ML20052E505
| ML20052E505 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/07/1982 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | PALMETTO ALLIANCE |
| Shared Package | |
| ML20052E507 | List: |
| References | |
| NUDOCS 8205110172 | |
| Download: ML20052E505 (8) | |
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STAFF 5/7/82 6
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)
)
NRC STAFF'S FIRST SET OF INTERR0GATORIES AND DOCUMENT PRODUCTION REQUESTS TO PALMETTO ALLIANCE In accordance with 10 CFR Sections 2.740, 2.740b and 2.741, the NRC Staff hereby serves Palmetto Alliance as an intervenor in the above-captioned proceeding with NRC Staff's First Set of Interrogatories and Document Requests to Palmetto Alliance. These interrogatories and document l
requests relate to Palmetto Alliance contentions 6, 7, 18, 40 and 43, as l
conditionally admitted in the Licensing Board's Memorandum and Order l
(Reflecting Decisions Made Following Prehearing Conference), dated i
March 5, 1982.
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Each interrogatory shall be answered separately and fully in writing under cath or affirmation, and shall include all pertinent information available to the Palmetto Alliance its officers, directors, members, employees, advisors, or counsel, based upon the personal knowledge of the person answering. Answers to these interrogatories are required to be served upon all parties to the proceeding within 14 days after service of the interrogatories. By each request for production of documents, the NRC Staff seeks to inspect and copy pertinent documents which are in the possession, custody, or control of Palmetto Alliance, its officers, directors, members, employees, advisors or counsel.
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As used herein, the term " documents" shall include any writings, drawings, graphs, charts, and schedules, however produced; photographs or other pictorial representations; recordings and tapes, whether sound or visual; and data compilations of whatever form.
Each interrogatory should be answered in six parts as follows:
(1) Answer the direct question asked or provide the information requested (separately as to each subpart as applicable).
(2)
Identify fully any documents (a) used as the basis for the answer to the interrogatory or (b) related to the subject of the interrogatory upon which you intend to rely in establishing the pertinent contention.
(3) Give the name, address, occupation and employer of the person or persons (a) answering each interrogatory, or (b) who have served, presently serve, or it is anticipated will serve as consultants or advisors to Palmetto Alliance on the subject matter of the interrogatory.
(4)
Identify each person whom you expect to call as a witness to testify as to the issue addressed in the pertinent interrogatory. As to each such person, please state (a) the subject matter of his ci her testimony and (b) the substance of the testimony.
(5)
Is the answer based on a calculation?
If so, describe (a) the calculation, (b) identify any documents setting forth such calculation, (c) identify the person who performed each calculation, (d) when it was performed, (e) each parameter used in such calculation, each value assigned to the parameters, and l
the source of your data, (f) the results of each calculation, l
and (g) how each calculation provides basis for the answers.
(6)
Is the answer based on conversations, consul' ations, correspondence or any other type of communic.tions with one or more individuals?
If so, (a) identify each such individual by name and address, (b) state the educational and professional background of each such individual, (c) describe the information received from such individual and its relation to t
your direct answer, (d) identify each writing or record related to each such conversation, consultation, correspondence or other communication with such individual.
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. t In addition, Palmetto Alliance is requested, pursuant to 10 CFR Section 2.740(e), to supplement its responses as necessary with respect to the identity of each person expected to be called as an expert '
witness at the hearing in this proceeding, the subject matter on which he or she is expected to testify, and the substance o" such testimony.
Similarly, Palmetto Alliance is requested to amend its respon>;es if Palmetto Alliance subsequently learns that any response made to the interrogatories herein was incorrect when made, or that the response though correct when made is no longer correct.
If the answer to any interrogatory or portion thereof is fully provided in a response to any other interrogatories which have been previously served in this proceeding, you may answer by so indicating, with specific reference to the portion of the interrogatory addressed in such other answers.
You are requested, however, so answer the interrogatories below based on all information in your possession at the time of answering, including any information received subsequent to answering any other interrogatories.
INTERR0GATORIES Palmetto Alliance Contention 6 1.
Explain each and every instance of " substandard workmanship and l
poor quality control" referred to in Contention 6.
2.
Explain fully what you mean by "NRC standards in many safety-related areas," as stated in the first sentence of Contention 6.
3.
Explain fully what you mean by "strongly suggest" in the first sentence of Contention 6.
4.
Explain full'y what you mean by " actual plant construction."
5.
Explain fully the basis for your statement that " Applicants have failed to provide a Quality Assurance program which meets the requirements of 10 C.F.R. Part 50, Appendix B."
Set out each factual basis, and the manner in which it supports your statements as to particular portions of 10 C.F.R. Part 50, Appendix B.
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6.
Explain fully the basis for your conclusion that "no reasonable assurance exists that the plant can operate without endangering the e
health and safety of the public."
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7.
Explain fully how the "NRC's Systematic Assessment of Licensee Performance Review Group" finding for Catawba supports your assertions of " substandard workmanship," " poor quality control,"
" actual plant construction is substantially below NRC standards in many safety related areas," failure to meet 10 C.F.R. Part 50, App. B requirements, or lack of reasonable assurance that the plant can operate without endangering the health and safety of the public.
8.
Identify the "former Duke Power Company construction workers, including a certified Quality Control Inspector" referred to in the last sentence of Contention 6.
For each person provide name, address, present employer, former position and responsibilities while with Duke and period of employment with Duke.
9.
As to each person identified in the answer to Interrogatory 8, identify the complaint or complaints of " systematic deficiencies in plant construction and company pressure to approve faulty workmanship."
- 10. As to each complaint identified in the answer to Interrogatory 9, state in detail the circumstances and basis for the complaint.
Your answer should include, but not be limited to, the nature of each " deficiency" identified, the person reporting such deficiency, the actions taken by the person reporting the deficiency, the time and plant location of each occurrence, the basis for the assertion that it is systematic, the nature of the " company pressure to approve faulty workmanship," the time, place, persons, and other circumstances of such " pressure," and each instance of " faulty workmanship" involved.
- 11. Explain fully as to each complaint identified in your answer to Interrogatory 9 and discussed in your inswer to Interrogatory 10, how each supports your assertions of " substandard workmanship,"
" poor quality control," " actual plant construction is substantially below NRC standards in many safety related areas," failure to meet 10 C.F.R. Part 50, App. B requirements, or lack of reasonable assurance that the plant can operate without endangering the health and safety of the public."
Palmetto Alliance Contention 7 12.
Identify, and give full decails with respect to, information which you contend in the f irst sentence of Contention 7 indicates that Duke has failed to adhere to operating and administrative procedures provided for is Commission rules and regulations, with respect specifica,11y tf the,c tawba facility.
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- 13. With respect to your answer to Interrogatory 12, identify (a) the public health and safety significance of any failure identified therein; and (b) each Commission rule and regulation which you contend is or was not adnered to by Duke.
14.
Identify (a) each weakness in personnel adherence to operating and administrative procedures, and (b) each failure to follow procedures referred to in the fourth sentence of Contention 7, which you contend supports your statements that "[n]o reasonable assurance can be hao that the [ Catawba] facility can be operated without endangering the public health and safety," or that any Comission rule or regulation has not been adhered to by Duke.
- 15. With respect to those matters identified in your answer to Interrogatory 14, explain fully how such weaknesses in personnel adherence to operating'and administrative procedures or failure to follow procedures, support your contention the "[n]o reasonable assurance can be had that the [ Catawba] facility can be operated without endangering the public health and safety," and/or demonstrates a failure to adhere to specific Commission rules and/or regulations.
- 16. Do you contend that the enforcement action taken by the NRC in 1977 with respect to the Oconee facility has a bearing on Applicants' adherence, with respect to the Catawba facility, to the Conunission rules and regulations specified in your answer to Interrogatory 13?
17.
Explain the factual basis and/or legal authority for your answer to Interrogatory 16.
Palmetto Alliance Contention 18 18.
Identify the " diesel generators" which are the subject of Contention 18.
I 19.
Identify each of the " standards" to which the first senterce of l
Contention 18 refers.
- 20. Do you contend that the diesel generators described in your answer to Interrogatory 18 fail to comply with any NRC regulation or regulatory guidance? If so, identify each regulation, regulatory guide or other authority which you assert is not satisfied, and explain, with reference to the diesel generator, component or function, the manner it is not satisfied.
- 21. Describe fully each deficiency, report, occurrence, instance, l
example, or fact, upon which you base your assertion that l
Applicants' diesel generators are not " designed, constructed l
. t and operated at standards sufficiently high that they may be relied upon to reasonably assure that the health and safety of the public will not be endangered." Please indicate as to each element of your answer whether you are addressing (1) design, (2) construction or (3) operation of Applicants' diesel generators, as well as what diesel generator, component, and function " critical to the safe shutdown or control of the reactor in the event of loss of offsite power" is involved.
- 22. To what " regulatory requirements" do you refer in the second paragraph of Contention 18?
23.
Identify the precise paragraphs of the Applicants' FSAR which are asserted to supply inadequate information and specify what information or assurance is missing.
- 24. What is the relevance of Duke Power Company installation of used generators in its McGuire Nuclear Station to the first two sentences of Contention 18?
Palmetto Alliance Contention 40
- 25. What do you mean by " irregularities in the welding practices" in Contention 40?
26.
Identify each such " irregularity."
27.
Identify each such " welding practice."
28.
For each " irregularity" and " welding practice" identified in your answers to Interrogatories 26 and 27, state each fact, occurrence, report, deficiency or other information upon which it is based, by whom it was identified and/or reported, when it was. identified, the specific location of the weld or place at which the practice occurred, the specific " safety-related systems" affected, to whom it was reported, and any action taken by any person to correct such "irreaularity" or " welding practice."
- 29. Do you contend the welding practices at the Catawba facility are not in compliance with any NRC regulation or regulatory guide, or other standard?
30.
If your answer to Interrogatory 29 is yes, identify each such regulation, regulatory guide or other standard, the " welding practices" or " irregularities" which give rise to such non-compliance, the " safety related systems" involved, and how "the public health and safety" will be endangered thereby.
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. t Palmetto Contention 43
- 31. What are the " effects" on the performance of the cooling tower system which form the basis for Contention 437
- 32. Describe fully the factual basis for each "effect" described in your answer to Interrogatory 31.
- 33. Describe the health and safety concern (s) or impact (s) on the environment, if any, which form the basis for Contention 43.
- 34. With respect to any health and safety concern, or environmental impact described in your answer to Interrogatory 33, identify any NRC regulatory requirement, regulatory guidance, or other authority which you contend is not satisfied, and the reasons therefor.
- 35. Are you aware of any known occurrences of Corbicula fouling of closed cycle cooling towers at steam-electric power plants? If so, identify each such plant, and describe fully any observed degradation of the cooling system due to such fouling.
Request for Documents Pursuant to 10 C.F.R. Section 2.741, the NRC Staff requests you to make available for inspection and copying at a time and location to be designated any and all documents, of whatever description, identified in the responses to the above Staff interrogatories, including, but not limited to:
(1) any written record of any oral communication between or among Intervenors, their advisors, consultants, agents, attorneys, and/or any other persons, including but not limited to the Applicants, and their advisors, consultants, agents, attorneys and/or any other persons; and (2) any documents, correspondence, letter, memorandum, notes, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts, and notes of meetings.
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. t If Palmetto Alliance maintains that some documents should not be made available for inspection, it should specify the documents and explain why such documents are not being made available. This request extends to any such document, described above, in the possession of Palmetto Alliance its advisors, consultants, agents, or attorneys.
Respectfully submitted, h
't tr.L George E John n Counsel for NRC Staff Dated at Bethesda, Maryland this 7th day of liay, 1982.
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