ML20010B356

Second Set of Interrogatories Directed to Nrc.Certificate of Svc Encl.Related Correspondence

ML20010B356
Person / Time
Site:	Callaway
Issue date:	08/10/1981
From:	Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8108140397
Download: ML20010B356 (1)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION & AUG 121981 > *T5 n%g gg,7

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

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(Callaway Plant, Unit 1) )

JOINT INTERVENORS' SECOND SET OF INTERROGA'f 0 RIES TO NRC STAFF Joint Intervenors Coalition for the Environment St. Louis Region, Missourians for Safe Energy and Crawdad Alliance request that the attached interrogatories be answered fully, in writing and under oath by members of the NRC Staff who have personal knowledge thereof or are the closest to having personal knowledge thereof.

Unless otherwise stated all of the attached interrogatories relate to Union Electric Company's ' Callaway Plant Unit One. Nuclear Regulatory Commission is sometimes abbreviated "NRC". Union Electric Company is sometimes abbreviated "UE".

" Identify" or " Identification", when used with reference to a document or documents requires, in addition to whatever information is specifically requested, identification of the NRC document number (if applicable), a statement of the date of the document, the general nature and description of the subject matter and contents of the document, and the name(s) of the person (s) who prepared the document.

" Identify" or " Identification", when used with respect to a person or persons requires, in addition to whatever information is specifically requested, a statement 'of the full name, current or last known address and telephone number, employment and position as of the time period (s) relevant to the subject interrogatory, A pa t

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Joint Intervenors reserve their right to propound addit onal interrogatories pertaining to Contention No. 2 when the technical specifications, the FES and SER are available.

Respec' fully submitted, CHACKES AND HOARE

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Kenneth M. Chickes

_wf Attorneys for Joint Intervenors 314 North Broadway St. Louis, MO 63102 314/241-7961 t

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1 This interrogatory pertains to the following sentence in the NRC Staff Answer to Interrogatory No. 2: "Further review by the NRC will be performed during the FSAR review." Please describe the extent of that review.

2.

State the date(s) on which the NRC Staff reviewed Unfor. Electric's audit report of the Cives Steel Company; and describe the extent and time span of the NRC review (as per NRC Staff Answer to Interrogatory No. 3).

3. Soecify the number of the crack in the " plant" north wall of the Control Building to which the NRC Staff Answer to Interrogatory 4 refers, using a number assigned by the Permittee to the cracks delineated in NCR-2-2081-C-A. Explain the souien of the. measurement of the width of the crack as per the NRC Staff Answer, namely, "one-sixtee.,th (1/16) inch at the widest place."

4. State whether the NRC requires an NRC Permittee to make a distinction between a visually detectable crack which extends through the depth of an exterior wall of a Q building, as compared with one visible on only one face of a wall, in its assessment of the crack's reportability and potential safety significance - that is, even if the crack width is below the one-sixteenth inch reportable size. Please explain the answer.

5. State whether the matter of flaking concrete referred to in Joint Intervenors' Firs' tot of interrogatories numbers 68 and 69 has been closed, and identify all documents pertaining to the cur ent status of this nonconformance.

6. In the " Answers to the NRC St iff to Joint Intervenors' First Set of Interrogatories . . ." in response No. 68, the Staff states that the listing submitted as ,

Appendix B, entitled "NCR's Related to Concrete Placement 2C231WO3," is being updated and that "any additional information will be provided" the Joint Intervenors.

In addition to the supplementary response when available, please submit the following information:

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a. The list of 23 NCRs in Appendix B differs from 23 NCRs produced by the Applicant in response to Interrogatory No. 80 and Document Request No. 47 as follows: The NRC Staff does not list Number 2-1683-C-A or Number 2-1042-C-A in its list of 23 NCRs, although the Applicant included both in its document production in response to Document Rcquest 47. On the other hand, the Applicant did not provide Number 2-1411-C-A or Number 2-1594-C-A among the 23 NCRs produced, though both are incluced in the NRC's Appendix B list. Please explain the disparity.

b. NCR Number 2-1532-C-B is listed by the Applicant in response to Joint Intervenors' Interrogatory 81 as one of nine NCRs outstanding on November 21, 1977, but is not included in the NRC Staff's Appendix B and was not produced by Applicant in response to Interrogatory 80 as one of the 23 NCRs in the third lift. Please explain.

c. The NRC Staff Answer to Joint Intervenors' First Set of Interrogatories, Number 68 says that Attachment B provides the " disposition where known" of the ponennforming condition of each of the 23 NCRs t vording to data from the NCR forms. Explain how the NRC Staff knows that acMon was taken or completed in a timely manner - that is, that the outstanding NCRs were " closed out" prior to concrete placement - when the only information included in the " Statement of Completed Action" 's either the comment " work completed per approved disposition," signed and dated a few days or months after the concrete pour, and/or " Hold Tag destroyed" or " Hold Tag lost in field," also signed and dated af ter the pour.

d. State the time of day at which NRC Staff members Tom Vandel and Jim Foster left the Callaway site on November 21, 1977. State further-4

whether any evaluation records were written by them indicating 'the number or content of the NCRs whi h were still outstanding on Pour s

Number 2C231WO3, and whether any, it it were to remain uncorrected, could affect adversely the safety of the plant. 4

7. State whether NRC Staff members Eugene Gallagher and James Foster.

were accompanied by William Smart, ironworker, at the Callaway site on January 3, 1978, during the Staff's visual inspection of the fourth lif t reinforcing steel placement of the Reactor Building exterior wall.

a. If the enswer is affirmative, explain why a mention of this date was omitted from NRC Report 78-01.

b. State further whether the NRC Staff discussed with the Permittee or its representatives at that time or subsequently areas in which the steel was installed contrary to the specifications or drawings,

c. If the answer to (b) is affirmative, describe such communication and any subsequent actions taken by the Permittee as a result.

8. This interrogatory pertains to the NRC Staff Answer to Joint Intervenors' First Set of interrogato ies, Number 62(a): State whether some of the reinforcing. steel and concrete cover in dispute pertains also to ;artical reinforcing steel.

9. Describe the range of variations from CC-3533.1 of Appendix C to BC-TOP-5 observed by the NttC Staff of reinforcing steel installed in the third and fourth lifts that led to the determination "that the deviations identified regarding concrete cover would have no adverse effect on the safety of the structure to perform under design conditians," as per the NRC. Staff Answer Number 73.

10. In response to Joint Intervenors' Interrogatory No. 71 (Set One), Applicant.

states - that "[o]n January 5,1978, the NRC was conducting a special, announced investigation into allegations regarding, among other things, improper concrete cover for reinforcement."

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a. State whether on January 3,1978, the NRC Staff also inspected the reinforcing steel which had been placed in the Reactor Building in t

preparation for the fourth lif t of the exterior wall - that is, inspected those reinforcing bars and other materials which had been installed l above the third lift following completion of the concrete pour of November 22, 1977.

b. State whether the NRC Staff was accompanied by William Smart, Daniel ironworker, during an inspection on January 3,1978, and/or any other inspection (s) of the fourth lift reinforcing steel. If the answer is affirmative, state the date(s) of each of the inspections.

c. State the date(s), number of manhours, and results of each of the NRC Staff inspections of the fourth lift prior to the fourth lift pour.

d. State the date of the fourth lif t pour.

c. If the answer to (b) above is affirmative, state whether the NRC Staff directed any questions verbelly to representatives of Union Electric or its contractors durini the inspection (s) of shortly thereafter regarding the placement of the reinforcing steel.

f. If the answer to (c) above is affirmative, state whether any changes were made in the placement of the fourth lift reinforcing steel subsequent to the NRC Staff inspections in January 1978.

g. If the answer to (f) above is affirmative, state the number of manhours expended by the Applicant on the replacement or reworking of the reinforcing steel.

11. A notice of violation attached to the cover letter of the Region HI IE Report No. 50-483/81-04 refers to a " Severity Level V Violation [ Supplement II]".

a. Explain the significance of the Severity Level V Violation.

b. Also explain the significance of all other levels of violation.

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c. Identify the document Supplement 11 supplement .'nd provide 9 copy of Supplement II.

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d. Were any actions taken against the vendors, suppliers or manufacturers involved with the acceptance of unaccepla' ole indications cited in this notice of violation? If so, what actions were taken and against whorr.

were they tc.en?

1?. A Bechtel Power Corporation report dated November 28, 1979 and titled,

" Final Report of Gulf & Western Preassembled Formations for Callaway Plant Unit One

[ Union Electric] and Wolf Creek [ Kansas Gas and Electric]" concerns rejectable indications found in welds of preasembled piping formations,

a. Has the NRC investigated any of the deficiencies or noncompliances cited in this report?

b. Did any of the deficiencies or noncompliances cited in this report indicate possible or actual violation of the criteria of 10 CFR Part 50, Appendix B?

c. Has the surveillance and inspection of any supply items for the Callaway Plant by Bechtel and Code Authorized Nuclear Inspectors been sufficient to assure the structural integrity of safety related items?

d. State separately for each question the factual basis for the answer and identify all documents on which you rely,in the answers to questions (a), (b) and (c) above.

13. Identify, separately for each of the above interrogatories and . subparts thereof, the person (s) providing the answer.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 'E AUG 12 % , {'

BEFORE THE ATOMIC SAFETY AND LICENSING BOA ( [ f :rchry f

EivQ Wg In the Matter of ) g ,a UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

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(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of the Joint Intervenors' Second Set of Interrogatories to Union Electde, Joint Intervenors' Second Set of Interrogatories to NRC Staff and Joint Intervenors' Second Request for Production of Documents to Union Electric have been served on the following by deposit in the United States mail this 10th day of August,1981.

James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Roy P. Lessy, Jr., Esq.

Office of the Executive Legal Director-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 N

Kenneth M. Chackes CHACKES AND HOARE