* 731 Pacific Street Suite #42 Managing Editor San Luis Obispo, CA 93401 San Luis Obispo County Telegram-Tribune Dian M. Grueneich, Esq.
1321 Johnson Avenue Edwin F. Lowry P.O. Box 112 Grueneich & Lowry San Luis Obispo, CA 93406 345 Franklin Street San Francisco, CA 94102 s / -
Hen Vf.O %feUurrM Coun or NRC Staff
_ . _ - _ . _ _ _ _ - __ _ __