ML20032D919
| ML20032D919 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/10/1981 |
| From: | Ridgway D SHAW, PITTMAN, POTTS & TROWBRIDGE, WISCONSIN ELECTRIC POWER CO. |
| To: | WISCONSIN'S ENVIRONMENTAL DECADE |
| References | |
| NUDOCS 8111180398 | |
| Download: ML20032D919 (21) | |
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UNITED STATES OF AMERICA
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Before the Atomic Safety and Licensing Board e'
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In the Matter of
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WISCONSIN ELECTRIC POWER COMPANY
)
Docket Nos. 50-266
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50-301 (Point Beach Nuclear Plant,
)
(OL Amendment)
-Units 1 and 2) s LICENSEE'S FIRST SET OF INTERRCGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR DECADE RELATIVE TO FULL SCALE SLEEVING PROGRAM These Interrogatories and Request for Production of Documents are filed by the Wisconsin Electric Power Company
(" Licensee") pursuant to the Board's October 13, 1981 Memorandum and Order Concerning The Admission of A Party and Its Contentions (" Memorandum and Order Concerning Admission")
and the Commission's Rules of Practice.
They are directed to Intervenor Wisconsin's Environmental Decade, Inc. (" Decade")
cnd pertain to the issues raised by Decade in its Contentions 3,
4, 5 and 7, as those issues relate to Licensee's July 2, 1981 amendment request, which would authorize full-scale sleeving of steam generator tubes at Point Beach Units 1 and 2.
The interrogatories submitted herein are filed pursuant to 10 C.F.R.
S 2.740b which requires that the phDh 8111180398 811110 PDR ADOCK 05000266 QQ \\
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interrogatories be answered separately and fully in writing under oath or affirmation, within 14 days after service.
The interrogatories are intended to be continuing in nature and the answers must be immediately supplemented or amended, as appropriate, should Decade obtain any new or differing informa-tion responsive to the interrogatories.
For purpcses of these interrogatories, the term
" document (s)" means all writings and records of every type in the possession, control or custody of Decade or Decade's attorney (s), including, but not limited to, memoranda, corre-spondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings or recordings of any kind.
" Document (s)" shall also mean copies of documents even though the originalt thereof tre not is, the possession, custody, or control of Decade.
For purposes of these interrogatories, a document shall be deemed to be within the " control" of Decade or Decade's attorney (s) if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document cr copy thereof from any person or public or private entity having physical possession thereof.
When identification of a document is requested, briefly describe the documents; i.e.,
letter, memorandum, book, pamphlet, etc., and state the following information as appli-cable to the particular document: name, title, number, author, -
date of publication and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the document.
The Request for Production of Documents is filed pursuant to 10 CFR S 2.741, which requires that Decade produce and either furnish copies of or permit Licensee to inspect and copy any documents responsive to the request and which are in the possession, custody or control of Decade.
The Request for Production of Documents is also continuing in nature and Decade must produce immediately any additional documents it obtains which are responsive to the Request.
INTERROGATORIES Contention 3 (Proprietary Heating Process) 3-1.
State in detail the factual bases for the allegation i
that the proprietary heating process will weaken the integrity of the original tube in laboratory conditions.
The purpose of this interrogatory is to ascertain the factual bases for each element of Contention 3 so that Licensee can adequately prepare its response to the contention.
3-2.
Identify with specificity the precise area in which, and quantify the extent to which, you contend the original tube will be weakened in the laboratory as a result of the proprie-tary heating process. See purpose statement for Interrogatory 3-1. -
State in detail the factual bases for the allegation 3-3.
that the proprietary heating process will weaken the integrity of the original tube in the field.
See purpose statement'for Interrogatory 3-1.
3-4.
Identify with specificity the precise area in which, and quantify the extent to which, you contend the original tube will be weakened in the field as a result of the proprietary heating process.
See purpose statement for Interrogatory 3-1.
3-5.
Do you contend that weakening of the original tube in the field as a result of the proprietary heating process will exceed weakening experienced in the laboratory?
If so, state in detail the factual bases for that position.
See purpose statement for Interrogatory 3-1.
This interrogatory is also intended to clarify Contention 3.
3-6.
State in detail the factual bases for the allegation that the proprietary heating process may " fatally compromise" the integrity of the original tube, in the field.
See purpose statement for Interrogatory 3-1.
3-7.
Define the term " fatally compromise" as that term is used in Contention 3.
This interroc tory is intended to clarify Contention 3.
3-8.
State in detail the factual bases for the allegation that the proprietary heating process "may lead to a circumfer-ential rupture" of the original tube during "various operating and/or accident conditions."
See purpose statement f6r Interrogatory 3-1.. - - _
Specify each of the "various operating and/or 3-9.
accident conditions" to which Contention 3 refers.
See purpose statement for Interrogatory 3-7.
3-10.
Identify and quantify the types of forces and stresses to be experienced by the sleeved tubes in each of the "various operating and/or accident conditions" specified in response to Interrogatory 3-9, and explain how those forces and stresses will cause a "circumferential rupture."
See purpose statement for Interrogatory 3-5.
3-11.
Do you contend that the sleeve / tube combination j
(the new primary / secondary pressure boundary) will not meet all applicable criteria of the ASME Code?
If so, state in detail l
the factual bases for that position, including a specific identification of each criterion which allegedly will not be net.
If not, explain in detail what you consider to be the practical safety significance of any weakening of the original tube alone.
See purpose statement for Interrogatory 3-5.
3-12.
Do you contend that the sleeve / tube combination will be weaker than the original tube?
If so, state in detail the factual bases for that position.
If not, explain in detail what you consider to be the practical safety significance of any weakening of the original tube alone. See purpose statement for Interrogatory 3-5.
3-13.
For each response to Interrogatories 3-1 through 3-6, 3-8, 3-10, 3-11, and 3-12: -
4 (a)
Identify all documents, including all relevant page citations, on which you rely to support each of your claims; (b)
State the name, present or last known address, and present or 'last known employer of each person known to you
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to have first-hand knowledge of the factual bases for each of your claims; and (c)
State the name of each person you intend to call as a witness to support each claim.
.The purpose of this interrogatory is to identify persons knowledgeable about Contention 3 for possible future discovery requests, to clarify the scope of Contention 3, and to ascertain the factual bases which support each element of Contention 3 so that Licensee may adequately prepare its response to the contention.
3-14.
For each person identified in response to Interrogatory 3-13(c):
(a)
State the address, title, employer and educa-tional and professional qualifications (including a complete list of publications) of each such person; (b)
State the precise subject matter on which each such person is expected to testify; (c)
State the substance of the facts and opinions as to which each such person is expected to testify; and (d)
State a summary of the grounds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions.
See purpose statement for Interrogatory 3-13.
3-15.
Identify all documents in your possession, custody or control (including all relevant page citations) pertaining to the subject matter of Contention 3.
See purpose statement for Interrogatory 3-5.
3-16.
Identify all documents (including all relevant page citations) which you intend to offer as exhibits during this proceeding to support Contention 3, or which you intend to use during your cross-examination of witnesses presented by Licensee and/or the Staff on Contention 3.
See purpose statement for Interrogatory 3-5.
Contention 4 (Environment in Annulus Between Tube and Sleeve) 4-1.
State in detail the factual bases for the allegation that the sleeving process will give rise to an " unexpectedly corrosive environment."
The purpose of this Interrogatory is to ascertain the factual bases for each element of Contention 4 so that Licensee can adequately prepare its response to the contention.
4-2.
Describe in detail the phenomenon by which you contend an " unexpectedly corrosive environment" will be created in the annulus between the tube and the sleeve.
See purpose statement for Interrogatory 4-1.
4-3.
Describe in detail the nature and extent of the corrosive environment which you contend will be created in the annulus between the tube and the sleeve.
See purpose statement for Interrogatory 4-1.
4-4.
Do you contend that the environment in the annulus between the tube and the sleeve may be more corrosive than the environment which the original tube experienced?
If so, state in detail the factual bases for that position.
See purpose statement for Interrogatory 4-1.
This interrogatory is also intended to clarify Contention 4 4-5.
Do you dispute that the sleeves are more corrosion-resistant than the tubes?
If so, state in detail the factual bases for your position.
See purpose statement for Interrogatory 4-4.
4-6.
Do you contend that the sleeves will be insuffi-ciently resistant to the " unexpectedly corrosive environment" which you contend may be created in the annulus between the tube and the sleeve?
If so, state in detail the factual bases for your position. See purpose statement for Interrogatory 4-4.
4-7.
Explain in detail what you consider to be the practical safety significance of the " unexpectedly corrosive environment" which you assert will be created in the annulus between the tube and the sleeve.
See purpose statement for Interrogatory 4-4.
4-8.
For each response to Interrogatories 4-1 through 4-7:
(a)
Identify all documents, including all relevant page citations, on which you rely to support each of your l
claims; (b)
State the name, present or last known address, and present or last known employer of each person known to you. _...
to have first-hand knowledge of the factual bases for each of your claims; and (c)
State the name of each person you intend t. call as a witness to support each claim.
The purpose of this interrogatory is to identify persons knowledgeable about Contention 4 for possible future discovery requests, to clarify the scope of Contention 4, and to ascertain the factual bases which support each element of Contention 4 so that Licensee may adequately prepare its response to the contention.
4-9.
For each person identified in response to Interrogatory 4-8(c):
(a)
State the address, title, employer and educa-tional and professional qualifications (including a complete list of publications) of each such person; (b)
State the precise subject matter on which each such person is expected to testify; (c)
State the substance of the facts and opinions as to which each such person is expected to testify; and (d)
State a summary of the grounds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions.
See purpose statement for Interrogatory 4-8.
i 4-10.
Identify all documents in your possession, custody or control (including all relevant page citations) pertaining to the subject matter of Contention 4.
See purpose statement for Interrogatory 4-4.
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4-11.
Identify all documents (including all relevant page citations) which you intend to offer as exhibits during this proceeding to support Contention 4, or which you intend to use during your cross-examination of witnesses presented by Licensee and/or the Staff on Contention 4.
See purpose state-ment for Interrogatory 4-4.
Contention 5 (Eddy Current Testing) 5-1.
State in detail the factual bases for the allegation that "[t]he presence of the sleeve will make the interpretation of eddy current test results extremely difficult."
The purpose of this interrogatory is to ascertain the factual bases for each element of Contention 5 so that Licensee can adequately prepare its response to the contention.
5-2.
Identify with specificity the precise area of the sleeved tube at which you assert there will be~ decreased sensitivity in detecting degradation by eddy current testing.
See purpose statement for Interrogatory 5-1.
This Interrogatory is also intended to clarify Contention 5.
5-3.
Do you contend that significant degradation will occur in the areas of the sleeved tube at which you assert there will be decreased sensitivity in detecting degradation by eddy current testing?
If so, state in detail the factual bases for your position.
See purpose statement for Interrogatory 5-2.
5-4.
Do you contend that significant degradation occurring in areas of the sleeved tube at which you assert there will be decreased sensitivity in detecting degradation by eddy current testing will go undetected?
If so, state in detail the factual bases for your position.
See purpose statement for Interrogatory 5-2.
5-5.
State in detail the factual bases for the allegation that tubes with undetected degradation will " rupture during a loss of coolant accident."
See purpose statement for Interrogatory 5-1.
5-6.
For each response to Interrogatories 5-1 through 5-5:
(a)
Identify all documents, including all relevant page citations, on which you rely to support each of your claims; (b)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each of your claims; and (c)
State the name of each person you intend to call as a witness to support each claim.
The purpose of this interrogatory is to identify persons knowledgeable about Contention 5 for possible future discovery requests, to clarify the scope of Contention 5, and to ascertain the factual bases which support each element of Contention 5 so that Licensee may adequately prepare its response to the contention.
5-7.
For each person identified in response to Interrogatory 5-6(c):
(a)
State the address, title, employer and educa-tional and professiona.'. qualifications (including a complete list of publications) of each such person; (b)
State the precise subject matter on which each such person is expected to testify; (c)
State the substance of the facts and opinions as to which each such person is expected to testify; and (d)
State a summary of the grounds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions.
See purpose statement for Interrogatory 5-6.
5-8.
Identify all documents in your possession, custody or control (including all relevant page citations) pertaining to the subject matter of Contention 5.
See purpose statement for Interrogatory 5-2.
5-9.
Identify all documents (including all relevant page citations) which you intend to offer as exhibits during this proceeding to support. Contention 5, or which you intend to use during your cross-examination of witnesses presented by Licensee and/or the Staff on Contention 5.
See purpose statement for Interrogatory 5-2.
Contention 7 (Training / Quality Assurance) 7-1.
State in detail the factual bases for the allegation that " untrained and transient ' jumpers'" will be employed as part of the full scale sleeving program "to perform the bulk of l l
the work which quality may deteriorate as a consequence."
The purpose of'this interrogatory is to ascertain the factual bases for each element of Contention 7 so that Licensee can ade-quately prepare its response to the contention.
7-2.
Identify with specificity all reasons why you contend the employment of channel head workers may lead to a deterioration in the quality of work performed as part of the full scale sleeving program.
See purpose statement for Interrogatory 7-1.
This interrogatory is also intended to clarify Contention 7.
7-3.
Describe in detail all deficiencies which you assert to exist in the training of channel head workers.
See purpose statement for Interrogatory 7-2.
7-4.
Describe in detail all deficiencies which you assert to exist in the quality assurance program for the full scale sleeving program such that errors or omissions by channel head workers will go undetected.
See purpose statement for state-ment for Interrogatoy 7-2.
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7-5.
Identify with specificity all tasks assigned to channel nead workers which you assert may not be performed or may not be correctly performed, including -- but not limited to
-- an explanation of each error or omission which you assert may occur, an explanation of why that error or omission will not be detected by quality assurance controls, and an explana-I tion of the safety significance of each such error or omission should it go undetected.
See purpose statement for i
Interrogatory 7-2.
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7-6.
For each response to Interrogatories 7-1 through 7-5:
(a)
Identify all documents, including all relevant page citations, on which you rely to support each of your claims; (b)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual bases for each of your claims; and (c)
State the name of each person you intend to call as a witness to support each claim.
The purpose of this interrogatory is to identify persons knowledgeable about Contention 7 for possible future discovery requests, to clarify the scope of Contention 7, and to ascertain the factual bases which support each element of Contentien 7 so that Licensee may adequately prepare its response to the contention.
7-7.
For each person identified in response to Interrogatory 7-6(c):
(a)
State the address, title, employer and educa-tional professional qualifications (including a complete list of publications) of each such person; (b)
State the precise subject matter on which each such person is expected to testify; i
(c)
State the substance of the facts and opinions as to which each such person is expected to testify; and _.. _ - -. _ _ -.
(d)
State a summary of the grcunds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions.
See purpose statement for Interrogatory 7-6.
7-8.
Identify-all documents in your possession, custody or control (including all relevant page citations) pertaining to the subject matter of Contention 7.
See purpose statement for Interrogatory 7-2.
7-9.
Identify all documents (including all relevant page citations) which you intend to offer as exhibits during this proceeding to support Contention 7, or which you intend to use during your cross-examination of witnesses presented by Licensee and/or the Staff on Contention 7.
See purpose statement for Interrogat3ry 7-2.
General Interrogatories 0-1.
State the name, title, employer and educational and professional qualifications (including a complete list of l
publications) of each person you intend to call as a witness in this proceeding who has not been previously identified as a witness in your responses to the foregoing interrogatories (except that witnesses whose names have been previously listed but who will be called to support claims not identified in your responses to the foregoing interrogatories should have their names repeated here).
The purpose of this interrogatory is to identify persons knowledgeable about Decade's claims for -
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possible future discovery requests, and to enable Licensee to adequately prepare its response to Decade's claims in this proceeding.
0-2.
For each person identified in response to Interrogatory 0-1:
(a)
State the precise subject matter on which each such person is expected to testify; (b)
State the substance of the facts and opinions as to which each such person is expected to testify; (c)
State a summary of the grounds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions; and (d)
Identify all documents in your possession, custody or control (including all relevant page citations) pertaining to each of the facts and opinions identified in response to Interrogatory 0-2(b).
The purpose of this interrogatory is to clarify the scope of Decade's claims in this proceeding and to ascertain the factual bases for each element of those claims, to enable Licensee to adequately prepare its response to those claims.
0-3.
Identify all documents (including all relevant page citations) which you intend to offer as exhibits during this proceeding, or which you intend to use during your cross-examination of witnesses presented by Licensee and/or the Staff, and which were not identified in your responses to Interrogatories 3-15, 4-11, 5-9 or 7-9.
See purpose statement for Interrogatory 0-2.
a 0-4.
State the name, title or position, address and employer of each person who provided information used in preparir.g responses to any of the foregoing interrogatories.
The purpose of this interrogatory is to identify persons knowledgeable about each issue for possible future discovery requests.
0-5.
For each person identified in response to the preceding interrogatory, state the numbers of the interroga-tories for which information was supplied.
See purpose statement for Interrogatory 0-4.
0-6.
State t.he name, title or position, address and employer of each person who searched for documents in order to respond ta an', of the foregoing requests for identification of documents.
See purpose statement for Interrogatory 0-4.
0-7.
For each person identified in response to the preceding interrogatory, state the numbers of the inter-rogatories for which the search was conducted and the location where the search was conducted.
See purpose statement for Interrogatory 0-4.
0-8.
Identify any written or recorded statement of any individual pertaining to the subject matter of Contentions 3, 4,
5 and 7, not previously identified in response to any of the foregoing interrogatories.
See purpcse statement for Interrog-atory 0-4..
REQUEST FOR PRODUCTION OF DOCUMENTS Licensee requests that Decade respond in writing to the following request for production of documents and produce the original or best copy of each of the documents requested below, at the office of David K.
Porter at the Wisconsin Electric Power Company or at a place mutually convenient to the parties.
The term " document (s)" means all writings and records of every type in the possession, control or custody of Decade or of Decade's attorney (s), including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings or recordings of any kind.
" Document (s)" shall also mean copies of documents even-though the originals thereof are'not in the possession, custody, or control ot Decade.
A document shall be deemed to be within the " control" of Decade or Decade's attorney (s) if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.
Licensee requests that Decade produce each and every document identified or described in the answers to the above d
Interrogatories 3-1 through 3-16, 4-1 through 4-11, 5-1 through 5-9, 7-1 through 7-9, and 0-1 through 0-8.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By a L h
'Brbce W.
ChurchillU
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Delissa A. Ridgway i
Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
November 10, 1981
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
WISCONSIN ELECTRIC POWER COMPANY
)
Docket Nos. 50-266
)
50-301 (Point Beach Nuclear Plant,
)
(OL Amendment)
Units 1 and 2)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing
" Licensee's First Set of Interrogatories and Request For Production of Documents To Intervenor Decade Relative To Full Sc' ale Sleeving Program" were served, by deposit in the U.S.
Mail, first class, postage prepaid, to all those on the attached service list, except that those marked by an asterisk were served by deposit with Federal Express, this 10th day of November.
/2 Y :$rt At&74
' '(Delissa'b Ridgws)f 9
Dated:
November 10, 1981
y o
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Sefore the Atomic Safety and Licensing Board In the Matter of
)
)
WISCONSIN ELECTRIC POWF.,R COMPANY
)
Docket Nos. 50-266
)
50-301 (Point Beach Nuclear Plant,
)
(OL Amendment)
Units 1 and 2)
)
SERVICE LIST Peter 3.
Bloch, Chairman Charles A.
Barth, Esquire Atomic Safety and Licensing Office of the Executive Board Panel Legal Director U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Hugh C.
Paxton
- Kathleen M.
Falk, Esquire 1229 - 41st Street Wisconsin's Environm' ental Los Alamos, New Mexico 87544 Decade 114 North Carroll Street' Dr. Jerry R.
Kline-Suite 208-Atomic Safety and Licensing Madison, Wisconsin 53703 Board Panel Stuart A. Treby, Esquire U.S.
Nuclear Regulatory Office of the Execu 1ve Commission Legal Director Washington, D.C.
20555 U.S. Nuclear Regula*;ory Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory l
Commission Washington, D.C.
20555 Atomic Safety and Licensing l
Appeal Board Panel l
U'. S. Nuclear Regulatory Commission Washington, D.C.
20555 4
Docketing and Service Section l
Office of the Secretary U.S. Nuclear Regulatory
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Commission Washington, D.C.
20555
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