ML20004C597
| ML20004C597 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/26/1981 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | COALITION FOR THE ENVIRONMENT, ST.LOUIS REGION |
| Shared Package | |
| ML20004C598 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8106040311 | |
| Download: ML20004C597 (33) | |
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t,.x ., m ac o k i UNITED STATEf(C PAMERIJ [ - yg g7!981> grs NUCLEAR REGULATORY-C-eM5 FISSION .-
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD A I e to In the Matter of )
)
UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1) )
APPLICANT'S INTERROGATORIES AND REQUESTS FOR DOCUMENT PRODUCTION (SET NO. 1)
TO JOINT INTERVENORS ON THEIR CONTENTION NO. 1 Applicant UNION ELECTRIC COMPANY hereby requests that each of the Joint Intervenors COALITION FOR THE ENVIRONMENT, ST. LOUIS REGION; MISSOURIANS FOR SAFE ENERGY; and the CRAWDAD ALLIANCE, pursuant to 10 CFR SS2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection and copying of the original or best copy of all documents identified in the responses to interrogatories below, and that subsequent to filing answers to these interrogatories and producing documents therein identified, Joint Intervenors file supplemental responses and produce additional documents as required by 10 CFR 52.740 (e) .
As set forth in the Special Pre-Hearing Conference Order of April 22, 1981, responses to these discovery requests are due no later than July 10, 1981; objections to interrogatories or the production of documents are to be served within fourteen (14) or (30) days, respectively, of uhe date of service of these requests. It will be acceptable if the o(
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g i Join't Intervenors chooseLto file a! joint response to these requests.
provided that such responses include all information and'all documents in1the possession, custody-or control of any of the' Joint Intervenors.
Where identification of a document is requested,'briefly describe
- the document (e.g., book, letter, = memorandum, . report) and state the following information'as' applicable for..the particular document: name,--
title, ntmter, author, date of publication and publisher, addressee, date written'or approved, and-the name and address of the person (s) having possession-of the document.
As used in these discovery requests the temm " document (s)" -includes publications of any format, letters, memoranda, notes, reports, analyses, test results or data, recordings, transcriptions and printed, typed or written materials of every kind in the possession, custody or control or within the knowledgelof any of the Joint Intervenors or'their counsel, Joint Intervenors' Contention No. lA (Embedded Plates) 1A-1. State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of-the facts alleged in your Contention No. lA.
lA-2(a). State the name, address, title, employer and educa-tional and professional qualifications of each person you intend to call as an expert witness on Contention No. LA.
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(b). ' State.theLsubject matter on_which.each such person is.
expectedLto testify.- ,
/(c). State the substance of the facts and opinions to which each such person 11s expected to testify.
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(d).. State a. summary of the grounds for such opinions, and identify all documents'upon which such person relies to substantiate
.such opinions.
lA-3. -State the name and' address of each person not identified in response to the preceding interrogatory, who you intend to call as a witness on Contention No. lA.
lA-4. Identify all documents in your possession, custody or con-trol pertaining to the subject matter of Contentic,. No. lA.
lA-5. Identify all documents which you intend to offer as exhibits during this proceeding to support Contention No. lA or which you intend to use during your cross-examination of witnesses presented by Union Electric Company and/or the NRC on Contention No. lA.
lA-6(a). State the factual basis for your allegation in Conten-tion No. lA that the NRC and Union Electric Company "do not know where (the 480] plates are located in the plant."
(b). Identify all documents you rely upon to support this
, allegation. l l
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(c).- State the name,_present or.last known' address, and c
present or'last_known' employer of'each' person known to'you to have-first-hand knowledge of the-factual-basis for this-allegation..
'(d). State the name of.each' person you. intend to call as.a witness to support this allegation.
'1A-7 (a) . . State-the factual basis for'your allegation in Conten-tion-No, lA that the 4!RC and Union Electric Company "do not know what
-loads each plate must bear."
-(b). Identify all documents you rely upon to support this-
- allegation.
(c). State the name, present or last known address, and present or last known employer of-each person known to you to have
-first-hand knowledge of the factual basis for this allegation.
(d). ' State the name of each person you intend to call as a witness to support this allegation.
lA-8 (a) . State the factual basis for your allegation in Conten-tion No. lA that the NRC and Union Electric Company "do not know what the consequences of plate failure would be to the safe operation of the plant and to the health and safety of the public."
(b). Identify all documents you rely upon to support this allegation.
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(c). State the name,.present or last known. address, and present or'last known' employer'of each person known to yousto have first-hand knowledge of'the factual basis-for this_ allegation.
-(d).- State.the name of each person'you intend to'. call as a i
witness to support this allegation.
lA-9(a). State the factual-basis for your allegation in.Conten-
- tion.No. lA that "many unused plates had to be repaired...or were.
returned to the manufacturer." ,
(b). Identify all documents.you rely upon to support this allegation.
(c). State the name, present or last known address, and
. -present or last known employer of each person known to you to have-first-hand knowledge of the factual basis for.this allegation.
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(d). State the name of each person you intend to call as a i
witness to support this allegation. .
t 1A-10(a). State the factual basis for your allegation in Conten- ,
tion No. lA that "[t]here is evidence of multiple defects on some plates."
'(b). Identify all documents you rely upon to support this !
allegation.
(c). State the name, present or last known address, and [
, present or last known employer of each person known to you to have ;
t first-hand knowledge of the factual basis for this allegation. l i
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'(d). ' State the'name of each person you intend to call as.a
-witnes's uo support 7 this. allegation.
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lA-ll (a) . State:the factual basis for your allegation.in Con;ea-tion No. LA.that "[d]uring the processaaf' evaluating.the question whetherLthe embedded plates-presented a safety significant problem, the Applicant improperly determined, with the NRC's apparent approval,
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that certain exceptions to structural welding code standards would be.
tolerated."
.(b). Identify all documents you rely upon to support this
-allegation.
(c). State the name, present or last-known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for t:. s allegation.
(d). State the name of each person you intend to call as a witness to support this al. legation.
(e). Identify the " structural welding code standards" to which you contend exceptions were tolerated.
(f). State the exact nature and degree of each alleged exception granted, lA-12 (a) . State the factual basis for your allegation in Conten-tien Nc. lA that " inadequate and incomplete inspection and testing were performed."
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(b).- Identify 7all documents you rely upon to support.this allegation..
~(c). ' State the name, present or.last known' address, and'
-preseni.or last'known employer of each person known to'you to have first-hand knowledge of the factual basis for this allegation.
(d). State the name of each person you intend to-call as.a witness to support this-allegation.
(e) . . Identify all inspections and testing which you contend should;have.been performed.
(f). State the factual. basis for.your contention that such inspections and . testing should have ';oen performed.
(g). . Identify all documet.ts you rely upon to support your contention t;._t such inspections and/or testing identified in response to interrogatory.no. lA-12(e) should have been performed.
(h). State the name of each person you intend to call as-a witness to support your contention that the inspections and/or testing t identified in response to interrogatory no. lA-12 (e) should have been performed.
1A-13. State the name, present or last known address, and present or last known employer of the person identified as Individual "A" in
-NRC Report No. 50-483/77-10 referenced in your Contention No. lA.
1A-14 (a) . Do you contend that the alleged problems with embedded plates as set forth in your Contention No. lA constitute or in any way
-relate to a failure in the quality assurance program at the Callaway Plant? l
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-- (b ) . If:the answer to the' preceding interrogatory is:affir-mative or'other:han negat ive, state the1 factual basis:for:such con-tention specifying the nature and degree of?the alleged failure in.the:
quality a'ssurance'prvgram.
! J (c)~. Identify all documents you. rely'upon.to: support this-
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J contention.
(d) f. -State the name,. present or. last known . address ,- and present or last known employer;of.each person known to you to hava
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L first-hand knowledge of the factual basis for such contention.
.(e). State the name of cach person you intend to call as a witness to support this contention.
lA-15 (a) . 'Do you contend that the alleged problems with embedded-plates;as set forth in your Contention No. lA-will affect the safe
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l- operation of the Callaway Plant?
(b). If the answer to the preceding interrogatory is affir-l
! mative or other than negative, state the factual basis for'such con-tention specifying the manner and degree in-which such. safe operation will allegedly be affected.
(c). Identify all documents you rely.upon to support this
! contention.
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(d). . State'the name, present'or:la'st known address, and
- present or last'known employer'of each-person known to you to have
-'- first4 hand knowledge of'the' factual basis.for.such contention.
(e) ~ *he.name of each person you intendnto call'as-
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'a-witnessLto supp._. chis contention.
LA-16.- Identify and produce all correspondenceLand-all written records. of telephone conversations or meetings ~ between any of the
- Joint Intervenors or-Kay Drey and-any employee of the NRC relating to
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the subject matter of.your Contention No. lA.
1A-17. -Identify and produce all documents pertaining to.the subject matter of your Contention No. lA cbtained from Union Electric Company or the NRC.-
Joint Intervenors' Contention No. ;3 (Concrete Cracks) 1B-1. State the name, present or last known address, and present or last known employer of each person known,to you to have first-hand knowledge of the facts alleged in your Contention No. 1B.
13-2(a). State tha name, address, title, employer and educa-tional and professional qualifications of each person you intend to call'as an expert witness on Contention No. 1B.
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(b)~. . State the.subjectLmatter on:which each such person-is-expected 'to :.te'stify.
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.(c). . State the substance of the facts and' opinions-to:which
-each such person _is expected to testify.- ,
- (d) . : State a sur ary of the grounds-for such' opinions, and-
. identify'al1Jdocuments_upon which.such person relies to substantiate
-such opinions.
- 1B-3. ' State the'name and address of:each' person'not' identified-
'in: response to thel preceding' interrogatory, who-you intend to call'as a: witness on Contention No. 1B.
~1A-4. Identify all documents-in;your possession, custody _or-con-trol pertaining to the subject matter of Contention No. 13.
1B-5. _ Identify all documents _which you intend to. offer as exhibits during this proceeding . to support Contention No. la cn: which you' intend to;use during-your cross-examination of. witnesses presented lar Union Electric Company-and/or the NRC on Contention No. 1B.
13-6(a). State the factual basis for your allegation in Conten-tion-No. 1B (pa:Jagraph no. 1) that the " crack up to 1/4 inch wide...
discovered in the Reactor Building in the reactor-cavity moat area in May, 1977" will affect the safe operation of the callaway Plant, i
specifying the manner and degree in which such safe operation will ;
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al1egedly be affected.
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(b). ' Identify: all documents you rely ~ upon . to : support this allegation.
(c)~. State the name,. present.or'l'ast known. address, and spresent c -last known employer-of-each person known to you~to.have-
-first-hand-knowledge of the factual basis:for this allegation.
.(d) . - State the name of'each person-you intend to call as a-
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witness to. support this allegation..
1B-71-). State ~the factualLbasis for-your allegation'in Co,nten-tion No. -1:B (paragraph no. 2)~that-the " crack approximately.12 feet--
long and 8 inches deep" in-the " north wall"~of the Control Building w 1.l~ affect the safe operation.of the Callaway' Plant', specifying the manner and degree in which such safe operation will allegedly be affected.
(b). Identify all documents you rely upon to support this allegation.
(c).- State the name, present or last known address, and-present or last known employer of each person known to-you to have first-hand knowledge of the factual basis for this allegation.
(d). State the name of each person you intend to call as a witness to support this al'egation.
(e). State the name, present or last known address,,and present-or last known employer of the Callaway Plant iron worker creferred to in paragraph no. 2 of your Contention No. 1B.
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13-8 (a) .. State the ' factual basis for your allegation 'in Conten-tion No.1B -(paragraph no. 2) Lthat .the crack' "apparently had' been overlooked by . the Applicant's . quality 'assur ance personnel. " '
(b). I tify all documents'you rely upon to. support'this
- allegation.-
(c). . State the-name,~present or.last known address, and present or 1ast known employer of.each person known-to you to-have.
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first-hand-knowledge of the factual-basis for this allegation.
(d). State the name of each person you intend to~ call ~as a witness to support this allegation.
1B-9(a). Do you contend that the concrete cracks referred to in-paragraph'nos. 1 and'2 in your Contention No. 1B constitute or in~any ,
- way relate to a failure in the quality assurance program at the Callaway Plant?.
(b). If the answer to the preceding interrogatory-is affir- ,
mative or other than negative, state the factual basis for such con-l tention specifying the nature and degree of the alleged failure in the <
quality assurance program. l (c). Identify all documents you rely upon to support this ,
, . contention.
(d). State the name, present or last known address, and ,
I present or last known employer of each person known to you to have t
first-hand knowledge of the factual basis for such contention. L i
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(e). State the?name of each-person 1you intend to call"as a
. witness to support-this contention.
1B-10. Identify andLproduce all correspondence and all written records of telephone conversations-or meetings between any of the Joint Intervenors or Kay Drey and any employee ~of the NRC relating to the subject matter _of your Contention No.-1B.
r 1B-11. Identify and produce-'all documents pertaining to the subject matter of your Contention No. 1B obtained from' Union Electric.
Company or the NRC.
Joint Intervenors' Contention No. 1C -(Honeycombing) 1C-1. State the name, present or last'known address, and present or last known employer of each person known to you.to have first-hand- -j i
9 knowledge of the facts alleged in your Contention No. 1C.
t 1C-2(a). State the name, address, title, employer and educa-
_.tional and professional qualifications of each person you intend to 1
call as an expert witness on Contention No. 1C.
(b). State the subject matter on which each such person is ,
expected to testify.
(c). State the substance of the facts and opinions to which each such person is expected to testify.
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l (d). . State ~a' summary.of~the greends or.such opinions,'and
- identifyiall. documents upon whichLsuch person relies to' substantiate
- such1 opinions.
1C-3. -State the name and address of.each person not identified
' in response to the preceding interrogatory, who you intend to call.as-a.witnessfon. Contention No. 1C.
Identify all' documents in your possession, custody or con :
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trol' pertaining to the subject matter of Contention No. 1C..
1C-5. Identify all documents which you intend to offer as exhibits during this proceeding to support Contention No. 1C or which you intend-to use during your cross-examination of witnesses' presented
' by-Union Electric Company and/or the NRC on-Contention No. 1C.
lC-6 (a) . Do you contend.that the honeycombing in the tendon access gallery. of the reactor base mat .(Contention No. 1C, para-graph no. 1) constitutes or in any way relates to a failure in the quality assurance program-at the Callaway Plant?
(b).- If the answer to the preceding interrogatory is affir-mative or other than negative, state.the factual basis for such con-tention specifying the nature and degree of the alleged failure in the quality assurance program.
_(c). Identify all documents you rely upon to support this contention.
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. (d) . - State'the name,1present or last.known~ address,:and present or last known'-employer of each person known to you to-have:
- first-hand knowledge of'the factual.bacis'for such contention.
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(e).- r State:the~name of each person'you intend to cal 1 as-
.a witness:to' support this contention.
llc-7 (a) . Do you contend that the honeycombing-in_the: tendon access gallery of the' reactor base mat (Contention No. 'lC, para-graph no. 1);will affect the safe operation of the'Callaway Plant?-
(b).- If the answer.to the preceding interrogatory is-affir-
- mative or other-than negativei state the-factual basis for such con-tention specifying the manner and degree in which such safe operation
- will allegedly be'affected.
(c). ' Identify all documents you-rely upon to support this contention.-
(d). State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for such contention.
-(e). State the name of each person you intend to call as a witness to support this contention.
1C-8 (a) .. Do-you contend that the honeycombing in the reactor building dome ', Contention No. 1C, paragraph no. 2) constitutes or in any way relates to a failure in the quality assurance program at the
. Callaway Plant?
(b). If the answer to.the preceding interrogatory is'affir-mative orfother than negative;, state the factual basis for sucl. con-
-itention specifying the nature and degree of the alleged _ failure in~the quality' assurance program.
-(c). Identify.all documents you rely upon to_ support this contention.
(d). State the name, present or.last'known address, and present or-last known employer of each person.known to you_to have- ,
first-hand knowledge of the factual basis for such contention.
(e). State the name of each person you intend to call aus a witness to support this contention.
1C-9(a). Do you contend that the honeycombing in the reactor.
L building dome (Contention No. 1C, paragraph no. 2) will affect the
. safe operation of the.Callaway Plant?
(b).. If.the answer to the preceding interrogatory is affir-mative or other than negative, state the factual basis for such con-tention specifying the manner and degree in which such safe operation will allegedly be affected.
(c). Identify all documents you rely upon to support this contention.
(d). State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for such contention.
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(e).- State the:name of each person you intend to call as a wirness to support this contention.
1C-10 (a) . LState'the name, present or last known-address, and present or last-known employer of-the " worker" who allegedly. described the voids in reactor building base mat as being " big enough for man to crawl into" (Contention No. .lC, paragraph no. 1).
(b) '. Identify all documents containing statements by such tworker' pert'aining to this incident'and all documents pertaining or referring to the alleged statement by such worker.
1C-ll(a). Please produce the letter of January-3,.1979,.from James Keppler, Director, Region III, NRC to Kay Drey referred to in your Contention No. 1C, paragraph 1.
(b). Identify.and produce all correspondence and all written-records of telephone conversations er meetings between any of the Joint Intervenors or Kay Drey and any employee of the NRC relating to the subject matter of Contention No, 1C.
1C-12. - Identify and produce all documents pertaining to the subject matter of your Contention No. 1C obtained from Union Electric Company or the NRC.
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Joint-Intervenors' Contention No. 1D (Concrete Coverace)_ l l
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1D-1. State the name, present or.last known address, and present or last known employer of.each1 person known to you to have first-hand ,
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- knowledge of the factsJalleged.in your-Contention No. 1D.
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'lD-2 (a)'. - State the name, a'ddress,.. title,* employer and e'duca-
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tional and professional qualifications of each person you intend to call as~an' expert witness on Contention No. 1D.
-(b). State the subject matter on which each such person is I
expected to testify.
-(c). State the-substance of the facts and opinions to which each such person-is expected to testify.
(d). State a summary of the grounds for such opinions, and identify all documents upon which-such person relies to substantiate such opinions.
1D-3. State the name and address of each person not identified in response to the preceding interrogatory, who you intend to call as a witness on Contention No. 1D.
3D-4. . Identify all documents in your possession, custody or control pertaining to the subject matter of Contention No. 1D.
1D-5. Identif: all documents which you intend to offer as exhibits during this proceeding to support Contention No. 1D or which you intend to use during your cross-examination of witnesses presented by Union Electric Company and/or the NRC on Contention No. 1D.
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1D-6 (a)'. .Do you contend that the alleged failure ~cf concrete coverage to " adhere to requirements" constitutes or-in any way.. relates to a failure in-the quality assurance program'at the'Callaway Plant?- ,
- (b)'. If the answer to the preceding interrogatory is;affir -
-mative or other than negative,7 state the factual basis for such con-
'ention, t specifying the~ nature and degree of the~ alleged failure in the quality assurance program.
(c). Identify'all documents you rely upon to support this-contention.
. (d) . State the name, present or last known address, and present or last known employer of each person known to you to have-first-hand knowledge of the factual basis for such contention.
(e). State the name of each person you. intend to call as a witness to support this contention.
1D-7 (a) . Do you contend that the allege 6 failcr2 of concrete coverage to " adhere-to requirements" will affect the safe operation of the Callaway Plant?
(b). If the answer to the preceding interrogatory is affir-
- mative or other than negative, state the factual basis for such con-tention, specifying the manner and degree in which such safe operation will allegedly be affected.
(c). Identify all documents you rely upon to support this 4
contention.
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~ (d). State the name, present or last known address, and
-present or last known employer-of each person-known to you'to.have first-hand _ knowledge of;the factual basis for.such contention.,
(e). State the name of each person you intend to call as a-witness to-support this contantion.
lD-8. Identify.and produce allt corres,Jondence and-all written records of telephone conversations or meetings between any of the Joint Intervenors or Kay Drey,and any employee of the NRC relating to the subject matter of'your Contention No. 1D.
1D-9. Identify and produce all documents pertaining to the subject matter of your Contention No. 1D obtained from Union Electric
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Company or the NRC.
Joint Intervenors' Centention No. lE (Piping) <
lE-1. State the name, present or last known address, and present' or last known employer of each person known to you to have first-hand knowledge of the facts alleged in your Contention No. lE.
lE-2(a). State the name, address, title, employer and educa-tional and professional qualifications of each person you intend to c.11 as an expert witness on Contention No. lE. .
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(b). - State the . subject matter- on1which each such per' son 'is
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! ' expected to testify.
(c).- State the' substance of the facts-and_ opinions to which.
each.such person is expected to testify.
(d). State a summary of the grounds for such opinions, and.
identify allLdocuments upon which such' person relies to substantiate
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such opinions.
lE-3. State the name and address of each person not identified in' response to the preceding interrogatory, who you intend to call as a witness.on Contention No. lE.
lE-4. Identify all documents in your possession, custody or con-trol pertaining to the subject matter of Contention No. lE.
lE-5. Identify all documents which you intend to offer as.
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exhibits during this proceeding to support Contention No. lE or which you intend to use during your cross-examination of witnesses presented by Union Electric Company and/or the NRC on Contention No. lE.
1E-6 (a) . State the factual basis for your allegation in Conten-tion No. lE that' "[s]afety-related pipe installed at Callaway was manufactured by a company or companies which did not have adequate control of welding parameters."
(b). Identify all documents you rely upon to support this allegation. '
( c ) ~. State the name, presentLor last knownfaddress, and present'-
or last:known employer of each person known to you to have first-hand
~ knowledge of the factual basis.'for this; allegation.
P (d). State the name of each person you intend to call as a factual Aitness'to support this allegation.
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J1E-7(a). State the factual basis for your allegation in Conten-tion. No. lE that_ "[t]his resulted in known= cases of ' defects which [
did'not comply with the requirements of the American Society of Mechanical Engineers (ASMF) Code."
(b). Identify all documents you rely upon to support this allegation.
(c). -State the-name, present or last known address,.and present or last known employer of each person known to you to have .
first-hand knowledge of the factual basis for this allegation.
(d). State the name of each person you~ intend to call'as a !
i witness to support this allegation.
(e). Identify the specific requirements of the ASME Code i you contend were not complied with.
lE-8(a). State the factual basis-for your allegation in Conten-
- tion No. lE that "[t]he evaluation and acceptance of those defects !
i and deficiencies were not done in accordance with the ASME Code."
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'O , '-g, (b). Identify all' documents youLrely upon to support this-allegation.--
(c). . State the name, present or last known address, and
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. present cur last known -employer of each person known to you to have
- first-hand' knowledge of the factual-basis for this allegation.-
(d). State the name of each person-you intend to call as a witness to support this: allegation.
(e). Identify the~ specific requirements'of the ASME Code-you contend were:not complied with.
lE-9(a). ~ State'the factual basis for your allegation in Conten- >
tion No. lE that ' [t]he safety of pipe installed at Callaway remains in question and demands further investigation before an operating license should be issued."
9 (b). Identify all documents you rely upon to support this allegation.
(c). State the name, present or last known address, and ,
present or last known employer of each cerson known to you to have first-hand knowledge of the factual basis for this allegation. {
(d). State the name of each person you intend to call as a ,
witness to support this allegation. ;
lE-10 (a) . State the name, present or last known address, and present or last known e "loyer of the pipe fitter who had allegedly e T f
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discovered land report'de a substandard piece of ASME. Class II SA-358 piping installed in; the emergency . core cocling system (Contention No.
' iE,_ paragraph'no. 1).
( b ) . -- Identify all documents containing statements by such pipefitter pertaining to this incident.and all documents pertaining
. or referring to such statements.
lE-ll(a) . State the factual basis for_your allegation in Conten-tion No.-lE (paragraph no. 1) that "[t]he pipe was substantially out-of-round, was machined below the minimum wall, and had rejectable weld defects on the inside of a longitudinal seam weld."
(b). Identify all documents you rely upon to support this allegation.
(c). State'the name, presen or last known address, and present or last known employer of each person known to you to have
- first-hand knowledge of the factual basis for this allegation.
(d). State the name of each person you intend to call as a.
witness to support this allegation.
! lE-12(a). Do you contend that this alleged incident of the
, installation of an allegedly substandard piece of ASME Class II I
SA-358 pipint (Contention No. lE, paragraph no. 1) constitutes or in j any way relates to a failure in the quality assurance program at the
' Callaway Plant?
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> f(b)". :If' the answer-- to the ; preceding int [errogatory ist affir-
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- mativeiorL other th'an negative, state theifactual. basis for : such con '
- tention specifying the nature'and?degreeJof the alleged failure.in the quality assurance program.
~ (c) . - Identify all documents you rely upon to supportithis contention. .
(d). -State the name,'present;or last known address, and.
- present or last.known employer of~eaci. person .nown to you to have
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first-hand knowledge of the factual ~ basis for such contention.-
.(e).1 State.the name of each person you intend to call as a-witness.to support this contention.-
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Do_you_ contend-that this alleged incident of the
-installation of an allegedly substandard piece _ of ASME Class II SA-358 :
. piping' (Contention - No. :lE, paragraph no. 1)Lwill affect the safe' operation of the_Callaway Plant?
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Db) . If the answer to the preceding interrogatory is affir- ,
lmative or_other than-negati/e, state the factual basis for such con- ;
tention: specifying the manner and degree in which such '_afe operation will allegedly be affected.
(c). ' Identify all documents you rely upon to support this contention.
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' ( d )' '. : State tne_name,-present.or last known address, and present or-last known employer.oficach: person.known to you to_have c *irst-hand knowledge of the factual basis'for such' contention.
l(e). .-State-the name af each perron you intend to call as-
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a witness to. support this contention.
lE-14 (a)'._ State the factual basis for your' allegation in Conten-tion No. lE :(paragraph no. 2) .that " (s] ubstandard . fusion welded
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SA-312; pipe manufactured by Youngstown Welding and, Engineering Company...has been installed at the Callaway_ Plant."
(b). Identify all documents'you rely upon to support this allegation.
(c). -State the'name, present or last known address, and present or last.known employer of each person known to you to have
'first-hand knowledge'of the factual basis for~this allegation.
(d). State the name of each person you intend to call as a'
' witness to support this allegation.
lE-15(a). State the factual basis for your allegation in Conten-
' tion-No. :US (paragraph no. 2) that "[t]he evaluation and acceptance of-this substandard SA-312 piping were not performed according to the requirements of Section III of the ASME Code", identifying the specific sections of the ASME Code allegedly not complied with.
(b). Identify all documents you rely upon to support this allegation.
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( c ) '. State the'name,:present.or last known-address, and'
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. present1or'last known employer _ef-.each' person known to you to have-
-first-hand knouledge of.the factual basis lfor this allegation.
L (d).. State.the'name of each person you intend to call.as a-
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- witness to support-this allegation; LE-16 (a) . ; . Do_ you contend that installation of this allegedly
- substandard SA-312 pipe and/or the subsequent evaluation and- I
-l acceptance _thereof (Contention No. lE, paragraph no. 2) constitute!
or in any-way relate to'a-failure in the quality assurance program 7 at-theLCallaway-Plant?
(b). If'the answer to the preceding interrogatory is affir +
mative or.other than negative, state the factual basis for such con-tention specifying the nature and degree of the alleged failure in-the quality assurance program.
(c). Identify all documents you rely upon to support this contention.
(d)' . State the name, present or last known address' and present'or.last known employer of each person known to you to have first-hand knowledge of the factual basis for such contention.
(e). State the name of each person you intend to call as a witness to support this contention.
lE-17 (a) . Do you contend that installation of this allegedly substandard SA-312 pipe and/or the subsequent evaluation and
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acceptance ' thereof -(' Contention l No.11E, paragraph no. 2) will affect (the-' safe operation of.the Callaway Plant.
-(b) .- = Iff the . answer. to the preceding 1interrogato;yris affir-mative or other than negative,: state the factual basis for such con-I tentionLspecifying the. manner and degree in which such safe operation i
will allegedly be affected.
Identify all documents'you rely upon to. support this.
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(c).
1 contention.-
-(d) . State the name, present or last known address, and
-present.or last known employer of each~ person known to you to have.
first-hand knowledge of the factual basis'for such contention.
'(e). Stt a the name of each person you intend-to call as a witness to support this contention.
lE-18. Identify and produce all correspondence and all written records of. telephone conversations or meetings between any of the Joint Intervenors or Kay Drey and any employee of the NRC relating to the subject matter of your Contention No. lE.
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-lE-19. Identify and produce all documents pertaining to the-subject matter of your. Contention-No.e lE obtain'ed frort Union Electric ,
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, Company or the NRC.
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Joint Intervenors' Contention No. -lF '(Pre-assembly Piping Formations)' f slF-1. ' State the name,.present or'last known address,'and present; oor last known~ employer of each person known to1you to have'first-hand knowledge of the facts alleged-in'your: Contention.No. 1F. ,
1F-2 (a) '. State the;name, address,; title,' employer and educa-- !
tional and professional qualifications of each person you intend'to
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call as an' expert witness on Contention No..lF.
(b). . State'the subject matter on.which each such person is-expectedLto testify.
(c).- State the substance of the-facts and opinions to which.
each such person is' expected to-testify. ,
__ (d). State a summary of the grounds for such opinions, and identify.all documents upon which such person relies to substantiate' .
i such opinions.
1F-3. State the name and address of each. person not identified in response to.the preceding interrogatory, who you intend to call as ;
a witness on Contention No. 1F.
1F-4. Identify all documents in your possession, custody or [
control pertaining to the subject matter of Contention No. 1F.
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.lF-5. Identify all documents which you intend to offer as exhibits during this proceeding to support Contention No. 1F.or which you intend to use during your cross-examination of witnesses presented
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by Union Electric Company and/or the NRC on Contention No. 1F.
1F-6(a). ' State the factual basis for your allegation in Conten-tion No. 1F that " pre-assembly piping formations with defective welds frem Gulf.& Western were accepted and were installed at Callaway."'
(b). Identify all documents you rely upon to support this allegation.
(c). State the name,,-present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
(d). State the name of each person you intend to call as a witness to support'this allegation.
s IF-7 (a) . State the factual basis for your allegation in Conten- r tion No. 1F that "[a]fter installation it was also discovered that the vendor had used improper radiographic techniques."
(b). Identify all documents you rely upon to support this allegation.
(c). State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
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(d). ' State the name of each person you intend to call as a witnessLto support this allegation.
1F-8(a). Do you contend'that the installation of pre-assembly piping formations with allegedly defective welds and/or that the vendor's alleged use of improper radiographic techniques (Contention.No. 1F)
. constitute or in any way relate to a failure in the quality assurance
-program at the Callaway Plant?
(b). If the answer to the preceding interrogatory is affir-mative or other than negative, state the factual basis for such con-tention, specifying the nature and degree of the alleged, failure in the quality assurance program.
(c). Identify all documents you rely upon to support this contention.
(d). -State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the' factual basis for such contention.
(e).- Stata the name of each person you intend to call as a witness to support this contention.
,. 1F-9(a). Do you contend that the installation of pre-assembly piping-fonnations with allegedly defective welds and/or that the vendor's alleged use of improper radiographic techniques (Contention No. 1F) l l
will affect thu safe operation of the callaway Plant?
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-(b). If the answer'to.the preceding interrogatory is affir-mative or.other than negative, state the factual basis'for'such con-tention,_specifying the manner and degree in which such safe' operation
~will all'egedly be affected. -
.(c). LIdentify all documents you' rely upon to support this contention.
(d). -State the name, present or last known address, and present or last known employer of each person _known to you to have
.first-hand knowledge of the factual basis for such contention. t (e). State the name of each person you intend to call as a witness to support this contention.
1F-10. Identify and produce all correspondence and_all written records of telephone conversations or meetings between any of the Joint Intervenors or Kay Drey and any employee of the NRC relating to the subject matter of your Contention No. 1F.
1F-ll. Identify and produce all documents pertaining to the subject matter of your Contention No. 1F obtained from Unit,n Electric
-Company or the NRC. ,
General Interrogatories Pertaining To Cont 3ntion Nos. lA through 1F A. State the name, title or position, address and employe: of each person who provided information used in preparing responses to any of the foregoing interrogatories.
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B. For each person identified in response to the preceding interrogatory, state the numbers of the interrogatories for which information was supplied.
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C. State-the name, title or position,' address and employer-of each-person whoEsearched for documents.in order to respond to any of the foregoing requests for identification and production of documents.
D. For each person identified in response to the preceding interrogatory, state the numbors of^the discovery requests for which the search was conducted and the location where the search was conducted.
E. -Identify and produce any written or recorded statement of any individual. pertaining to the subject matter of your Contention Nos, lA through 1F, not-previously identified in response to the foregoing ,
discovery requests.
Respectfully submitted, SEAW, PITTMAN, POTTS & TROWBRIDGE I
By: ~ -
Thomas A. Baxter Richard E. Galen ,
Counsel for Applicant ,
1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 I Dated: May 26, 1981 4
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