ML20028C880
| ML20028C880 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/10/1983 |
| From: | Guild R GUILD, R., PALMETTO ALLIANCE |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8301140258 | |
| Download: ML20028C880 (9) | |
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e Ok UNITED STATES OF AMERICA og3 MN N N g NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD,7 g g
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In the Matter of
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DUKE POWER COMPANY, et al.
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Docket Nos. 50-413
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50-414 (Catawba' Nuclear Station,
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Units 1 and 2)
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January 10,-1983 PALMETTO ALLIANCE INTERROGATORIES AND REQUESTS TO PRODUCE TO NRC STAFF Pursuant to 10 CFR Sections 2.720 (h) (2) (ii), 2.740b, 2.741 and 2.744, and the Board's Order of December 22, 1982, at p. 17, Palmetto Alliance (Intervenor) hereby serves its Interrogatories and Requests to Produce upon the NRC Regulatory Staff.
These interrogatories involve Palnetto Alliance Contentions 8 and 27.
Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known I
to the Regulatory Staff, its employees, agents, advisors or counsel.
Each request to produce applies to pertinent documents which are in the possession, custody or control of the Staff, its employees, agents, advisors or counsel.
In answering each interrogatory.and in responding to each request, please recite the interrogatory or request preceding each answer or' response.
Also, please identify the person providing each answer or response and state the educa-tional and professional background of each.
These interrogatories and requests shall be continuing in
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Thus, any time information is obtained which renders any 0
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previous response incorrect or indicates that a response was in-correct when made, a supplement should be made to the previous response to the appropriate interroaatory or request to produce.
Supplements should be made to the responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony.
Intervenor is particularly interested in the names and areas of expertise of witnesses, if any.
Each identification of such witnesses is necessary if Intervenor is to be afforded adequate time to depose them.
The term " documents" shall include any writings, drawinas, graphs, charts, photooraphs, and other data compilations from which information can be obtained.
We request that at a date or dates to be agreed upon, you make available for inspection and copying, all documents subject to the requests set forth below.
REQUESTS TO PRODUCE Pursuant to 10 CFR Sections 2.741 and 2.744, Intervenor reouests you to make available for inspection and copying at a time and lo-N*
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cation to be designated, any and all documents, of whatsoever de-scription, identified in the responses to these interrogatorics,
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below; including, but not limited to:
(1) any written record of any oral communication between or amor.4 NRC Staff, their advisors, consultants, agents, attorneys, and/or any other persons, including but not limited to -.
i the Applicants, the Intervenors, and their advisors, consultants, agents, attorneys and/or i
any other persons; and (2) any documents, correspondence, letters, memo-randum, notes, diagrams, reports, charts, photo-graphs, or any other writing or whatsoever description, including but not limited to work l
papers, prior drafts, and notes of meetings.
If you maintain some documents should not be made available for i
inspection, you should specify the documents and explain why such are not being made available.
This request extends to any such i
documents described above, in the possession of Staff end its advisors, consultants, agents, or attorneys.
INTERROGATORIES i
l Pursuant to 10 CFR Sections 2.740b, 2.720 (h) (2) (ii), Inter-l venor requests the NRC Staff by and through its attorney, to answer separately and fully in writing under oath or affirmation, by persons having knowledge of the information requested, the following interrogatories.
CONTENTION 8 1.
Describe in detail the steps taken to upgrade reactor oper-ator training programs as a result of the TMI Action Plan, L.
j as referred to in your earlier answer to Interrogatory No. 4 "i
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Include specifically a description of the training for simu-i t
lated accident conditions and the use of simulator exercises to observe and evaluate job performance. -
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i 2.
Identify and describe any studies, reports, documents or evidence known to the NRC Staff reflecting a relationship between actual hands-on experience by reactor operators and safe operation of' commercial power reactors such as Catawba l
under both normal and accident conditions.
t 3.
Identify and describe all licensee Event Reports, accidents, abnormal events, or other occurences at operating nuclear reactors known to the NRC Staff where operator error, lack i
of skill or lack of experience contributed to an actual or potential threat to public health or safety.
4.
Identify and describe in detail any evaluation, critique, criticism or commendation known to the NRC Staff of reactor operator qualification, training and experience at Duke Power owned or operated facilities, including any corrective action recommended and implemented in respose by Duke.
5.
Identify and describe in detail the status of the NRC review of Applicants' operator training program which is to be re-flected in the yet unpublished SER.
Include a complete descrip-tion of any and all documents, reports, correspondence, tests,
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studies or other communication known to the NRC Staff which reflects the training program or its review.
6.
Explain fully any factual basis known to NRC Staff to support the statements contained in your earlier answer to Interroga-tory No. 14 regarding operator training through simulator l
experience and during plant start-up testing as sufficient to e
provide qualification for safe plant operation during normal and accident conditions.
7.
Describe in detail any information known to the NRC Staff re-garding the charac'teristics of the national and regional pool of military and commercial nuclear reactor operators with hands-on experience during actual operations including numbers of persons, types and degre'es of experience, salary levels, geographic location, availability, and present employment.
8.
Describe in detail any simulator exercises that are designed to test manual dexterity and mature judgment which are a part of the reactor operator training program.
9.
Describe in detail any NRC evaluation of Applicants' training personnel and materials either underway or to be performed prior to licensing.
10.
What review will be conducted by NRC Staff of the individual operator evaluations and test results?
Please describe in
- detail, 11.
Are independent evaluators not employed by Applicants used to test and evaluate persons undergoing reactor operator training? ',
Please explain.
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12.
When will Applicants supply a complete list of control room l
personnel to NRC Staff?
13.
Are the specific details of the Applicants' emergency response training for reactor operators now available?
Please identify., -., - _ _ _ -
CONTENTION 27 1.
Describe in detial the information known to the NRC Staff concerning installed real-time monitoring systems at the i
facilities shown in Table VIII, page 47 of NUREG/CR-2644, or at any other facilities, including operating experience and effectiveness, costs of installation and operation, l
accuracy and reliability, benefits and detriments, types and description of equipment and operating procedures and regu-latory or legal basis for use at each facility.
2.
Describe in detail the radiation monitoring equipment and procedures employed both before and after the March 1979 accident at Three Mile Island Unit 2 including specifically a detailed description of the personnel, plans, equipment, procedures, results and analysis of post accident offsite radiation releases at TMI-2, and the protective actions taken in response to such monitoring, if any.
3.
Describe in detail any information known to the NRC Staff regarding the offsite radiation monitoring equipment, pro-I cedures and experience at Duke Power Company's other operatina
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facilities, including the cost of installation and operation, accuracy and reliability, benefits and detriments, evaluation
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and criticism, upgrading, alteration or replacement.
4.
Describe in detail any information known to the NRC Staff 1
regarding Duke Power Company's plans to use field monitoring teams with real-time monitoring equipment during accident conditions including qualification and number of personnel, I
means of transportation, types, costs, and specifications of equipment and effectiveness. -
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5.
Describe in detail the characteristics of an offsite real-time dose measurement system for emergency situations which, in the judgment of the NRC Staff, would provide sufficiently reliable technical information to be of use in emergency decision making, including the type and number of stations, the placement of stations, costs of installation and operation, and operational results.
6.
Describe in detail any information known to the NRC Staff regarding the release by Duke Power Company of radioactive water into Lake Hartwell from its Oconee Nuclear Station in 1977, including a description and identification of any documents reflecting the cause of the release, the type, performance and cost-of installation and operation of on-site and off-site radiation monitoring equipment and pro-cedures employed there, and the compliance or non-compliance by Duke with Commission rules and policy in actions before and after the release,
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Robert Guild \\w/
Attorney for Palmetto Alliance P.O. Box 12097 Charleston, S.C.
29412 l
803/795-8708 l
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
DUKE POWER COMPANY, et al.
)
Docket Nos. 50-413
)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Palmetto Alliance Interroga-tories and Requests to Produce to NRC Staff" in the above captioned matters, have been served upon the following by deposit in the United States mail this 10th day of January, 1983.
James L. Kelley, Chairman George E. Johnson, Esq.
Atomic Safety and Licensing Office of the Executive Legal
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1 Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory "i
Commission commission s
Washington, D.C.
20555 Washington, D.C.
20555 4
Dr. A. Dixon Callihan William L. Porter, Esq.
Union Carbide Corporation Albert V. Carr, Jr., Esq.
P.O. Box Y Ellen T. Ruff, Esq..
Oak Ridge, Tennessee 37830 Duke Power Company P.O. Box 33189 Dr. Richard R. Foster Charlotte, North Carolina 28242 P.O. Box 4263 Sunriver, Oregon 97701 Richard P. Wilson, Esq.
Assistant Attorney General Chairman State of South Carolina Atomic Safety and Licensing P.O. Box 11549 Board Panel Columbia, South Carolina 29211 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Chairman Jesse L. Riley Atomic Safety and Licensing 854 Henley Place Appeal Board Charlotte, North Carolina 28207 U.S. Nuclear Regulatory Commission
/ Scott Stucky Washinoton, D.C.
20555 Docketing and Service Station U.S. Nuclear Regulatory Henry A. Presler Commission Charlotte-Mecklenbura Washington, D.C.
20555 Environmental Coalition 943 Henley Place Charlotte, North Carolina 28207 J. Michael McGarry, III, Esq.
Debevoise & Liberman 1200 Seventeenth St., N.W.
Washington, D.C.
20036
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