ML19224C515
| ML19224C515 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/25/1979 |
| From: | Siegfried K CITIZENS FOR ENERGY & EMPLOYMENT |
| To: | |
| Shared Package | |
| ML19224C516 | List: |
| References | |
| NUDOCS 7907020479 | |
| Download: ML19224C515 (5) | |
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NRQ PUEfC DOCUMEEE 100M CEP Interror;otories to Applicant Pet the f.icensing P,oard order of I' arch '?l.1979, Citizens for Euple /m 3n' and Ena:gy (CEE) reque ts the Applicant to answer tha follo' cing iv a roga-tor 13 ithin the time lhaits established by a foresaid ordar.
Such answere ; hall ba under oath, au where such answer makes re.iensa my other document (including the PSAR), then wt forth completaty uw
.t of each such reference or attach a copy. As used with!n thoce !n um-D'l>-
.torie >, the word " writing: " (or vcorau of similar importT shall in$ M ill
". " - rltion, typau, printed arid photoatated matter, including photog: ' Ju, dupli-PA atiginals, c irbon copies, Thermofa> copies, photostatic cept :0 cmJ Of
%p g %+ pthe. copir s theraaf, including drafts thereof, in your posession, < m.cd'.
or cm'a ul, eritten, made, deliv" red or recalv :d et any time up to m.i in-h,cr.4 c! ud ing
'ay 25, 1979, including, but 'cithout limiting the general!t:. of tha j.). h dMir,itica, all corr ' conaonce, telegrams, memoranda, rainutuu of oceii:n;a,
NN cli at mem.;r un', acacunt carda, lenos, dccuments of title, r.
cm w call ad ch acP, ban'. utalements, record' of talephone calls nuam
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racetinu, ag:oor,:en4, contracts and notes, whether formal or info aal.
h[]9 The, interrogatorios are not intended to call for writing wh!ch a > m.
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to u valid erivilega; ho/rever, you shall be requhed to describa g. < ral b 7-th ' //rit.ingr a s to,vhich you may claim privilegn in order that oppo;mnity
- h for argerm nt thereon may be had.
272 130 In sre,a torics s
1.
I.h ' all incid intr of physical intrusion on the plant site from tS b :yinnin; of contruction tc th" pr~nt by unauthorized parsons, includire; an: in t ru,--
lons by parsons authorized to be on the plant site, but nut in spacific cu sa:
Por each such intrusion, provide copies of any reports or record:
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ternally, th. date.s of such intrusions, the parson or parco:.s hwalv-d in the et ent, cud wbt str.ps were taken to prevent furthe: intrustens o: that nature
.h ; liat any demage or suspected damage that may hw o '. Mn cauaed by sur:h intrusions. Provida a copy of any security plans tha Applicont us now o-has used pre /lously that wa s designed t.a.: top un.ndhorbari intr t in!on a If some of such plans are not in writing, e:: plain why anc' arovide a detailed nummaty of such olans 2.
Provide a copy of the
. plicant's current and ani pr vious Quality
, :um: -
Inspection Program Planc. If at any point, the Nuctuar RNu@' ': 3< 'ox a,
or other appropriate body has required a change in such pl. u > c. h tionod >ny partior< of the cur ent or previoua plans, provi6 a n y o c't 7007020t[7],
Fermi 2 Interrcptories, May 25, 1979
-1 questions or challenges. List all reinspections duno of any and all plani components, particularly including, but not limitcd to, reinspection ofoli large and small bore pipe hangers and welds of safety related components lo a result of any inspection or reinspection, has installation or work don in the plant he 'n redone If so, de mribo spocificall, all construcHon e Lutallation.mt tha t has buen rudane, and wn dam that redona woi ha.;
al.;o been reinspected to see if it was done proparly.
3.
List in detail all quality assurance documents that have ever been kept by Applicant. Ilave any of those records ever been destroyed, misplaced or lost by Applicant? If so, list all such documents destroyed, ralsplacad or lost by Applicant, and explain v;hy such documents are no longer avaihble.
Has Applicant or its contractors maintained a so-called daily stte icc; that is available for inspection by interested parties e-by the Compliance rivis-lon of the Nuclear Regulatory Commission? Doet Applicant or its contractor maintain "significant deficiency reportr" or "Significant deficiency follow-up reports" or documents of a similar nature? If so, are these documents class-ified as being confidential ? If so, why was such e decision made. If not, can one determine, alter the fact, whether such " deficiencies" were corrected ?
Has the Petroit Edison Company and its co-applicants retained responsibility for the establishment and execution of the quality assurance program? If not, provide a copy or portion of the contract between you and such contractor that does have such responsibilitj.
D lias the Eetroit Edison company or its contracturc ever had supervisory per-sonnel replaced for whatcver recon? If so, list the specific individuals C2g3 replaced, their job titles, the reason they were replaced and copics of any M
and all documentn related to their dismissal, transfer or voluntary resig~ na-tian. Has the Detroit Edison Company ever replaced, dismissed or accepted the voluntary resignation of any contractor or subecatractor. If so, explain DTil specifically the contractor or subcontractor replaced, the reason for such rv placement, and copie., of all documen ts related to the replacement. Have any of Applicant's contractors ever replaced a *.bcontractor? If so, state the subcontractor so replaced, the reason for suca replacement and copias of all documents related to the replacement. IIas Aoplicant or an'/ of its contractors
.or subcontractors ever dismissed, laid off or caused the forced resignation of any employee 'verking on the plant site. If so, list all such employees, their date of hire and fir e, the reason for their being let go, and copies of all docu-ments related to such dismiscal. Has any employee ever complained to Appli-cant or its contractors or subcontractors about problems with qualltv assurance fr.m,
at the plant? If so, list the employee making such a complaint, the date of the complaint, anf action taken to resolve the complaint, and coplec of all documents related to auch complaint. Has any emoloy a of the I.pplicant, its contractors or subcontractors ever oecn. dismissed, laid off or caused to resign because of a complaint related to quality assurance ? If so, name the employee, the date of such dismissal, the employee's address at the time of dismissal, the reason stated for such dismissal and copies of all oocumants related to <,uch dismiss 21.
272 131
Fermi 2 Intmrogatorus, May 25, 1979 L
i 5.
List all flaws in construction that have been idantified during the contru=.on of the plant throuah inspection or reinspection. per each such flas., provi e a copy of the inspection or reinspection report, 0:. plain ' / hat was done to.eme-dy the problem, whether the repair or replacem 2nt was toinspected, m,d t ole s of all documr nts related to the reinspection or repaire. Thi' listin', of H t.
mid inclum, I.ut la n t t i a lter! t.,
' :f nj o! a m
at ic ',
0u 3 in the plant, particularly the concrete base, and any hairline crac b s in < :oc-tural ateel in the plant, particularly that steel currounding tha dry '; ell.
6.
provida a copy of all cocuments relating to the radiation monitocino str a for the plant. IIas the Nuclear Regulatory Commiscicn or other apwohia:
regulatory body ever que ationed aspects of the proposed monitoring sy lte n?
If so, list all such qu,stions, what s/as done to resolve the proble. :, an i p: ovide copien of all documents pertaining thereto. Any inf ormation providc d regarding the radiation monitoring system should indicate the type of eqe p-munt to be used, what types of radiation will be monitored and how of ten, and the proposed maintenanc-plan to insure the equtpment is proparls iunc-loning. Also provide information as to whether the monitoring plan will in-clude- (1) continuouc monitoring on the lake for air and water that can ba read remotely, and (2) continuous mon!toring on thn site boundary that can be read remotely. If not, explain why and also indicate whether such a plan has ever been proposed by the NRC or other regulatory body or by an employee of f
Applicant or its contractors.
Q 7.
provide all documents relating to reactor coolant piping, including, but not gp limited to, tha typ, of materials to bc used, the specified installation pro-Dru cedures, whather there w!!1 be undercuts in such piping allowed, anti what D C2 proydures the Tcplicant intendr to implemc nt for inspection and maintenant d) of such piping. Is Applicant aware of potential problema related to cracking FR due to stress or corrosion? If so, describe Applicant's knowledge of such a
M J1 probleras and provide copies of all documents that nonlicant has u: ed to on-darstand and eliminate such problems.
b.r,, 1 8.
provide all document related to electrict. cables to be us"d in the plant, in-cluding, but not lir:ited to, the spccific materiale to be used in thc cable:,
and insulation, the spacified installation precedure and what procedut o, thc
.'ipplicant intends to implement for insnoction and maintenance of such cable.>.
Is Applicant aviare of problems related to deterioration of such cablea? If db so, describe Applicant's knowledge of such problems and provide copics of all documents that Applicant has used to understand and eliminate se 'h prob-
"M lems.
9.
provido all documents related to the design of cable tray r to b1 used in the plant, including, but not limited to, the isolation, spacing and delineatica of such trays, the specific materials to be used in the trays, the specified installation procedures and what procedut s thm App'icant intencls to implement for inspection and maintenance of such trays. Is th. Applicant ame of prob-lems related to separation, isolation, spa'tg and delir'entien of such trays artl their cables ? If so, describe Applirmt's kno"/ ledge of such proble m.; and provide copics of all documents that Applicant has used to understand and eliminate such problems. lias Applicaat ever considered using sprinkler 272 132
Permi 2 Interrogatories, May 25, 1979 systanu, to deal with problems that may be related to cable trays If not, explain why in detail. It yes, provide copies of all documents relatea to u'ch a conshleration, and explain why such sprinkler systems were not incluJ 1n the plant.
IU.
Pro /ide all cocasenta releted to an evacuation plan for residents of o suu aot Michigan and Ohio in case of an accident at the plant. In there an evacuation plan that has been approved by Michi:pm or Federal authorities. If so, ; o/ide a copy of such plan. If not, explain why such a plan does not exmt or ha nnot been formally approved and provide copies of all oraft piar. and communbtions with federal and ntato authorit to a.
Also provide an explanation and ccpio, of any doctunents related to the question of whether eny individuale te'dding in the Stony Pointe area er other areas within a ten mile radius of the plaat uot ld be exp%ed to more radiatiomnd danger because of thc lack of an adequate evacuation route for such individuals. In particular, will any inuividu al resid-ing near the plant be forced to travel closer to the plant site in order to cvace-ate the area J-If the Applicant believes that no individuals will be placed in such a situation as described in the preceding sentence, explain why and indicato alterna;c evacuation routes for such individuals, particularly those living in the Stony Pointe area.
rc&u 11. Pro;ide copies of all documents related to design conditions established for M
hinh-aa tsr canoitions at the plant site. Iron ', as the '\\pplicant' n final design D"lllI para' 'ter for hi h water arrived at? Has that design parameter ever been en-t EE3I::I coe ca in the immediate past or since records have been kept ? On hov many occasion:
1' ive the des.tgn parameters even been approachen, by hic,, -water con-n g
ditions near the plant site' 22::n 79
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Provide copion of all documents used by the Applicant in analyzing the
- n effects of mining. milling. enrichment and fabric.dion of uren!um in the nuch ar fual cycle. If the Applicant did not analyze such effects er did so perfunctorily, explain why.
CA 7G CE requestr that Applicant provide it with one copy of the Preliminary Safety CQN Anah ;is Report and any rminions of auch report. If provided with such report, CEE rould rcauito that any responses to the al;ove Interreaatorica be Hckvaver, respoatisfied ny citing the relevant action of the PSTR or revision.
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relate I to docun :nts other than the PSAR would still require the provision of Sllcn GocumOnts.
- 13. Identify each witnaas wuo will present direct testimony on behalf of Applicant, state the nurabered paragraph (c) and lettered sub-paragraph (s) in the Stipula-tion of Contentiour coucarning which tho witness el'1 testify, and set forth for each witness (1) his or her educational bach,round, (2) his or her employ-ment eWrience, (3' a d;3cription of each publication related tc> his or her testimony which he or she has anrhored or co-authored, (4) each instant in which the witnacs has previously testified on the same or a cloc aly-related issue, (5) the substance of the acts or opinions tc which he or she is expected to testify, (6) a summary of thc ba us for each opinion of nuch wit.ne,,, (7)a de',cription of each docurnt on which he or nho is expected to rely or which App!icant contendo support: n., or her testimony (if such document la not pro-vid ad in respono > to the Interrogatories above, provide a copy with your to,pon e to 1j), an I (3) a dO 7Cription of each document knaWD lo lpplicant that may
I'ermi ? InMrroptwica, hiny 25, 1979 tend to refute oc contradict his or her testimony (if,uch docuraent is not p:o-vid d in recpon:
to the Interrogatorian above, provide a copy v/ith your rc-sponse to 13).
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By Kim Arthur Siegfried','itwitornay Certificate of Service I hereby certify that I have this 25th day of May,1979 served the foregoing documant entitled "CEE interrogatories to Applicant"Iby mailing co,Lic.
thereof, first class mail, poctage prepaid end properly addres :ed to the folloviing persons:
mer-I} Charles Bochhoofer, Esq.
Chairman, Ttomic Safety and Chairman, Atomic Safety and Licensing Appeal Board Panel Licnosing Board U. S. Nuclear Regulator / Commission D
dm U.S. Nuclear Regulatory Comm.
Wa shing to n, D.C 20555 L
V.'a shing ton, D. C. 2 05 5 5 Dr. David R. Schink Mr. Frederich J. Shon I?epartment of Oceanography "N
Atomic Safety and Licansing Board Tc):as AW Univorof ty h%
U.S. Muclcar Regulacry Comm.
CoHege Station, Texas 77840
,g Wa :ching ton, I r. C. 2 05 5 5 d WA %
Chairman, Atomic Safety and Office of the D:ecutive Legal Director Licensing ilourd Panel U. S. N uclear Regulatory Commission
%ATJ U.S. Nuclear Regulatory Comm.
Wa shington, D.C. 20555 OC'S Wa shing~ ton, D. C. 2 05 55 Mr. Dol, ert J. Hoffman o
g Monroe County Library System S upe rvi:., Frenchtoven Town ship Reference Depat tment Frenchtown Township IIall b
3700 South Custer Road 2GG5 Vivian Road L'onroe, Michigan 43161 Monroe, Michigan 48161 Secreta ry Harry H. Voigt, Esq.
U.S. Nuclenr Regulatory Comm.
LeRoauf, Lamb, Leiby and MacRae V.ushington, D. C. 2 0555 1757 N Straat, N.W.
Atta: Docketing and Servico SectionWashington, D.C. 2003G (orig inal).
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