ML20023C632
| ML20023C632 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/12/1983 |
| From: | Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Eddleman W EDDLEMAN, W. |
| References | |
| ISSUANCES-OL, NUDOCS 8305170497 | |
| Download: ML20023C632 (56) | |
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' p/
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In the Matter of )
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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
APPLICANTS' RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 41 and 65 TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.
(FIRST SET)
RESPONSES TO GENERAL INTERROGATORIES
, INTERROGATORY NO. Gl(a). Which contentions of Wells l
Eddleman do Applicants agree are now admitted in this pro-j ceeding, NRC Dockets 50-400/401 0.L.?
l ANSWER: See Applicants' answer filed on April 28, 1983.
INTERROGATORY NO. G1(b). For each such contention, provide for any answers to interrogatories by Wells Eddleman which Applicants have previously or presently received (except those suspended by Board order, if any), the following informa-tion.
ANSWER: The answers to General Interrogatories herein are restricted to Eddleman Contentions 41 and 65.
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INTERROGATORY NO. G1(c). Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) upon whom Applicants relied (other than their attorneys) in making such answer.
ANSWER: The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Eddleman Contention Nos. 41 and 65 and indicates the particular interrogatory answer (s) for which each such person provided information.
i PERSON INTERROGATORY NO(S).
V. Safarian 41-1(a)(b)(c)(f)(g)(j)(k)
(t)(u)(v)(y); 41-3(a)(b)(c)
(d);41-4(a)(b)(c)(d); 41-5(g)
(h)(1); 41-6; 41-7; 41-9; 4-10; 41-11 G. O. White 41-1(d)(e); 41-4(k)(1)
(n)(o);41-6 K. V. Hate' 41-1(d)(w)(x)
A. Fuller 41-3(e)(f); 41-5(i)(j)(k)(1);
41-4(g)(h)(j)(m); 41-6 D. Timberlake 41-4(e)(f); 41-6 N. J. Chiangi 41-1(z)
B. Marlar 65-1(a)-(j); 55-4(a)-(j);
65-5(a)-(e); 65-6; 65-7 All of the above individuals are employees of Carolina Power &
Light Company at the Shearon Harris Nuclear Power Plant, Route 1, Box 101, New Hill, North Carolina 27562.
INTERROGATORY NO. G1(d). Please identify all facts concerning which each such person identified in response to G1(c)(1) above has first-hand knowledge.
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- ANSWER: See snswer to Interrogatory No. G1(c).
INTERROGATORY NO. Gl(e). Please identify all facts and/or documents upon which each person identified in response to Gl(c)(2) above relied in providing information to respond to the interrogatory, including the parts of such documents relied upon.
ANSWER: All facts or documents relied upon by those individuals identified in the answer to Interrogatory No. G1(c) are indicated within each response to the specific interroga-tories on Contentions 41 and 65.
INTERROGATORY NO. G1(f). Please identify any other document (s) used or relied upon by Applicants in responding to the interrogatory.
ANSWER: See answer to Interrogatory No. G1(e).
INTERROGATORY NO. G1(g). Please state which specific fact each document, identified in G1(e) and G1(f) above, supports, in the opinion or belief of Applicants, or which Applicants allege such document supports.
ANSWER: Applicants have indicated which specific facts are supported by the documents identified, within each response to the specific interrogatories on Contentions 41 and 65.
INTERROGATORY NO. G1(h). Please state specifically what information each person identified in response to G1(c)(1) or G1(c)(2) above provided to or for Applicants' affiant in answering the interrogatory. If any of this information is not .
documented, please identify it as " undocumented" in responding l to.this section of General Interrogatory Gl. j l
ANSWER: See answer to Interrogatory No. G1(c).
INTERROGATORY NO. G2(a). Please state the name, present or last known address, title (if.any), and present or last known employer, and economic interest (shareholder, bondholder, ~
contractor, employee, etc.) if any (beyond expert or other witness fees) such person holds in Applicants or any of them, 1
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s a for each person you intend or expect to call as an expert witness or a witness in this proceeding, if such information has not previously been supplied, or has changed since such information was last supplied, to Wells Eddleman. This applies to Eddleman and Joint Contentions as admitted, or stipulated by Applicants.
ANSWER: Applicants have not yet identified the expert or other witnesses they expect to call in this proceeding. When and if such witnesses are identified, Applicants will supple-ment this response in a timely manner.
INTERROGATORY NO. G2(b). Please identify each contention regarding which each such person is expected to testify.
ANSWER: See answer to Interrogatory No. G2(a).
INTERROGATORY NO. G2(c). Please state when you first contacted each such person with regard to the possibility of such person's testifying for Applicants, if you have contacted such person.
ANSWER: See answer to Interrogatory No. G2(a).
INTERROGATORY NO. G2(d). Please state the subject matter, separately for each contention as to which each such person is expected to testify, which each such person is expected to testify to.
ANSWER: See answer to Interrogatory No. G2(a).
INTERROGATORY NO. G2(e). Please identify all documents or parts thereof upon which each such witness is expected to, plans to, or will rely, in testifying or in preparing testi-mony.
ANSWER: See answer to Interrogatory No. G2(a).
INTERROGATORY NO. G3(a). Please identify any other source (s) of information which Applicants have used to respond to any interrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.
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ANSWER: Applicants have identified all such other sources of information, if any, within the answers to the specific interrogatories set forth herein.
INTERROGATORY NO. G3(b). Please identify any other source (s) of information not previously identified upon which any witness identified under G2 above, or other witness, has used in preparing testimony or exhibits, or expects to use in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the part or part(s) of such source (if applicable) which are expected to be used, and, if not previously stated, the fact (s) or subject matter (or both) to which such source relates.
ANSWER: See answer to Interrogatory No. G2(a).
INTERROGATORY NO. G4(a). Please identify all documents, and which pages or sections thereof Applicants intend or expect to use in cross-examination of any witness I call in this hearing. For each such witness, please provide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject matter Applicants believe they relate to, and make the document (s) available for inspection and copying as soon as possible after Applicants decide or form intent to use such document in cross-examination.
ANSWER: Applicants have not yet identified which docu-ments, if any, they intend to use in cross-examination of Mr.
Eddleman's witnesses.
i INTERROGATORY NO. G4(b). Please identify any undocumented information Applicants intend to use in cross-examination of l each such witness for me. -
l ANSWER: See answer to Interrogatory No. G4(a).
( INTERROGATORY NO. G5(a). For each contention Applicants l state or admit is an admitted Eddleman contention under G1(a) above, or an admitted joint intervenor contention, please state whether Applicants have available to them experts and informa-tion, on the subject matter of the contention.
ANSWER: Applicants have available to them experts and information on the subject matter of Contentions 41 and 65.
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- t INTERROGATORY NO. G5(b). If the answer to (a) above is other than affirmative, state whether Applicants expect to be able to obtain expertise in the subject matter, and information on it, and if not, why not.
ANSWER: Not applicable.
INTERROGATORY NO. G7. Please identify all documents which Applicants plan, expect or intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted which is included in your current response to Gl(a), in this proceeding. For each such document, specify the contention and the subject matter to which it relates.
ANSWER: Applicants have not yet identified all those
. documents they intend to offer as exhibits relating to Eddleman Contentions 41 and 65. With respect to Contention 41, Applicants anticipate offering the June 11, 1981 Final Report,
" Weld Symbol Errors and Misapplication of Weld on Bergen-Patterson Pipe Hangars."
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INTERROGATORY NO. G8. Please identify all other informa-tion, not identified in response to the above general inter-rogatories, tha'c Applicants rely on or use or plan or expect to use in preparing testimony, or in conducting cross-examination, or in preparing exhibits, for this proceeding, with respect to each Eddleman contention and Joint contention which is admitted
! in this proceeding and on which discovery is currently open or on which discovery has been open under the schedule laid out by the Board 3-10-83. Please state for each such item of informa-tion the contention and subject matter to which it relates.
ANSWER: Applicants have not yet identified any "other information" which they plan to use in this proceeding relating to Eddleman Contentions 41 and 65 beyond that discussed in the answers to specific interrogatories herein.
OBJECTION: To the extent this interrogatory seeks t
information beyond the scope of the answer provided, it is
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objected to as being overly broad, irrelevant, burdensome, and seeking protected or privileged information.
1 RESPONSES TO INTERROGATORIES ON CONTENTION 41 INTERROGATORY NO. 41-1(a). Please identify every person who has ever inspected at least one pipe hanger weld at the Harris plant, to Applicants' knowledge. If privacy considera-tions would in your view preclude disclosure of the identifica-tion of any such person, list each person by a unique number (E.G. Weld inspector #1, Pipe Hanger Inspector #13).
ANSWER: Persons who have inspected Seismic Category I pipe hanger welos at the Harris Plant are identified in Exhibit 1.
INTERROGATORY NO. 41-1(b). For each person identified in a above, state what qualifications if any that person had as a weld inspector when hired, what tests in welding inspection she or he passed-before or after hiring for the Harris plant, the time between passing any such test and the date of hiring, i whether Applicants possess the results of such test, the requirements of such test (or questions on it), any other j content or nature of such test or tests, and any other informa-tion Applicants have about the qualification of such person to inspect welds.
ANSWER: During the hiring process, CP&L does consider previous background and experience; however, CP&L does not test for welding inspection ability prior to hiring. After hiring,
! individuals are sent through a training program (which includes i
self-study and on-the-job training) and are required to pass qualification tests prior to performing inspections in the field. The personnel training and qualification programs are i
described in CP&L Procedure CQA-1. CP&L does possess the results of qualification tests given to the weld inspectors.
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Exhibit 1 summarizes the qualification of welding inspectors !
prior to hiring.
I INTERROGATORY NO. 41-1(c). For each person identified in a above, state whether the person was able to read welding ;
blueprints, including size, type, width penetration, side, length, method, and other welding blueprint symbols. For any person for whom the answer to any of the preceding matters in this part c or all of them is yes, state exactly how and when Applicants verified each such fact or ability, and whether a record of such verification is still in Applicants' possession.
l ANSWER: Yes, each person identified in Exhibit 1 is capable of performing the tasks identified in this inter-rogatory. This capability is verified during the oral and I
written qualification tests and certification process.
Records, attesting to inspectors' test results, are maintained by Applicants.
INTERROGATORY NO. 41-1(d). State exactly how the welding symbols, blueprints, and specifications for pipe hanger welds as put together by Applicants' design parsonnel were checked before the pipe hangers were welded. State also if anyone on-site checked these matters, and if so, who checked each such welding specification and when, identifying the qualifications of all persons who checked these welding specifications, blueprints and symbols, and whether they were adjudged by such l
person to be correct or not.
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l ANSWER: Welding procedure specifications are reviewed by
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QA Engineers prior to start of work. QA Engineers are degreed engineers. Errors have not been noted in approved welding procedure specifications. Welding blueprints and symbols are not reviewed by QA/QC personnel. However, the design drawings, after checking and release by the design organization (i.e.,
Bergen-Patterson, Ebasco or CP&L), are again reviewed either by
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Construction Engineering Mechanical or Welding Group personnel prior to release of each work package; these construction engineering personnel fill out the Weld Data Reports (WDR's) which accompany the work package. Results of these reviews (i.e., whether the blueprints and symbols were judged correct) are not tabulated. Within the design organization, the design drawings are checked by designers under the supervision of registered engineers. Most of the designers are degreed engineers. See also answers to Interrogatory Nos. 41-4(d) and 41-4(h).
OBJECTION: Applicants object to performing the research and compilation necessary to answer the interrogatory literally as burdensome and oppressive. Roughly 50,000 drawings in 16,000 work packages would have to be reviewed to identify the information by blueprint and symbol.
INTERROGATORY NO. 41-1(e). For each such symbol, welding blueprint or specification judged incorrect, state when corrective action was taken and what corrective action was taken. State also if this was before or after the welding was done.
ANSWER: Any unclear or questionable detail on any hanger drawing which is identified during the reviews of the drawing is revised to moet the requirements of applicable specifica-tions, codes and standards. Revision takes place prior to release of the hanger sketch for final welding. Any additional problems identified during inspection are corrected by drawing revision and reinspection. Welding procedure specifications were not found to be incorrect.
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OBJECTION: See objection above to Interrogatory 41-4(d) as to answers by blueprint and symbol.
INTERROGATORY NO. 41-1(f). State what percentage of pipe hangers were required to be inspected under Applicants QA program prior to the NRC inspector's idantification of the defective welds on 3 September 1980. If there was no percent-age required, how was the number or percentage of welds to be inspected determined?
ANSWER: All Seismic Category I pipe hanger field welds were required to be inspected prior to the hanger being accepted.
INTERROGATORY NO. 41-1(g). What percentage of pipe hangers were required to be inspected by Applicants' QA program prior to 9/3/80?
ANSWER: All Seismic Category I pipe hanger field welds were required to be inspected prior to the hanger being accepted.
INTERROGATORY NO. 41-1(h). What percentage of pipe hangers actually had been inspected, of those installed prior to 9/3/80, as of 9/3/80? What percentage of pipe hangers installed had been inspected prior to 1-1-80? Prior to 1-1-79?
If none, so state.
OBJECTION: All hangers are required to be inspected prior to being accepted. A tabulation, however, summarizing the above requested information, has not been compiled, nor is such data readily accessible. Applicants object to performing the requested research and compilation of immense volumes of documents as burdensome and oppressive. Roughly 55 file drawers of WDR's would be involved in such a search.
INTERROGATORY NO. 41-1(i). What percentage of pipe hanger welds had actually been inspected at Harris prior to 9/3/80, of those installed and welded by that date? Of those welded by 9/30/80 but not installed? Of those installed by 1-1-80, what percentage or number had been inspected by 1-1-80.
OBJECTION: The interrogatory is either duplicative of No.
41-1(h) or it is incomprehensible.
INTERROGATORY NO. 41-1(j). What percentage defective welds had been identified as of (1) 9/3/80; (2) 1-1-80; (3) 1-1-79 among the welds on pipe hangers (a) installed by that date, for each date; (b) welded by that date, for each date, but not installed.
ANSWER: This information is not available since records are maintained by hanger numbers and not by welds.
INTERROGATORY NO. 41-1(k). Do Applicants possess the records of weld inspections for all welds at the Harris plant on pipe hangers? Will they make these available for inspection and copying?
ANSWER: Applicants do possess records of field weld inspections for all Seismic Class I pipe hangers installed at the Harris Plant. Records that will be made available consist of approximately 36 notebooks containing the most recent Weld Data Reports on inspections of all Seismic Category I hangers.
These records do not contain a complete historical trace for all hangers. For the inspections included, however, the records provide documentation of the welding inspection, the date the inspection was performed and the inspector. These records will be made available pursuant to Applicants' Response to Wells Eddleman's Request for Production of Documents.
t OBJECTION: Applicants object to performing the research and compilation which would be necessary to produce the requested documents for all Seismic Category-I pipe hanger inspections. Roughly 20,000 pages of WDRs and work packages are involved. They are a part of active files and their j removal would require suspension of some project work. This would be burdensome and oppressive, especially when viewed against the unrecognizable benefit to the requesting party.
INTERROGATORY NO. 41-1(1). Identify every person who i welded a pipe hanger that has been installed at the Shearon Harris plant at any time.
OBJECTION: Applicants object to this interrogatory as outside the scope of the contention, which is limited to the inspection of pipe hanger welds. The contention does not go to the issue of how the welder executed his task, but whether defective hanger welds have been improperly inspected and approved. See Licensing Board Memorandum and Order . . .,
September 22, 1982, at 49-50; Licensing Board Memorandum and I
order . . ., January 17, 1983, at 4.
INTERROGATORY NO. 41-1(m). For each such person, state the date hired, the date discharged if the person has been i discharged, the date of resignation or leaving work if resigned
~. laid off, and the qualifications in welding Applicants established each such person had when hired. State any additional training each such person received in welding while employed by Applicants (including their contractors and subcontractors, etc.) and what welding tests or welding qualification tests each such person passed, and when, identifying all such tests passed and any tests the person failed, and when. State whether Applicants or their con-tractors or subcontractors possess records of such tests passed or failed. Will Applicants make the results of each such test available for inspection and copying? Did Applicants,
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including contractors and subcontractors, retain the specimens or test pieces welded by this person in each welding test that person took? If not,-why not? .If yes, will Applicants make the specimens and test pieces available for inspection or
.further. testing?
OBJECTION: See objection to. Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-1(n). For each welder identified in m above, state whether Applicants know if this person could read welding blueprints, including ~ symbols for size, length, position, penetration, groove preparation, heat treatment, undercut allowable, type of electrode required, current setting and type (DC or AC). If yes, how do Applicants know this and-when did they first know it. If no, please so state.
{ OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-1(o). Have Applicants established who made the defective welds identified on_ pipe hangers at Harris?
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-1(p). List for each welder identified.in m above,.the total number of welds s/he has welded as of (1) 1-1-79 (2) 1-1-80 (3) 9-3-80 (4) 1-1-81 (5) 1-1-82 and as of the end of each calendar year after 1982, on pipe hangers; the number of such pipe hanger ~ welds which had been inspected as of each date (1-1-79 etc.); the number of I
such welds which had been found defective (a) as of each such date (b) in any reinspections after 9-3-80.
i I OBJECTION: Not applicable. See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-1(q). If Applicants don't know who
- made the defective pipe hanger welds, will they admit their QA program is inadequate in that respect?
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-1(r). Were any welders discharged
- due to making defective pipe hanger welds at Harris prior to 9/3/80? Identify each such welder.
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s OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-1(s). Were any welders discharged due to making defective pipe hanger welds at Harris after 9/3/80? Identify each such welder.
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-1(t). Were any weld inspectors other than those identified in the report (Revision 1, dated 11 June 1981 on Weld symbol' err' ors and misapplication of weld on Bergen-Patterson pipe hangers) discharged by CP&L due to failure to catch defective pipe hanger welds after 9/3/80?
ANSWER: The referenced report does not so indicate and no weld inspectors have been discharged for failure to catch defects on pipe hanger welds.
INTERRO_GATORY NO. 41-1(u). Were any inspectors discharged for failing to catch errors in pipe hanger welds at Harris prior to 9/3/80? i -
ANSWER: No.
INTERROGATORY NO. 41-1(v). Identify all such inspectors who are included under items t and u above, diccharged for failure to detect pipe hanger weld defects.
- ANSWER'
- Not applicable.
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j INTERROGATORY NO. 41-1(w). Were any persons discharged who had checked the weld specifications on pipe hangers at
- Harris prior to 9/3/80, for failure to detect errors in such?
Identify all such persons.
ANSWER: No. See also answer to Interrogatory 41-1(d).
INTERROGATORY NO. 41-1(x). Were any persons discharged or disciplined who had checked the weld specifications on pipe hangers at Harris, if.'such discharge or discipline occurred l after 9/3/80 or on thas date? Identify all such persons.
, ANSWER: See answer to Interrogatory No. 41-1(w).
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- INTERROGATORY NO. 41-1(y). Do Applicants possess informa-tion detailing every error in pipe hanger welds which they have so far detected at Harris? If yes, will they make this information available for inspection and copying?
ANSWER: See answer and objection to Interrogatory No.
41-1(k).
INTERROGATORY NO. 41-1(z). Do Applicants possess any information detailing errors in weld specifications, inspection of welds, or welding of pipe hangers at Harris which is not included in their June 11, 1981 revision 1 final report to NRC?
Will they make that information available for inspection and copying?
ANSWER: All relevant information available at that time was summarized in the June 11, 1981, Final Report to NRC.
Documents made available as a result of the response to Interrogatory 41-1(k) may provide supplemental information.
INTERROGATORY NO. 41-2. Please answer parts a through z of 41-1 above, limiting your answers to welds on Bergen Patterson pipe hangers of Seismic Class I, i.e. interpreting the word " welds" in each part of 41-1 interrogatory to mean
" welds on Bergen-Patterson pipe hangers for Seismic Category I".
ANSWER: See the above answers to Interrogatory Nos.
41-1(a) through (z).
INTERROGATORY NO. 41-3(a). Were all pipe hangers at Harris reinspected after 9/3/80? If not, how many weren't?
ANSWER: All Seismic Category I hangers at Harris installed or partially installed prior to 9/3/80 were inspected or reinspected after 9/3/80.
INTERROGATORY NO. 41-3(b). For every pipe hanger rejected as a result of reinspection please identify the exact defect (s) it had in its welds, where these defects were dispositioned or located, and how they were identified. See also answer to Interrogatory 41-1(k).
ANSWER: The types of defects noted as a result of the reinspection are shown in the June 11, 1981, Final Report to the NRC. Information on specific location of the defect (s) is not available. The defects were identified by marking the base metal adjacent to the weld and were noted in the reinspection package. Identified defects were dispositioned or repaired.
See also answer to Interrogatory 41-1(k).
INTERROGATORY NO. 41-3(c). Were any such defects, for each hanger, unable to be seen on previous inspections?
ANSWER: No.
INTERROGATORY NO. 41-3(d). For each such hanger, state who reinspected it, how long they took to reinspect it, and whether they stated all defects in writing.
ANSWER: Inspectors are identified in the documents produced in response to Interrogatory No. 41-1(k). Weld defects were documented. The time it took to perform the inspections was not recorded.
INTERROGATORY NO. 41-3(e). For each such rejection of hanger in b above, identify and produce all field change requests, requests for permanent waiver, and field rework orders issued with respect to it.
OBJECTION: Identification and retrieval of the docu-I mentation requested for pipe hangers would be burdensome and oppressive. A search for approximately 1000 documents would be involved in producing this information. The effort required to retrieve these documents is estimated to be six man days. In addition, the information sought is irrelevant since it does l
not address the adequacy of weld inspection.
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ANSWER: With respect to HVAC and conduit hangers, Exhibit 8 of the June 1981 Final Report lists all FCRs, PWs and DCNs applicable. These reports and all reworks will be produced pursuant to Applicants' Response to Wells Eddleman's Request for Production of Documents.
INTERROGATORY NO. 41-3(f). For each hanger in e above, state what review of the field work orders, field change request, or request for permanent waiver was done, and the date for each such field work order, field change request (FCR) or permanent waiver request (PW) and the date each such was approved. If any such FCR or PW request was denied, or any field work order modified for this hanger, so state, and explain fully, for each hanger covered by this interrogatory.
ANSWER: Site Mechanical Engineering unit personnel reviewed the results of the reinspection and determined whether to rework or to revise the drawing. The date that the rework was inspected is listed on the rework form. The date of the permanent waiver or hanger revision is listed on the actual document. Any modifications or request denials can be identified by reviewing the subject documents.
OBJECTION: See objection above to Interrogatory No.
41-3(e). ,
INTERROGATORY NO. 41-4(a). Did CP&L QA or QC inspect any drawings of pipe hanger welds, as sent out by Bergen-Patterson or otherwise, before the welding was done according to those drawings, before 9/3/80?
ANSWER: No, review of pipe hanger drawings is not the responsibility of CP&L QA/QC. This activity was performed by the design organization and Ebasco.
d INTERROGATORY NO. 41-4(b). If answer to a above is affirmative, what fraction of the drawings received at the Harris site were inspected? Of those inspected, how many were found to have errors, unclear details or missing details?
ANSWER: Not applicable as to QA/QC personnel. See also answer to Interrogatory No. 41-4(f).
INTERROGATORY NO. 41-4(c). Does Applicants' QA/QC retain records of any such inspections made, or listed in response to a or b above, of pipe hanger weld drawings received at Harris prior to 9/3/80? If so, will Applicants make all such records available for inspection and copying?
ANSWER: Not applicable.
INTERROGATORY NO. 41-4(d). Does Applicants' QA/QC program now inspect every drawing for pipe hanger welds received from Bergen Patterson?
ANSWER: No. Site QA/QC is not in the review cycle for drawings. See answer to Interrogatory No. 41-4(e).
INTERROGATORY NO. 41-4(e). If answer to d is affirmative, when was this begun? Is it a formal policy? Does it apply to drawings of other safety-related welding, e.g. that on embeds?
OBJECTION: Applicants object to this interrogatory to the extent that it seeks information regarding the inspection of other types of welding as outside the scope of the contention, which is limited to the inspection of pipe hanger welds.
ANSWER: Review of drawings is being performed in accor-dance with the corrective action described in the June 11, 1981 Final Report to the NRC. Site Construction Engineering personnel (Mechanical or Welding) presently review each hanger drawing received from Bergen-Patterson for missing, unclear,
and incorrect weld symbols prior to each hanger being issued to the field. This practice began in September, 1980. ,
INTERROGATORY NO. 41-4(f). If answer to d above is other than affirmative, state how many or what percentage of drawings of pipe hanger welds received have been inspected since 9/3/80, and the total number of such drawings received at the Harris site since 9/3/80.
ANSWER: The exact percentage of drawings of Seismic Category I pipe hanger welds that have been reviewed since 9/3/80 is 100% for hangers issued to the field for installa-tion. The exact total number of such drawings received at the Harris site since September 1980 has not been determined. It has been estimated by the Harris Plant Engineering Section that approximately 5500 new pipe hanger drawings and approximately 50,000 revised pipe hanger drawings have been received since September 1980 (as of 4/20/83).
INTERRCGATORY NO. 41-4(g). List all persons who reviewed pipe hanger drawings at Harris prior to 9/3/80 and state each's qualifications for such work.
ANSWER: CP&L site personnel were not involved in the review of weld drawings prior to September 1980. During that time period such reviews were conducted by the design organiza-tion and Ebasco.
INTERROGATORY NO. 41-4(h). List all persons not listed above who reviewed pipe hanger drawings at Harris after or on 9/3/80, and the qualifications of each one for such work.
ANSWER: CP&L site engineering personnel began reviewing pipe hanger drawings in September 1980. There is no formal 1
qualification program that these site engineering personnel must complete prior to being given responsibility for reviewing hanger drawings and their educational background varies from high school to college graduate. Because of the varying educational and experience levels of these personnel, the decision to assign personnel to drawing reviews is made on a case-by-case basis by the group Tupervisor upon a demonstration of the individual's understanding of applicable requirements.
The names of the persons at Harris who have reviewed pipe hanger drawings on or after 9/3/80 are listed on the attached Exhibit 2.
INTERROGATORY NO. 41-4(1). List all persons under g above who are no longer at Harris, giving last known address for each.
OBJECTION: Applicants object to this interrogatory as irrelevant to the contention.
INTERROGATORY NO. 41-4(j). Are weld drawing reviews for pipe hangers independently checked at Harris now on a routine basis by two or more persons?
ANSWER: Seismic Category I pipe hanger drawings are reviewed at the site by one or more CP&L construction engi-neering personnel prior to release to the field.
INTERROGATORY NO. 41-4(k). If answer to j above is other than affirmative, state what additional review, if any, is being made to check the review of pipe hanger weld drawings received at Harris, or to see how well the review is done. If none, so state. If there is a p.Ocedure or QA/QC requirement for how many such drawings will !' rechecked, state it and when it was established, and state how if at all it was changed after 9/3/80.
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- ANSWER: Not applicable.
INTERROGATORY NO. 41-4(1). If answer to j above is affirmative, state how many drawings have been reinspected, and identify all such drawings of pipe hanger welds on which missing, unclear or wrong symbols or instruction were found upon review, and the total number of such drawings found to contain errors upon reinspection.
ANSWER: See answer to Interrogatory 41-4(j) above. Any problems, including constructability, interferences, and field related problems requiring design changes are identified for resolution in accordance with approved procedures. Weld drawing errors are not specifically identified and tracked.
INTERROGATORY NO. 41-4(m). State the qualifications for inspecting such drawings, and the identity of, each person at the Harris site who re-inspects or checks initial inspection of pipe hanger weld drawings received at Harris.
ANSWER: See answer to Interrogatory No. 41-4(h).
INTERROGATORY NO. 41-4(n). Provide the information requested in m above for all persons who have reinspected at least one drawing at Harris of pipe hanger welds, after 9/3/80, if not already given above. .
ANSWER: See answer to Interrogatory No. 41-4(h).
INTERROGATORY NO. 41-4(o). State when pipe hanger weld drawings were first double-checked at Harris and when such drawings were first triple checked at Harris, if ever; and the percentage of errors found in such drawings upon double-checking and upon triple checking during any periods when such checking was done, identifying each such time period.
ANSWER: Seismic I pipe hanger drawings are reviewed prior to release for final installation and inspection. Many of these drawings are revised several times and each revision is reviewed prior to issuance to the field. Revisions are i
generated by change in piping design, by additions or deletions of other equipment or hangers, and by the need to identify "as-built" field conditions on the drawing. Revisions required to correct or clarify drawings are not tracked separately from revisions required for other reasons.
INTERROGATORY NO. 41-5(a). State whether welders working at Harris had any instructions, prior to 9.3.80, on what to do if a weld drawing was unclear, unreadable, or in obvious error?
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-5(b). If answer to a above is affirmative, state the exact instructions, whether written or oral, and the dates in effect. State also whether Applicants know if each welder working on pipe hangers knew of each such instruction.
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-5(c). If answer to a above is other than affirmative, did QA/QC know of the non-existence of such instructions?
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-5(d). Name every welder who worked on pipe hangers at Harris who identified an unclear or missing detail or instruction on a pipe hanger weld blueprint to a
- superior (foreman, etc) or QA/QC person at Harris prior to l 9/3/80, and state the date on which s/he did it, and what action was taken with respect to such blueprint, for each such blueprint.
I OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-5(e). If no action was taken under (d) above for any report, or if CP&L cannot document the action, so state; otherwise, provide all documentation of actions taken on such identification of unclear or missing detail or instruction on a pipe hanger weld blueprint prior to 9/3/80, for inspection and copying.
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-5(f). State whether any welders at Harris made defective pipe hanger welds after going through Applicants' welder training program.
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-5(g). If answer to f above is affirmative, state name of each such welder, and the number of defective pipe hanger welds s/he made; state also if such welder has been discharged for making defective welds.
OBJECTION: See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-5(g)[ sic]. Identify all welders, inspectors, and QA/QC personnel who worked on pipe hanger welds or inspected same or blueprints for same at Harris prior to 9/3/80 and state for each whether CP&L had verified that person's ability to read weld blueprints properly prior to 9/3/80.
OBJECTION: Applicants object to this interrogatory to the extent that it seeks information on welders as outside the scope of the contention. See objection to Interrogatory 41-1(1).
ANSWER: The answer to Interrogatory No. 41-1(a) provides j the requested information concerning inspectors. Verification 1
that inspectors can read weld blueprints is done prior to l qualifying the inspector.
INTERROGATORY NO. 41-5(h). State whether the 12.7%
failure rate for pipe hanger welds shown on Exhibit 1 to CP&L's 6-11-81 letter to NRC re pipe hanger welds is acceptable to CP&L QA/QC at Harris.
ANSWER: CP&L QA/QC does not establish the criteria for failure rate. Rather, QA/QC ensures that the accept / reject criteria established by CP&L Engineering are met.
INTERROGATORY NO. 41-5(i). State exactly how many weld drawings have been returned to the Site Mechanical Unit under the policy of returning such when it is not possible to weld the hanger exactly as drawn due to physical limitations or drawing errors.
ANSWER: Since 9/3/80, the number of hangers returned with drawing errors or problems with physical limitations is not known since this information is not specifically tracked.
OBJECTION: Approximately 6,000 pipe hanger problem reports and field change requests and an additional 2,000 reports on HVAC and conduit hangers would have to be reviewed to determine this information. Applicants object to performing such research and compilation as burdensome and oppressive.
Further, the information sought is not relevant to the conten-tion. -
INTERROGATORY NO. 41-5(j). For each weld drawing which was returned due to the reasons set forth in i above, since 9/3/80, state exactly what was done to resolve the problem and document all such resolution by identifying all documents which show or contribute to such resolution or approve such rcsolu-tion.
ANSWER: See answer and objection to Interrogatory No.
41-5(i).
i INTERROGATORY No. 41-5(k). State whether any permanent waivers have been granted for any weld for which a drawing has been returned to the Site Mechanical Unit for the reason (s) set forth in i above or any of them, and for each such permanent waiver, state the basis therefor and any engineering rationale underlying it, and state who granted the waiver or approved it.
ANSWER: Yes. A permanent waiver could be used to correct the conditions described in Interrogatory No. 41-5(i). The l
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approval is by the pipe hanger designer (Bergen-Paterson) or by the Harris Plant Engineering Section after performing calcula-tions to justify the adequacy of the configuration; approval of permanent waivers by the Harris Plant Engineering Section or Ebasco is needed for HVAC and conduit hangers.
OBJECTION: As to information sought for each 17er, see objection above to Interrogatory No. 41-5(i).
INTERROGATORY NO. 41-5(1). Identify any drawings pointed out to the Site Mechanical engineering unit by QA or QC personnel due to such defects as identified or listed in i above; state for each the resolution of the problem.
ANSWER: CP&L QA/QC personnel have referred drawings to the Site Mechanical Engineering (or Electrical Engineering for HVAC and conduit hangers) units for the reasons identified in Interrogatory No. 41-5(1). However, the requested information is not available as these referrals and subsequent dispositions are not tracked by individual drawing.
INTERROGATORY NO. 41-6. Answer all questions and all parts of Interrogatories 41-3, 41-4, 41-5 above, inclusive, with respect to (a) Bergen-Patterson pipe hangers only (b) HVAC hangers only (c) Cable tray and electrical conduit hangers only (d) has any such analysis been done for non-seismic-category-I hangers of any kind at Harris, as is asked about in 41-3, 41-4, or 41-5 above, or any such reinspections made?
ANSWER: Unless otherwise noted above, the response to subparts (a), (b) and (c) of this interrogatory is the same as the answers and objections to Interrogatories 41-3, 41-4 and 41-5; i .e., HVAC and conduit hangers were subjected to the same reinspection and inspection programs described above, except
that HVAC and conduit hanger drawings are not subject to construction engineering reviews. There are not drawings for each support; the weld details are generic for each different type of support. Rather, there is one set of drawings showing standard joints and weld details. These drawings have been reviewed by site personnel and are not re-examined for each individual support.
OBJECTION: Applicants object to subpart (d) of this interrogatory because non-Seismic Category I hangers are not safety-related components, and therefore are not relevant to this contention or within the scope of this proceeding. ,
INTERROGATORY NO. 41-7. Identify all persons retrained in welding, blueprint reading, or inspection re pipe hangers or other supports by CP&L since 9/3/80 and when each such person was retrained, for how long, using what curriculum and mate-rials (produce same for inspection and copying), and state what tests if any were given to each such person during or after such training to determine the effect of such training (or for any other purpose) and what the results of those tests were for that person, for each such person.
OBJECTION: Applicants object to this interrogatory to the extent that it seeks information regarding welders as outside f,he scope of the contention. See objection to Interrogatory No. 41-1(1).
ANSWER: Subjects covered during retrair.ing of weld inspectors included (i) weld symbol identification; (ii) weld inspection techniques and criteria; (iii) procedure require-
- ments. Information which provides details of the retraining
given to the inspectors will be produced in accordance with Applicants' Response to Wells Eddeman's Request for Production of Documents. Written tests to inspection personnel were not given after completion of these training classes.
INTERROGATORY NO. 41-8. Identify all welds made by persons listed in 41-7 above (response) which have been found to be defective in anyway since the person was retrained, listing for each such person all such defective welds.
OBJECTION: Applicants object to this interrogatory as outside the scope of the contention. See objection to Interrogatory No. 41-1(1).
INTERROGATORY NO. 41-9. Identify any inspections made by any person identified in response to 41-7 above which have been reinspected since 9-3-80 after such person was retrained in inspection. For each such re-inspection, state if any defects were found in any welds inspected. State also the number of such defective welds found upon reinspection, and the total number of welds reinspected, for each such person who has been retrained in inspection since 9-3-80.
ANSWER: Documents produced in response to Interrogatory No. 41-7 identify the weld inspectors who participated in the retraining program. See also answer to Interrogatory No.
41-1(k).
OBJECTION: This information has not been compiled into a single document since such action wou.ld entail the review and analysis of approximately 20,000 documents, and would therefore be burdensome and oppressive.
INTERROGATORY NO. 41-10. State exactly what was taught re blueprint reading and weld symbol identification, to whom, since 9/3/80 as described in item 2 on page 2 under " corrective action" in CP&L's 6-11-81 to NRC re pipe hanger defects and the
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l report attached to such letter, at p.2 also of this report attached to the 6-11-81 letter.
ANSWER: Documents produced in response to Interrogatory No. 41-7 provide details on the scope of the inspector retrain-ing program.
INTERROGATORY NO. 41-11. Please list each pipe hanger defect, HVAC hanger defect, or cable tray or conduit hanger defect identified since CP&L made its rev. 1 report on pipe hanger defects on 6-11-81, at the Harris plant. For each such, please state when it was found, by whom, and whether it is mentioned in any NRC inspection reports, and if so, which reports, of what date, by whom.
ANSWER: See answer to Interrogatory No. 41-1(k) as to pipe hangers. NRC Reports 50-400/83-05-01, issued on February 4, 1983, and 50-400/82-03, issued April 28, 1982, and Applicants' letters dated March 24, 1982 (CQAD 82-519),
September 13, 1982 (CQAD 82-1560), and March 31, 1983 (NRC-52),
identify additional defects not previously mentioned.
OBJECTION: The information required to respond to this question literally has not been compiled since such action would entail the review and analysis of approximately 20,000 documents. This would be burdensome and oppressive.
RESPONSES TO INTERROGATORIES ON CONTENTION 65 l
l INTERROGATORY NO. 65-1(a). Please state how the quality
- of concrete for each pour in the Harris base mat, containment walls, and auxiliary building and fuel building (spent fuel l pool) was assessed by Applicants and whether samples of the mix
- have been retained by Applicants for each such pour.
1 OBJECTION: Applicants object to this interrogatory to the l
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extent that it seeks information relating to concrete placements other than those associated with the containment building as outside the scope of the contention.
ANSWER: All concrete placements are closely controlled by methods prescribed in site work procedures, technical proce-dures, and administrative procedures. The control of concrete placed begins with the purchase and testing of concrete constituent materials. The batching process is also closely monitored, with each batch of concrete being accepted / rejected by a qualified QC Inspector to assure proper mix proportions and homogeneity of the mix. The concrete is further inspected at the placement by a qualified Construction Inspector who verifies the mix design identification number for each truck and follows all aspects of the placing operation including transporting, placing, consolidation and final finishing. In addition, a QA Inspector performs air content, slump, unit weight, and temperature tests in addition to molding com-pressive strength cylinders on a set frequency for each placement. The Construction Inspector also monitors curing operations for each placement and insures that the proper i concrete temperature and moisture conditions are being maintained. A post-placement check is subsequently performed by the Construction Inspector to make a final check on the quality of the placement. Any defects which may exist are identified and repaired using prescribed repair procedures.
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1 All inspection documents are summarized into a " pour package" which is reviewed by the Construction Inspection Supervisor for accuracy and conformance to procedures prior to being submitted to QA for final review and filing in permanent plant records.
Samples of concrete for all placements are retained by QC for compressive strength testing at a cylinder age of 7 and 28 days. In addition a reserve cylinder is retained for several months after each placement should any additional concrete testing be requested at a later date.
INTERROGATORY NO. 65-1(b). For each pour in each area identified in a above (or listed by me in that interrogatory) please state the date(s) of the pour, the supervisor (s) of that pour, the time (s) in which the pour took place, and whether a concrete placement report or equivalent, exists for such pour, and whether a sample or samples of such pour was retained by Applicants, and identify each such sample.
ANSWER: All the referenced concrete placements are identified by concrete placement numbers using a code system.
These placement numbers are recorded on a Concrete Placement Report. A Concrete Placement Report is initiated for each placement and has approval signature blocks at each phase of work prior to actual concrete placement. A qualified Construction Inspector examines all items to be embedded in a cencrete placement prior to the actual placement and documents
.the inspections for accept / reject criteria. These inspection documents are combined prior to the placement into a " pour package" and reviewed by the Construction Inspection Supervisor for accuracy.
Following the placement these " pour packages" are sent to the permanent plant filing systems. Any such information as to the date of the pour, supervisory personnel on the pour, time at which the pour took place, concrete placement report number, and any information relating to the pour, can be found in (or referenced by) the " pour package". Samples of concrete for all referenced placements are retained by QC for compressive strength testing at a concrete cylinder age of 7 and 28 days.
In addition, a reserve cylinder is retained for several months after each placement, should additional concrete testing be requested at a later date.
OBJECTION: See objection to Interrogatory No. 65-1(a).
In addition, Applicants object to the research and compilation which would be required to ascertain and present the informa-tion sought as burdensome and oppressive. This information is contained in approximately 500 separate placement packages (individual placements), which are kept in a fireproof vault in the QA Department under controlled access.
INTERROGATORY NO. 65-1(c). State for each such pour the nature and extent of all inspections made during and after the pour to detect voids or honeycombing in the pour.
OBJECTION: See objection to Interrogatory No. 65-1(a).
ANSWER: Measures are taken before a placement begins to prevent formation of honeycombs and voids. Construction Inspection personnel examine design documents to determine the difficulty of the placement. Placements which are determined h
! to be difficult are brought to the attention of the Area Engineer who then selects an appropriate concrete mix design that will perform adequately under the given placement condi-
. tions, while still meeting design strength requirements. In some cases, a super plasticized concrete mix design is used when placement conditions require use of a highly workable mix to preclude formation of honeycombs or voids.
A preventative program is also used during the actual placements. Construction Inspection personnel constantly watch the placement to insure that adequate consolidation is being used to effect a dense and homogeneous concrete placement.
- Special attention is given to vibration of concrete around dense reinforcing steel areas to prevent honeycombing. Craft personnel are instructed as to the importance of adequate vibration.
After each placement is completed, a Post Placement Inspection is conducted by Construction Inspection personnel who examine the exposed concrete surfaces for honeycombing and voids. Any honeycombing or voids which may be present are chipped out until sound concrete is encountered in the entire area. The area is then repaired and cured.
INTERROGATORY NO. 65-1(d). State for each such pour or for the area of concrete that pour emplaced, whether Applicants, Daniel or anyone else had conducted ultrasonic inspection to assess the extent of voids or honeycombing in the pour.
ANSWER: No ultrasonic testing or inspection has been performed on any concrete placed at the Harris Site.
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INTERROGATORY NO. 65-1(e). Whenever an answer to (d) above is affirmative for any pour or area, state the results of such inspection and identify all documents and records of such ultrasonic inspection.
ANSWER: Not applicable.
INTERROGATORY NO. 65-1(f). Identify all documents describing the information requested in (c) above.
ANSWER: Not applicable.
INTERROGATORY NO. 65-1(g). For all inspections listed in d or e above, state what measures, if any, were taken to distinguish the passage of sound through concrete from the passage of sound through rebar or other metal emplaced in the concrete, including trumplates and embeds.
ANSWER: Not applicable.
INTERROGATORY NO. 65-1(h). Identify any instances of honeycombing or voids in any pour in the Harris (1) base mat (2) containment wall (3) auxiliary building walls (3)(sic) containment ceiling (4) fuel building or spent fuel pool walls which Applicants have so far identified.
OBJECTION: See objection to Interrogatory No. 65-1(a).
ANSWER: There were 103 areas of voids / honeycombs out of approximately 500 placements in the Unit 1 Containment Building that required structural repair. The average surface area was approximately two square feet.
INTERROGATORY NO. 65-1(i). State for each such instance identified in response to h above when the honeycombing or void was discovered, exactly what corrective actions if any were taken for it, what the results of such corrective measures were, how those results were established, who verified the results, who took the corrective measures, and identify all documents showing how the corrective measures were planned, carried out, and inspected or tested for results.
ANSWER: The voids / honeycombs were identified during the i
routine post-placement check-out of the concrete placement.
These areas required concrete pour-backs in accordance with established construction procedures prepared and approved by CP&L and Ebasco engineers. All repair areas, whether during pre-placement, placement or post-placement, were inspected in the same manner as the original placement. In addition, concrete testing during placement and curing following place-ment were performed in the same manner as the original place-ment. Actual concrete placement was performed by the concrete construction personnel.
INTERROGATORY NO. 65-1(j). For each instance of honeycombing or voids identified above in response to any part of this interrogatory, state (1) the weakening effect of the honeycombing or voids before correction, if known, and (2) the weakening effect of such honeycombing or voids after correc-tion, if known, and how such effect was calculated and what the weakening effect is in terms of the strength of the wall or base mat involved, the gripping of concrete on the rebar in such portion or area or pour, the strength and integrity of embeds and trumplates placed in such portion, area or pour, and how such weakening effect was calculated and whether it has been verified by actual physical or mechanical test on that portion, pour or area in which the honeycombing or void (s) were found.
1 ANSWER: No evaluation is performed on patched areas to determine the weakening effect of a void because methods are outlined to effect a patch that is of acceptable quality. Once a honeycomb or void is patched, procedures are adequate to insure that the patched area is acceptable, therefore no strength loss evaluation needs to be performed.
All work procedures are prepared by a CP&L discipline engineer. Procedures for work that pertains to safety-related l
items are reviewed by the design engineer, Ebasco. This review insures the procedure will produce the quality of work the design engineer desires. If a structural repair is made, the concrete is tested during the repair placement.
INTERROGATORY No. 65-2(a). To knowledge of Applicants, including their contractor Daniel International, is it true that (1) the base mat poured in December 1977 at Wolf Creek has approximately 50 percent of its concrete test containers for the base mat pour failing (of having failed) to meet strength of 5000 psi, (2) that 5000 pai is the specified strength for test containers from this pour, (3) that the concrete used in the pour was purchased from a company that supplied Daniel with a mix formulated intended for use in ditch linings and box culverts on highways, (4) that such concrete was used in the base mat pour at Wolf Creek, and/or (5) that such concrete is not approved for a highway surface, but only for non-safety-related mud slabs and fill concrete only.
OBJECTION: Applicants and their contractors do not have this information at the Harris site. Applicants object to performing the special research which would be required to obtain the information sought. In addition, Applicants object to this interrogatory as seeking information which is irrelevant to this proceeding. See Atomic Safety and Licensing Board " Memorandum and Order (Reflecting Decisions Made i
Following Prehearing Conference)," (Sept. 22, 1982) at 58 ("...
l we do not intend to embark on a broad-ranging review of the i
contractor's past work at other projects. The circumstantial evidence possibly to be obtained would not be worth the time and effort involved.").
INTERROGATORY NO. 65-2(b). Identify all Daniel documents,
- and all other documents in Applicants' possession, which relate to the facts inquired about in (a) above.
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OBJECTION: See objection to Interrogatory No. 65-2(a).
INTERROGATORY NO. 65-3(a). At the Wolf Creek, Callaway, and Farley plants, state (1) what modifications to design and structures at each were required by (a) NRC (b) Daniel (c) the utility, after discovery of defects in concrete emplaced in the base mat or in other parts of the plant structure including the spent fuel and auxiliary buildings, wherever defects in concrete have so far been discovered; (2) the identity of all documents requesting such modifications, whether the modifica-tions were made or not, which came to Daniel International; (3) any response Daniel made to any documents requesting such modifications as asked for in (2) preceding this subsection of this interrogatory; (4) any documents Daniel used, or created, in response to such requests, other than responses, including design of modifications, and all work papers relating to such design, please identify, and state whether Daniel still possesses same; (5) identify all reports of work done in such modifications made as identified in a(1) above, and state whether Daniel possesses same; (6) identify any defects found in modification work done as stated in response to a(1) above.
OBJECTION: See objection to Interrogatory No. 65-2(a).
INTERROGATORY NO. 65-3(b). Identify all repairs made to concrete in the base mat, and containment walls, at each plant:
Callaway, Wolf Creek, and Farley, after discovery of and defects therein, whether such defects were found by Daniel or others, identifying who found the defects, when they were found, and when the concrete found defective was originally poured, and stating when repairs were begun, and when com-pleted.
OBJECTION: See objection to Interrogatory No. 65-2(a).
INTERROGATORY NO. 65-3(c). Answer every item in 65-1(a) through (j) above with respect to (1) the Callaway plant (2) the Wolf Creek Plant (3) the Farley plant, substituting the
- name of each plant listed here for "(SHNPP) Harris" in my interrogatory 65-1 wherever it occurs, and substituting Daniel for " Applicants" wherever the word " Applicants" appears in my interrogatory 65-1, throughout.
OBJECTION: See objection to Interrogatory No. 65-2(a).
INTERROGATORY NO. 65-4(a). Identify all documents in which the rebar design of the Harris base mat as it was when the base mat concrete was poured, are given.
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ANSWER: Design documents consist of masonry and reinforc-ing steel drawings by Ebasco, which wili be produced pursuant to Applicants' Response to Wells Eddleman's Request for Production of Documents.
INTERROGATORY NO. 65-4(b). If answer to (a) is none, identify all documents partially describing the Harris base mat rebar structure before the base mat was poured.
ANSWER: Not applicable.
INTERROGATORY NO. 65-4(c). Identify all documents showing the location of embeds or trumplates in the base mat of the Harris plant before the concrete of the base mat was poured.
ANSWER: See answer to Interrogatory No. 65-4(a). The design of the Harris Plant containment building base mat does not include the use of trumplates.
INTERROGATORY NO. 65-4(d). Identify the location (state it) of any embeds or trumplates added to the Harris base mat after the initial concrete pour, and state for each how additional concrete or other anchoring for it was accomplished and when this was done.
ANSWER: No embeds or trumplates have been added to the containment building base mat.
INTERROGATORY NO. 65-4(e). State the minimum clearance between rebars (1) side to side on the same level (2) top to bottom of one on the next higher level and (3) between all layers of rebar in the base mat, as viewed from the top (i.e.
the smallest open space visible from the top of the rebar layers if one looked straight down before the concrete was poured, or inspected a blueprint showing all overlays of rebar from above the basemat in top view) in the Harris base mat.
ANSWER: Minimum clearance distances between rebars in the base mat, as a rule, was 4-1/2 inches center to center. Runs of rebar comprising a " mat" are in contact at points of intersection. Clear distances between bars in the same layer will vary depending on the size of the rebar. These are standard unless further reduced by design, drawings, or ACI Codes.
INTERROGATORY NO. 65-4(f). State the average clearance between rebar in the Harris base mat for each dimension /
clearance for which the minimum is requested in (e) above.
ANSWER: The " average" clearance has not been determined.
See answer to Interrogatory No. 65-4(e). The containment base mat had a plus or minus 1-1/2 inch tolerance. The designer can provide approval to bend or shift bars around embeds or interferences with a maximum distance of 18 inches allowed between bar centers.
INTERROGATORY No. 65-4(g). State the viscosity of concrete used in each part of the pour of the Harris base mat, if such was measured at or before the time of pouring.
ANSWER: The specified slump range for concrete in the containment base mat was one to four inches, with a tolerance of plus or minus one inch. Slump is measured on the first truck of the placement and every fifty yards thereafter by QC personnel. A review of the base mat concrete placement reports shows that the average slump for all of the concrete in the base mat was 3.02 inches.
INTERROGATORY NO. 65-4(h). State if any voids were observed in the Harris base mat during or after concrete was poured in it.
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ANSWER: None of the areas of voids / honeycombs discussed in the answer to Interrogatory No. 65-1(h) were in the contain-ment building base mat.
INTERROGATORY NO. 65-4(i). Identify all voids so ob-served, stating how each was observed and when it was first observed.
ANSWER: Not applicable.
INTERROGATORY NO. 65-4(j). State all corrective action taken, if any, for each such void.
ANSWER: Not applicable.
INTERROGATORY NO. 65-5(a). State whether any concrete has ever been rejected at the Harris plant site and not re-used.
ANSWER: Yes. Concrete is tested to verify design requirements and if testing shows the concrete to be outside the design requirements it is rejected. That part rejected is not used in any permanent plant structure.
l INTERROGATORY NO. 65-5(b). State whether any concrete not meeting applicable standards has ever been poured in the base mat or safety related structures at Harris to Applicants' l
knowledge (includes contractors and employees' knowledge).
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! ANSWER: See answers to Interrogatory Nos. 65-5(c) and (d) l below.
OBJECTION: See objection to Interrogatory No. 65-1(a) as to structures other than the containment building.
INTERROGATORY No. 65-5(c). State the date and reason for each instance of rejection of concrete at Harris if the answer to (a) above is affirmative.
l ANSWER: Concrete is rejected for not meeting applicable l
L
e
- ranges for air content, slump, unit, weight, etc. and all such rejections are addressed on Discrepancy Reports, Batch Tickets (of which there are thousands) and QC test logs which are filed in plant records with volumes of other plant documents.
OBJECTION: Applicants object to performing the research and compilation sought as burdensome and oppressive. In addition, the interrogatory in part seeks information outside the scope of the contention since it is not limited to the containment building.
INTERROGATORY NO. 65-5(d). State whec any pour of concrete not meeting applicable standards was observed or noted, by whom, and when it was reported, at Harris.
ANSWER: Placement dates, locations and inspection personnel performing testing and placing inspections are shown on Concrete Test Reports, Batch Tickets, and Discrepancy Reports. See answer and objection to (c) above and answers to Interrogatory No. 65-1.
INTERROGATORY NO. 65-5(e). For each such pour or portion thereof, identify all corrective action taken, including analyses that Applicants contend would indicate the concrete is j able to perform what the sign of the plant requires it to in terms of strength, stability, holding rebar, etc, in place (e.g. trumplates and embeds), and when such correction or analysis was performed and by whom, and by whom it was then inspected or approved or both; if it has not been inspected or approved, so state.
ANSWER: When an out of specification condition was found to exist after some of the concrete had been placed, cylinders were made from the subject concrete. Concrete batched after l the "out of specification condition" was tested for the 1
f w
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)
I
! existing condition until it was corrected. All out of <.'
, (\
' specification conditions including !'placed concrete" are T; documented and evaluated by Engineering and recorded in !
, \' l i
discrepancy reports which are filed in records with other i permanent plant documents. See-answsrssto (c) and (d) above j
and answers to Interrogatory No. 65-1. Engineering evaluatton i of in-place concrete has' resolved all discrppancies.
i, OBJECTION: Applicants object to performing the research and compilation which would be necessary to provide the
, . , . e ..
information sought by each relevant pour. Such an effort would " gs require examination of roughly 1500 Deficiency and Dispositign ,-
Reports and 1900 Discrepancy Repobts, which address all aspects of the project and are not cata,logued by discipline or '
building. It would also require review of roughly 1800 civil i *
~
Non-Conformance-Reports, which are not catalogued in smaller ; - w 1 categories and therefore include civil activities other th 3n +
. , Mw concrete placement. .
I e e INTERROGATORY NO. 65-6. Define precisely th'e function (s)I'I Applicants mean, and the performance levels expected, with i respect to cach requirement'for strength, integrity, not i i cracking, etc which is required of base mats and containment ~sj s I
walls containing concrete, when they-refer in their interroga- .
tories on Eddleman 65 (first set) to "p'revent that structure *'
from performing its intended function". What does this phrase ,
mean precisely and in detail? If it means different things in the different Eddleman 65 interrogatories Applicants sent V l
l-31-83, please' define it for each such interrogatory,
- identifying to which' interrogatory each definition sapplies, i ANSWER: The containment structure, base mat and walls, provide pressure and temperature protection, biological
,m j N
(
I shielding, and m'iscile protection for the Nuclear Steam Supply s ,
System 2.The concrete wall's protect the inner liner plate from
\
internal pressures, external e'hvironmental effects and missile r
protection. ~. ,
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INTERROGATCRYNb.65-7. Dtete' concisely the NRC require-ments, rules, and guidancesfor'th'e function and properties and capabilities of base mats and pontfinments of nuclear power plants applicable to Harris at present, as Applicants under-stand same, identifying all relevant numerical and other properti,es required explicitly,or implicitly.
v ANSWER: SHNPP FSAR Section 3.8.1.2 identifies the codes, standards and 5pecifications (including NRC Regulatory Guides) bs applicableto'thhHerrisP,lankcontainmentandbasemat.
.. \ \ .
Additionally, dection 3. L.hf the ESAR discusses the conformance of Harris Plant structuraq important to_s3 fety to the NRC g . )
General Design Criteria (A'ppendix A 'ch10 t C.F.R. Part 50);
% \t containment design in particularlis sisgussed in Sections s 3.1.12 (GDC 16), 3.1.43 (GDC 50), and 3.1.44 (GDC 51).
Objections submitted by
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- j?
t* ' Thomas A. Baxter, P.C.
. Shaw, Pittman, Potts & Trowbridge i 1800 M Street, N.W.
l . $$h o' Washington, D.C. 20036
~
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4 (202) 822-1090 t
3 #
l Ns ,
Richard E., Jones Samantha Francis Flynn Carolina Power & Light Company P.O. Box 1551
\
Raleigh, North Carolina 27602
, ,< . . , . (919) 836-6517
< 4 Counsel for Applicants
~T s, Dated: May 12, 1983
\ \
,I s
%_- A- _
41-1 (c) (b) EXHIBIT 1 PIPE I! ANGER INSPECTOR DATE HIRED QUALIFICATION WHEN HIRED TESTING DATE & RESULTS ,
7/8/82 C. LOCKE 8/82 NDE - 3 yrs /8 months 7/17/82 PASSED LII VT, MT, PT, UT -
T. G. LOVE 2/7/83 7 months WELDER - 4 yrs 2/18/83 PASSED R. G. MAYS 12/7/82 Welding Inspection - 4 years 12/22/82 PASSED J. OGSBURY 2/15/83 WELDING INSP - 3 yrs /6 mo 2/22/83 PASSED M. A. PFOUTS 2/7/83 WELDING INSP - 1 yr/6 mo 2/18/83 PASSED WELDING INSP - 2 yrs /l m J. A. SMITH 6/21/82 7/19/82 PASSED WELD & VISUAL INSP- 4 yrs /4 m T. D. SMITH 11/1/82 OC MAN - 2 years 11/11/82 PASSED W. A. SOULT 2/22/83 W ER - 3 yea R. TAYLOR 6/8/82 VISUAL INSP - 1 yr/6 mo 6/29/82 PASSED A. L. TITTLE 5/18/82 VISUAL INSP - 6 years 6/3/82 PASSED 5
R. G. TOMLINSON 2
VISUAL INSP - 8 years 6/3/82 PASSED NDE (UT, MT, PT, ET) 9/16/82 PASSED E. E. VICK 4/5/82 1 yr/ 6 m 4/30/82 VT 4 ynnvn R. M. TOTTEN 12/7/82 VISUAL WELD INSP 12/20/82 PASSED VT LII - 4 yrs /6 mo a
41-1 (a) (b) EXIIIBIT 1 PIPE ilANGER INSPECTOR DATE IIIRED OtIALIFICATION WilEN llIRED TESTING DATE & RESULTS .
CWI C. F. WEAST 12/7/82 VT- 18 yrs / WELDING 12/22/82 PASSED MT - 2 yrs 2 yrs 5/76-8/77 - WELDING FOREMAN TOM F. ASHLEY 5/27/82 ACF INDUSTRIES 6/3/82 PASSED 6/72-3/76 - WELD FOREMAN MARATIION-LeTOURNEAU CO.
10/71-6/72-WELD FOREMAN I.TTTOM RTITP RYRTFMR 1/70-10/71-WELD SUPV.
OWENS-JOIST STEEL CO.
3/63-11/69-MELD FOPE!'^"
FOOD MACllINERY & CHEM.
ll/81-3/12/82-WELD INSP.
T"Pt'EY POI"T LIQUID PENETRANT TESTING HAL BOYLSTON 5/17/82 LEVEL II QA INSPECTOR 10/6/82 PASSED WELD INSPECTOR - NDE THOMAS B DANIEL 2/25/82 TECH. RT-MT 3/5/82 PASSED HAROLD F DILL 5/24/82 WELD INSP.-33 months PIPE FITTER - 42 months 6/9/82 PASSED PIPE WFf, DER 42 months FRED LOCKLEAR 7/12/82 f S AL ffSP.OFWELDS 7/12/82 PASSED GEORGE T. WEST 01 7/8/82 WELD INSPECTOR 7/17/82 PASSED MICHAEL ALLEN MECHANICAL INSPECTOR MILLER 6/21/82 LEVEL II 7/6/82 PASSED DAVID L. ROGERS 3/30/82 flDE & WELD INSPECTOR 4/5/82 PASSED Welder 3 years DON A. SANDS 2/2/81 V sug Ingg 2 gears 3/5/81 PASSED
41-1 (a) (b) EXIIIBIT 1 PIPE IIANGER INSPECTOR DATE IIIRED QUALIFICATION WIIEN llIRED TESTING DATE & RESULTS ,
JOHN SCOATES 2/8/82 PT, RT, MT- Level II 8 yrs 2/15/82 PASSED LEVEL II MECH, WELD, DOUGLAS SUDDUTil 3/23/82 CIVIL, COATINGS INSP. 4/1/82 PASSED C. A. Rif0 DES 2/23/81 Piperitter 1 year 6/23/81 PASSED 1/9/80 PASSED G. G. TINGEN 2/23/81 WELDER - 3 yrs /3 months 3/80 (cert. VTII)
H. R. VEGA 5/24/82 WELDER - 3 yrs /8 months 7/19/82 FAILED 8/11/82 PASSED VISUAL INSP 1 yr/3 mo 9/9/82 FAILED W. T. BRUNI 5/17/82 LII-Py,ypJ6gf- 9/16/82 PASSED WELDER - 5 yrs /7 months 12/16/82 PASSED WELDING INSP - 6 months B. R. BRYANT 11/29/82 D. O. COOK '!/9/82 8/82 VISUAL INSP. - 4 yr/l mo 7/17/82 PASSED S. L. COTHAM 12/10/80 j WEgDjtgj{NSPEgfION Ig/}g/gg((((fl VISUAL INSP-1 yr/10 mo 12/21/82 PASSED K. W. DANIELS 12/7/82 LII-RT, PT, MT-4 yr/9 mo VISUAL INSP-3 yrs /4 mo 2/28/83 PASSED T. G. DAVIS 2/7/83 LII-PT, MT, RT-3 yrs /7 mo VISUAL INSP-ll yrs /6 mo C. GOINS 5/20/82 LII-MT, PT, RT-11 yrs /6 mo 6/3/82 PASSED VISUAL INSP-9 months J. G. JACKSON 12/1/82 LII-PT, MT, RT-1 yr/3 mo 12/29/82 PASSED
41-1 (a) (b) EXHIBIT 1 PIPE HANGER INSPECTOR DATE HIRED QUALIFICATION WHEN HIRED TESTING DATE & RESULTS ,
VISUAL INSP-3 yrs D. F. JARVIS 2/8/82 LII-MT, PT-6 mo 2/15/82 PASSED WELDER-1 yr/11 mn VISUAL INSP.-2 yrs .
M. KING 4/7/82 LI-PT, MT, RT-1 yr 4/23/82 PASSED WELDER-4 yrs /5.mo R. GARRISON 2/21/83 LII-VT, PT-2 months 3/3/83 PASSED DOB STEELE 2/8/82 QC INSPECTOR LEVEL II 2/15/82 PASSED DONALD GARY CRISPIN0 6/8/81 Level II Inspector 8 1/2 yrs. 6/22/81 PASSED JAMES RICHARD LEVEL II RT, PT, UT, FOUSHEE 6/14/82 MT CWI-10 yrs /7 mo 7/6/82 PASSED VTSHAI, TMRP CLARENCE GALLAGHER 3/5/79 Welding Inspection 6 months 6/13/79 PASSED ALAN BRUCE INSPECTOR - ROCKWELL INT.
GILES 6/19/78 2 yrs /1 mo 8/15/78 PASSED DAVID J.
HOLLER 9/11/78 NO PREVIOUS INSPECTION EXP. 10/17/80 PASSED WELDINSP.@gRIpygIgg y
JON JOHANSON 9/2/78 LII-VT @ SOUTHWEST 2 yrs /6 mo 10/18/78 PASSED JUDITH C. 5/7/80 (VTII) PASSED McDONNELL 1/14/80 WELDER DCC-5 months 4/17/80 PASSED STEVE W.
MOUNTCASTLE 6/2/78 NO PREVIOUS INSPECTION EXP. 2/17/81 PASSED JAMES ROOT 9/29/80 WELDING INSP. 4 years 10/7/80 PASSED a
41-1 (a) (b) EXIIIBIT 1 PIPE IIANGER TESTING DATE & RESULTS :
INSPECTOR DATE iiIRED OUALIFICATION WilEN IIIRED W. P. RUSSELL INSPECTOR - 6 months 1/19/79 (VTII)
(Bill) 9/25/78 WELDING - 4 yrs /l month 11/8/78 PASSED 2/26/79 (VTII)
JOHN R. SilIRAH 2/26/79 WELDING INSPECTOR 11 months 3/15/79 PASSED INSPECTOR - 9 months KEN B. STANLEY 9/8/81 WELDING - 10 months 11/13/81 PASSED A. G. WADE 8/25/80 Welding Inspections 10 years 9/16/80 (VTII)
T. J. ANGELINA 8/30/82 INSPECTOR - 9 months 11/9/82 PASSED D. M. BROWN 4/13/82 WELDER - 2 yrs /6 no 8/6/82 PASSED J. L. BUCKNER 7/6/82 WELDER - 4 yrs /8 mo 6/8/82 PASSED (STRU)
WELDER - 9 months INSP. - 4 yrs /11 mo 11/9/82 PASSED C. M. CASE 10/25/82 10/12/81 orig 11/2/81 PASSED G. A. DeBARROS 11/3/82 rehiro WELDING INSP. - 1 yr/9 mo 11/18/82 PASSED S. M. DOUGLAS 6/7/82 NO PREVIOUS INSPECTION EXP. 9/22/82 PASSED K. M. KENYON 4/13/82 WELDER - 11 yrs /5 mo 5/24/82 PASSED A. L. LEONARD 12/7/82 INSPECTOR - 18 years 12/20/82 PASSED R. C. LUCAS 6/1/82 WELDER - 1 yr 6/29/82 PASSED
41-1 (a) (b) EXHIBIT 1 PIPE HANGER INSPECTOR DATE HIRED QUALIFICATION WHEN HIRED TESTING DATE & RESULTS
}
J. M. MARTIN 6/28/82 WELDER - 2 yrs /3 mo 7/26/82 PASSED W. MARTIN 3/29/82 WELDER - 5 yrs /2 mo 5/24/82 PASSED 5/2/79 PASSED (STRU)
E. W. MERCER 2/19/79 RT INSP. - 2 years 3/19/79 PASSED (VTII)
H. L. O'BRIANT 9/20/82 WELDER - 1 year 11/2/82 PASSED W. H. PERE 5/14/79 NO PREVIOUS INSPECTION EXP. 2/17/81 PASSED 35 years welding R. E. CAIN 12/15/80 inspection & welding 1/6/81 PASSED J. C. KING 2/18/80 Welding Inspection 4 years 4/9/80 PASSED G. DeWEESE 12/1/30 Visual Inspection 12/15/80 PASSED 7 years RT, PT LEVEL II 1/24/80 PASSED C. L. GODWIN JTt. 1/14/80 MT, UT LEVEL I B. R. PORTER 12/15/80 Visual Inspection 2 years 12/31/80 PASSED S. M. FREEMAN 3/2/81 Visual Inspection 4 mo. 3/12/81 PASSED MT, PT, RT-Lev II 2 years J. A. SHUMATE 6/21/82 QC Inspector 2 yrs /5 mo. 7/19/82 PASSED
,e se o ABBREVIATIONS FOR EXHIBIT 1
' ABBREVIATION MEANING NDE Nondestructive Examination LII Level II VT Visual Inspection MT Magnetic Particle Examination PT Liquid Penetrant Examination UT Ultrasonic Examination RT Radiographic Examination ET Eddy Current Examination CWI Certified Weld Inspector (American Welding Society)
STRU Structural l
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EXHIBIT 2 (Interrogatory 41-4(h))
Metallurgy / Welding Engineering Mechanical Engineering Barbara Morris Chase Thomas Fasih Shaikh Ken Fuller Ray Hanford Chris Dell Marty Miller Larry Coble David Timberlake Paul Howard Wrightson Lewis William Hartley Pat Chriscoe Gary Pollard Tim Underwood Phil Williams Mike Taggart Van Davis Johnny Jackson Jim Kirby Ed Bullard Rodney Turner Mark Stearly Ed Willett Alex Fuller Karl Lehman Mark Fulcher Bruce Deese Neal Cornwell Rick Fichera Wayne Harris Tom French l Wallace Ponder l
l l
. . . . 1 UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _
~
In the Mattar of )
) ,
CAROLINA POWER & LIGHT COMPANY -
)
and NORTH CAROLINA EASTERN )
DOCKET NOS. 50-400 OL MUNICIPAL POWER AGENCY ) -
50-401 OL
)
(Shearon Harris Nuclear Power ).
Plant, Units 1 and 2) )
AFFIDAVIT __OF ROLAND M. PARSONS County of Wake
) ~
) as:
State of North Carolina ) -
Roland M. Parsons, being duly sworn according to lawi deposes '
and says that he is Project ~ General Manager - Shearon Harris Nuclear Power Plant of Carolina Power & Light Company; that the answers to Interrogatories on Contentions 41 and 65 contained in
" Applicants' Responses to Wella Eddleman's General Interrogatories and Interrogatories on Contentions 41 and 65 to App 11canta carolina Power & Light Company, el al. (First Set)" are true and correct to the beist of his information, knowledge and belief; and that the l
I cources of his information are officers, employaes, ac[ents and contractors of Carolina Power & Light Company. '
l = ~>>7 ' =- D ROLAND M. PARS'ONS Sworn to and subscribed before me thia /#A day of May,1983, s h & N k &--
Notary Public ~
l My commission expires _ d 9- Jo - ?6 '
l 9
- 1
, , _ --s --t-
May 13, 1983
.,v>
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION [-
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~
i In the Matter of ) 7-
)
s' CAROLINA POWER & LIGHT COMPANY ) .c AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
CERTIFICATION OF COUNSEL I hereby certify that I have made the following efforts to resolve Applicants' objections to certain of Wells Eddle-mans' Interrogatories (First Set) and Request for Production of Documents, dated March 21, 1983, on Contentions 41 and 65.
I spoke with Mr. Eddleman by telephone on May 11, 1983, to discuss the substance and nature of Applicants' objections.
Since Mr. Eddleman had not yet seen the answers being provided and the description of the documents Applicants agreed to produce, he could not readily judge the effect of the objections i
l I described and the discussion from both his perspective and mine was often difficult and not useful.
In those instances where the objections are based on grounds of irrelevancy to the contention and/or the proceeding, I explained Applicants' reasoning and Mr. Eddleman expressed his disagreement with it.
- Where Applicants' objections were based on the facts
. that the information was not readily accessible in the form Sb3 -
.. -4 requested, and that the research and compilation required to answer the interrogatory literally would be burdensome and oppressive, I also described the effort Applicants made to provide responsive information. In each instange Mr.
Eddleman took the position that he was entitled to any relevant information in Applicants' possession.
I described to Mr. Eddleman the situations where even the option of producing records for inspection, in lieu of answering the interrogatory, was burdensome and oppressive because of the effort which would be required to search for, identify and extract the voluminous relevant documentation from CP&L files, and because removal of some documents from their files would cause a disruption in project work, as would Mr. Eddleman's presence if he were to attempt to search out documents himself from CP&L files. Again, there was no agreement reached on the merits of Applicants' objections.
Thomas A. Baxter , P .'C .
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1090 Counsel for Applicants Dated: May 13, 1983
tslIL
.y _N
[ pay;13,'1983 I
. H '
c:
UNITED STA[ESTOF' AMERICA NUCLEAR REGULATORY COMMISSION
-X BEFORE THE ATOMIC SAFETY AND-LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) DOCKET NOS. 5 0--4 0 0 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 41 and 65 to Applicants Carolina Pcwer & Light Company, et al. (First Set)", " Applicants' Response to Wells Eddleman's Request for Production of Documents (Contentions 41 and 65)", and " Certification of Counsel" were served this 13th day of May, 1983 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.
Thomas A. Baxter, P.C.
DATED: May 13, 1983 1 So3
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Commission 307 Granville Road Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atomic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Commission Post Office Box 12643 Washington, D.C. 20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S.' Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C. 20555 Charles A, Barth, Esquire Mr. Wells Eddleman 718-A Iredell Street Myron Karman, Esquire Durham, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Commis~sion Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Docketing and Service Section Carolina Power & Light Company Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C. 20555 Dr. Phyllis Lotchin
'Mr. Daniel F. Read, President 108 Bridle Run Chapel Hill Anti-Nuclear Group Effort Chapel Hill, North Carolina 27514 Post Office Box 524 Chapel Hill, North Carolina 27514 Deborah Greenblatt, Esquire 1634 Crest Road Raleigh, North Carolina 27606 w - -
/
Service List Page Two Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Karen E. Long, Esquire Public Staff - NCUC Post Office Box 991 Raleigh, North Carolina 27602 i
r e
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