ML19263E477
| ML19263E477 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 04/20/1979 |
| From: | Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7906180693 | |
| Download: ML19263E477 (10) | |
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April 20,1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CINCINNATI GAS AND ELECTRIC
)
Docket No. 50-358 COMPANY, et _al.
)
)
(Wm. H. Zimmer Nuclear Power
)
Station, Unit No.1)
)
To: Leah S. Kosik, Esq.
3454 Cornell Place Cincinnati, Ohio 45220 Counsel for Miami Valley Power Project NRC STAFF INTERROGATORIES TO MIAMI VALLEY POWER PROJECT Pursuant to 10 CFR 12.740b and the Order of the Licensing Board dated April 9,1979, the NRC Staff hereby requires the Intervenor, Miami Valley Power Project (MVPP) to answer separately and fully, in writing and under oath or affirmation, the following Interrogatories on or before May 4,1079 On March 7,1979 MVPP submitted two additional contentions which were admitted by the Licensing Board's Order of April 9,1979 and in the Order the Board also admitted a third contention. Continuing the Applicant's numerical designation of contentions contained in its filing of December 5, 1978, the Staff will refer to the three most recently admitted contentions as contentions 14,15 and 16. The Interrogatories relate to the contention which imediately precedes them.
2355
,21 7906180b D h
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' Contention 14 Cable trays containing electrical wires have been inadequately welded by imoroperly qualified welders and there have been in;dequate testing of these welds.
1.
Identify and describe the inadequacy of the welds upon the clectric cable trays.
2.
Identify and describe in what way the welds fail to meet NRC specification.
3.
Identify and describe in what way the welds fail to meet ASME specifications.
4.
Identify and set forth the NRC and ASME specifications which aoply to welds upon electric cable trays.
5., Is the integrity of the cable trays a necessary safety function of plant operation.
6.
Set forth the basis for your answer to interrogatory no. 5.
7.
Does Cincinnati Gas and Electric Company (CG&E) apply standards to welding the cable trays different than those required by NRC?
8.
Identify and describe the qualifications required of welders in order to weld upon the cable trays.
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. 9.
Identify and describe the lack of such qualifications by welders--
setting forth the time period that such alleged unqualified welders welded and identify the trays upon which they are alleged to have welded.
10.
e fs a " certified welder pursuant to NRC regulations" (see Saul Rigberg filing dated April 2,1979, page 8, line 5).
11.
Identify and describe what is a proper test of a weld upon a cable
- tray, 12.
Identify and describe what tests were made by CGAE of the welds upon the cable trays.
13.
Identify by name and address all expert witnesses which MVPP intends to use at the hearing to substantiate contention 14.
14.
Summarize the testimony of all expert witnesses which MVPP intends to use at the hearing to substantiate its contention 14.
15.
Set forth the qualifications of all expert witnesses which the MVPP intends to use to substantiate its contention 14.
16.
Identify all graphic materials used by, or in the oossession of, MVPP or any of its members or consultants which tend to supoort contention 14.
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. 17. Will f1VPP make the graohic materials identified in response to interrogatory no.15 voluntarily available to flRC Staff for examination and copying during normal business hours in the greater Cincinnati metropolitan area?
Contention 15 Control rods which must be easily inserted into and removed from the reactor core have been inadeauately manufactured so that they do not meet the size specifications for such control rods.
18.
Identify and describe what asoect of the manufacturing process was inadequate.
- 19. What part of a control rod was inadequately manufactured?
- 20. What is the inadequacy of the control rod resulting from the alleged inadequate manufacture?
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- 21. What specific part of the control rod is affected by improper manufacture and how does this effect the performance of the control rod?
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. 22. What is the size specification for the control rod which is not met because of improper manufacture?
- 23. How is the control rod measured to determine whether 1t conforms to the size spec.ification?
24.
Identify by name and address all expert witnesses which MVPP intends to use at the hearing to substantiate Contention 15.
- 25. Sunmarize the testimony of all expert witnesses which MVPP intends to use at the hearing to substantiate its Contention 15.
- 26. Set forth the qualifications of all expert witnesses which the MVPP intends to use to substantiate its Contention 15.
27.
Idertify all graphic materials used by, or in the possession of, MVPP or any of its members or consultants which tend to support Contention 15.
- 28. Will MVPP make the graphic materials identified in response to interrogatory 27 voluntarily available to NRC Staff for examination and copying during normal business hours in the greater Cincinnati metropolitan area?
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. Contention 16 Aimost all of the seals on the control rods, which when properly set prevent radioactive water from leaking out when the reactor is shut down for maintenance, do not meet minimum specifications for smoothness.
Rough seals cannot set properly, making servicing more difficult and unnecessarily endangering workers and the general public by causing leakage of radioactive water.
29.
Identify and describe w.ch particularity the seals alleged not to meet minimum specifications, including a description of where they are located upon the control rod.
- 30. How many control rods have defective seals?
31.
Identify and describe the " minimum specifications for smoothness" for all seals identified in response to interrogatory 29.
- 32. What is the material of which the seals are composed?
33.
Describe the manufacturing process by which the seals are made smooth.
34.
Describe the testing procedure used to determine whether the smoothness of the seals meets the minimum specifications identified in response to interrogatory 31 above.
- 35. What is the water leakage rate per each alleged defective seal?
2355 326 36.
Does CG&E have any provisions for collection of water due to the alleged defective seals?
37.
Describe the operational mode when the seals would be operable and what activities lead to their being needed.
- 38. Are defective seals now installed at the Zimmer facility?
- 39. Has CG&E been informed that it has installed defective control rod seals at the Zimmer site?
- 40. What actions has CG&E taken to remedy the installation of defective seals, if the response to interrogatory 38 is yes?
41.
Identify by name and address ~ all expert witnesses which MVPP intends to use at the hearing to substantiate its Contention 16,
- 42. Summarize the testing of all expert witnesses which MVPP intends to use at the hearing to substantiate its Contention 16.
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- 43. Set forth the qualifications of all expert witnesses which MVPP intends to use to substantiate its Contention 16.
44.
Identify all graphic materials used by, or in ':he possission of, MVPP or any of its members or consultants which tend to support Contention 16.
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- 45. Will MVPP make the graphic materials identified in response to interrogatory 40 voluntarily available to the NRC Staff for examination and copying during normal business hours in the greater Cincinnati metropolitan area?
Respectfully submitted, k Shal Charles A. Barth Counsel for NRC Staff 2355 328 Dated at Bethesda, Maryland, this 20th day of April,1979.
UllITED STATES OF AMERICA flVCLEAR REGULATORY COMMISSI0ti
'BEFORE THE ATCMIC SAFETY AfiD LICEt:SIf;G BOARD In the Matter of CIflCIftilATI GAS Afl0 ELECTRIC Docket flo. 50-358 COMPAtlY, a_t, al.
(Wm. H. Zimmer fluclear Power
)
Station Unit fic.1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "flRC STAFF IflTERRUGATORIES TO MIAMI VALLEY POWER PROJECT" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk by deposit in the fluclear Regulatory Commission internal mail system, this 20th day of April,1979:
Charles Bechhoefer, Esq., Chairman
- Leah S. Kosik, Esq.
Atomic Safety and Licensing 3454 Cornell Place Board Panel Cincinnati, Ohio 45220 U.S. fluclear Regulatory Commission Washington, D.C.
20555 W. Peter Hefle, Esg.
Assistant City Solicitor Dr. Frank F. Hooper Room 214, City Hall School of flatural Resources Cincinnati, Ohio 45220 University of Michigan Ann Arbor, Michigan 48109 Timothy S. Hogan, Jr., Chairman Board of Comissioners Mr. Glenn 0. Bright
- 50 Market Street Atomic Safety and LicenQng Clermont County Board Panel Batavia, Ohio 45103 U.S. tiuclear Regulatory Commission Washington, D.C.
20555 John D. Woliver, Esq.
Clermont County Comunity Council Troy B. Conner, Esq.
Box 181 Conner, Moore and Corber Batavia, Ohio 45103 1747 Pennsylvania Avenue, fl.W.
Washington, D.C.
20006 2355 329
William J. floran, Esq.
Atomic Safety and Licensinq General Counsel Aopeal Board
- Cincinnati Gas & Electric Company U.S. fluclear Regulatory Comission P.O. Box 960 Washington, D. C.
20555 Cincinnati, Ohio 45201 Docketina and Service Section*
Atomic Safety and Licensing Office of the Secretary
, Board Panel
- U.S. ??uclear Regulatory Commission U.S. fluclear Regulatory Comission Washington, D. C.
20555 Washington, D. C.
20555 Charles A. Barth Counsel for flRC Staff 2355 330
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