ML20054E070

First Set of Interrogatories & Requests to Produce

ML20054E070
Person / Time
Site:	Catawba
Issue date:	04/20/1982
From:	Guild R PALMETTO ALLIANCE
To:	DUKE POWER CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20054E071	List: ML20054E070 ML20054E078
References
NUDOCS 8204260101
Download: ML20054E070 (21)

Text

- _ _ _ _ _ _ _ _

, Iy9fP

,v 7 , .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD o>

In the Matter of ) @ Q

) #

DUKE POWER COMPANY, ^et al. ) Docket Nos. 50-413 $

50-414 RECEIVEO (Catawba Nuclear Station, 92 42 APR2319825 Units 1 and 2) n r.wn %%

c> noc f PALMETTO ALLIANCE FIRST SET OF INTERR0GATORIES AND REQUESTS TO PRODUCE g 6

Pursuant to 10 CFR Sections 2.720(h)(2)(ii), 2.740b, 2.741 and 2.744, Palmetto Alliance (Intervenor) hereby serves its First Set of Interroga-tories and Requests to Produce upon the Applicants and the NRC Regulatory Staff. These interrogatories involve Palmetto Alliance Contentions 6, 7, 18, 40 and 43.

Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to the Regulatory Staff and the Applicants including their officers, directors, employees, agents, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of the Staff and the Applicants including their officers, directors, employees, agents, advisors or counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceeding each answer or response. Also, please identify the person providing each answer or response.

5 0 50 8204260 /6[

)

1 Q

• l 1

These interrogatories and requests shall be continuing in nature. Thus, any time infomation is obtained which renders any previous response in-correct or indicates that a response was incorrect when made, a supplement should be made to the previous response to the appropriate interrogatory 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 tem " documents" shall include any writings, drawings, graphs, charts, photographs, 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 requests you to make available for inspection and copying at a time and location to be designated, any and all documents, of whatsoever description, identified in the responses to the these interrogatories, below; including, but not limited to:

(1)~ any written record of any oral comunication between or among Applicants, their advisors, consultants, agents, 2

attorneys, and/or any other persons,-including but not limited to the NRC Staff, the Intervenors, 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 or whatsoever description, including but not limited to work papers, prior drafts, and notes of meetings.

If you maintain some documents should not be made available for inspection, you should specify the documents and explain why such are not being made available. This request extends to any such document, described above, in the possession of Applicants, Staff and their advisors, consultants, agents, or attorneys.

INTERR0GATORIES Pursuant to 10 CFR Sections 2.740b, 2.720(h)(2)(ii), Intervenor re-quests Applicants and 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.

A. General Interrogatories The following interrogatories apply severally to each of the contentions admitted as issues in controversy in this proceeding.

1. Please state the full name, address, occupation and employer of each person answering the interrogatories and designate the interrogatory or the part thereof he or she answered.

2. Please identify each and every person whom you are considering 3

w --- --- ,- e - ,.-_ _ - - _ _ 1 -- _ - . ,..w,. , __% -.. s, -

to call as a witness at the hearing in this matter on this con-tention, and with respect to each such person, please:

a. State the substance of the facts and opinions to which the witness is expected to testify;

b. Give a summary of the grounds for each opinion; and

c. Describe the witness' educational and professional background.

3. Is your position on the contention based on one or more calculations?

If so:

a. Describe each calculation and identify any documents setting forth such calculation.

b. Who performed each calculation?

c. When was each calculation perfonned?

d. Describe each parameter used in such calculation and each value assigned to the parameter, and describe the source of your data,

e. What are the results of each calculation?

f. Explain in detail how each calculation provides a basis for 1

i the issue.

4. Is your position on the contention based upon conversations, con-sultations, correspondence or any other type of comunications with one or more individuals?

If so:

a. Identify by name and address each such individual,

b. State the educational and professional background of each individual, including occupation and institutional affiliations.

4

c. Decribe the nature of each comunication with such individual, when it occurred, and identify all other individuals involved.

d. Describe the information received from such individuals and  !

i explain how it provides a basis for the issue. l

e. Identify each letter, memorandum, tape, note or other record i related to each conversation, consultation, correspondence, or other comunication with such individual.

B. Specific Interrogatories CONTENTIONS 6 AND 40

1. Do you agree that the Duke Power Company (DPC) Quality Assurance ,

(QA) program must comply with each of the criteria of Appendix B to 10' CFR Part 50 in order to establish Duke Power Company entitle-ment to the licenses sought in this proceeding?

2. If the answer to No.1 is negative, describe in detail the respects in which such compliance is not required and explain fully the factual and legal basis for your position.

3. Does the Duke Power Company Quality Assurance program comply with each of the criteria of Appendix B to 10 CFR Part 50?

4. What are the bases for your responses to Nos.1-3? Identify all l documents, physical evidence, testimony or oral statements by any person and legal authority on which you rely in support of your position.

5. Do you agree i.nat substandard workmanship in the actual des.ign, fabrication, construction and testing of safety-related structures, systems, and components can adversely affect the confidence that 5

l such structures, systems and components will perfonn satisfactorily in service?

6. Do you agree that the failure of safety related structures, systems, s

and components to perfonn satisfactorily in service can adversely affect the ability to prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public?

7. If the answer to either Nos. 5 or 6 is negative describe in de-tail the respects in which you do not agree and explain fully the factual and legal basis for your position.

8. Does workmanship in the actual design, fabrication, construction and testing of safety-related structures, systems, and components meet or exceed all applicable standards?

9. Identify and describe in detail all standards applicable to the actual design, fabrication, construction and testi.ng of safety-related structures, systems, and components.

10. If the answer to No. 8 is negative, describe in detail the respects in which such workmanship does not meet or exceed all applicable standards, and explain fully the factual and legal basis for your answer.

11. What are the bases for your responses to Nos. 5-107 Identify all documents, physical evidence, testimony, or oral statements by any person and legal authority on which you rely in support of your position.

12. Identify each deficiency in design and construction as defined in 6

10 CFR Section 50.55(e) and for each indicate: the classifica-tion of its significance (ie, classified under which subsections,-

50.55(e)(1)(i.- iv); the 10 CFR Part 50 Appendix A General Design Criteria to which each relates and the respects in which it re-flects noncompliance; the report number, and date, if any; the

names, titles, addresses, and telephone numbers of each person responsible for the deficiency, its discovery, its reporting, and i

! its corrective action; a detailed description of the deficiency and its safety implications; a detailed description of its correc-tive action.

I

13. For each activity under license by NRC or AEC conducted by Duke Power Company or its contractors and subcontractors involving any i nuclear facility or operation, including but not limited to Catawba, identify each deficiency, as defined in 10 CFR Section 50.55(e), which represents a s.ignificant breakdown in any portion of the Quality Assurance program conducted in accordance with the requirements of Appendix 0 to 10 CFR Part 50; identify the Appendix B criteria to which it relates; describe in detail the respects in which the deficiency reflects a noncompliance with the re-I quirements of Appendix B criteria; the 10 CFR Part 50 Appendix A General Design Criteria to which each relates, if any and the respects in which it reflects noncompliance; the report number and date, if any; the names, titles, addresses and telephone numbers of each person responsible for the deficiency, its discovery, its reporting, and its corrective action; a detailed description 7

l

1 of the deficiency and its safety implication; a detailed descrip-tion of its corrective action.

14. Identify all audits conducted pursuant to 10 CFR Part 50 Appendix B Criterion XVIII which reflected deficiencies; for each indicate:

the nature of the deficiency, the Appendix B criteria to which it relates and the respects in which noncompliance is reflected; the date and other identifying information of the audit documentation;

- the names, titles, addresses and telephone numbers of each person

responsible for the deficiency, the performance of the audit, the management review of the results, and its corrective action; a i detailed description of the deficiency and its safety implications; a detailed description of its corrective action.

15. Describe in detail each review of Duke Power Company's and Westinghouse's Quality Assurance program by the AEC/NRC Regulatory I

I Staff, including but not limited to those reviews referred to at pp 17-1 through 17-13 ~of the " Safety Evaluation of the Catawba Nuclear Station Unit Nos. I and 2", Supplenant No. ~ 1: January 21, 1974; for each indicate the deficiencies found, the adjustments, modifications, and improvements resulting or otherwise made; the Duke Power Company and Westinghouse position'and responses; the names, titles, addresses and telephone numbers of each person involved and a description of the involvement of each.

16. Describe in detail the selection, training, testing and evalua-tion program for Quality Control Inspectors at the Catawba plant from the commencement of construction until the present.

8

- -- . ,,,--,,,.,--,_,,-,------,,.,-,.,.,.-,--,,_.--,.,,,,m.,-,. ~ , - - . . . - - - .n . . . -- , ,.-..-,,--,,--.,,...,-.,-,.,-nn

17. Describe the job qualifications required of persons who are res-ponsible for training, testing, certifying and supervising Quality Control Inspectors.

18. Does Duke Power Company have a program which insures the integrity of the testing for Quality Control Inspector certification? If so, describe in detail.

19. What prior nuclear experience is required of Quality Control Field Engineers, Supervisor Technicians, or other persons responsible for supervising Quality Control Inspectors?

20. Describe in detail the circumstances and procedures, if any, under which Quality Control inspection criteria may be waived.

21. Identify in detail, including date, number, subject, and results all NRC Regulatory Staff inspection reports regarding the facility and correspondence by and beween the Regulatory Staff and Duke Power Company regarding such inspections and any corrective action.

22. Provide the names, titles, addresses, phone numbers and date of employment for all persons employed at the facility in or responsible l

for, the Quality Assurance and Quality Control programs. For each such person no longer employed in Quality Assurance / Quality Control indicate the reason for temination. For each such person involun-tarily tenninated describe in detail the circumstances of termination.

23. Identify in detail all documents, including correspondence, reports, minutes of meetings or notes of oral conversations, reflecting disagreements, disputes or differences of opinion between Quality Control Inspectors and their supervisors or Duke Power Company 9

management. Include the subject, date, names of persons involved and resolution for each instance so reflected.

24. Does Duke Power Company have a policy or program to encourage complaints or suggestions by workers regarding substandard workmanship and significant deficiencies in plant design and construction? If so describe in detail.

25. Identify any complaints or suggestions by workers known to Duke Power Company regarding substandard workmanship and significant deficiencies in plant design and construction or pressure to perform or approve faulty workmanship. Include the date, name, title, aadress and telephone number of the source, subject and resolution or other action taken for each.

26. Describe in detail the basis for the "below average" rating for Catawba by the NRC Systematic Assessment of Licensee Performance Review Group (SALP) for the evaluation period 9/1/79-8/31/80 as reflected in NUREG-0834. What specific evidence of " weaknesses in the areas of quality assurance, including management and train-ing" was 1.und, how, by whom, and what corrective action has been taken?

27. What are the bases for your responses to Nos.16-26? Identify all documents, physical evidence, testimony, or oral statements by any person and legal authority on which you rely in support of your position.

CONTENTION 7

1. Do you agree that a consistent failure by Duke Power Company to 10

I i

adhere to required NRC operating and administrative procedures provided for in Commission rules and regulations impugns the assurance that the facility can be operated without endangering )

i the public health and safety and bars issuance of the licenses j sought in this proceeding?

2. If your response to No.1 is negative, explain in detail the respects in which you do not agree.

3. Do you agree that Duke Power Company has consistently failed to adhere to required NRC operating and administrative procedures provided for in Commission rules and regulations, and that, there-fore, no reasonable assurance can be had that the facility can be operated without endangering the public health and safety?

4. If your response to No. 3 ~is negative, explain in detail the respects in which you do not agree.

5. What are the bases for your responses to Nos.1-4? Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.

6. Describe in detail Duke Power Company policy, program and pro-cedures, if any, for assuring adherance to NRC operating and administrative procedures, rules and regulations.

7. Describe in detail any Duke Power Company personnel training, selection, performance evaluation or disciplinary procedures employed to assure adherance to NRC operating and administrative procedures, rules and regulations.

8. What are the bases for your responses to Nos. 5-7? Identify 11 l l

all documents, testimony, or' oral statements by any person and legal requirements on which you rely in support of your position.

9. Do you agree that Duke Power Company has been responsible for a history of repetitive and chronic non-compliance with NRC rules and regulations and a failure to institute effective corrective action and management controls with respect to such non-compliance?

10. ' If your response to No. 8 is negative, explain in detail the respects in which you do not agree.

11. Describe in detail each instance of Duke Power Company noncom-pliance with NRC operating and administrative procedures pro-vided for in Commission rules and regulations.

12. Describe in detail the corrective actions and management con-trols instituted by Duke Power Company with respect to each instance of noncompliance referred to in response to No.11.

13. Were the corrective actions and management controls referred to in response to No. 12 effective?

14. If your response to No.13 is negative, explain the respects in which they were not effective. .

15. What are the bases for your responses to Nos. 9-14? Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.

16. Have any Duke Power Company employees or contractor or subcon-tractor employees been warned, counseled, disciplined, trans-ferred, demoted, penalized, suspended or terminated as a result of noncompliance with NRC operating and administrative procedures, 12 i

f 1

l l

rules or regulations at any licensed facility or for actions under any NRC license? Identify the name, title, dates of employment, address and telephone number of each such employee; describe in detail the action taken, the reason for each sur.n action, the procedures, rules or regulations not complied with, and the safety significance of such noncompliance.

17. Has Duke Power Company been the subject of requests for action, notices of proposed action, notices of violation, notices of proposed imposition of civil penalties, orders to show cause, proceedings to modify, suspend, or revoke a license or to impose civil penalties pursuant to 10 CFR Part 2, Subpart B, any other provisions of AEC or NRC statutes or regulations, or any civil or criminal proceeding in the courts of the United States or any State, before any agency of the United States or any State with respect to activities under AEC/NRC license?

Describe in detail each such instance, the violation or claim alleged, its date and place, the Duke Power Company response including any evidence offered in answer, remission or mitiga-tion, the proceedings had thereon and the outcome.

18. What are the bases for your responses to Nos.16 and 177 Identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position.

CONTENTION ^18

1. Do the emergency diesel generators and associated systems and 13 ,

l l

components comply with 10 CFR Part 50, Appendix A, General Design criteria 5,17 and 18?

2. If your response to No.1 is negative explain in detail the respects in which they do not comply.

3. Are the emergency diesel generators and associated systems and components designed, constructed and capable of operation at standards sufficiently l

l high to assure safe shutdown and control of the reactor in the event of loss of off-site power and thereby not endanger the health and safety of the public?

4. If your response to No. 3 is negative explain in detail the respects in which they are deficient.

5. What are the bases for your responses to Nos.1-4? Identify all documents, testimony or oral statements by any person and 1.egal re-quirements on which you rely in support of your position.

6. What is the manufacturer, model number, date of manufacture, place of manufacture, rated capacity, testing and operational history, date of purchase and installation at the facility of each emergency diesel generator to be used at the facility, including the following com-ponents and related systems: the diesel engine, the starting system, the fuel oil system, the lube oil system, the cooling system, the governor, the generator and related controls,-the safety shutdown and emergency control system, the combustion air supply and filtra-tion system, the battery and battery charging system, the automatic load transfer system, the load shedding system, the engineered safety l

l features (ESF) loss of normal power protective logic, the load 14

sequencers, the inverters and DC/AC motor generator sets, and the fusing and protective relaying system.

7. What has been the testing and operating experience of the emergency diesel generators, the components and related components identified i

in No. 6 and the use of such for safe shutdown and reactor control  !

in the event of loss of off-site power in testing and actual use at operating nuclear power plants, plants under construction, and other installations? Identify each other nuclear facility, or other in-stallation under construction or in operation, at which components of the same, or substantially similar design are employed and describe in detail the testing and operating experience at such installation including each Licensee Event Report or other record reflecti.ng such experience.

8. Have actual qualification tests been performed on the emergency diesel generators to be used at the facility? If so describe in detail.

9. Can the emergency diesel generator units at the facility pass at least 300 valid start and load tests (defined as a start from design cold ambient conditions with loading to at least 50% of the continuous rating within the required time interval, and continued operation untiltemperatureequilibriumisattained)withnomorethanihree failures? Has each unit passed such a test?

10. If your response to No. 9 is negative, describe in detail the respects in which the units can not or have not passed such a test.

11. What are the bases for your responses to Nos. 6-107 Identify all documents, testimony, or oral statements by any person and legal 15

requirements on which you~ rely in support of your position.

12. What has been the testing and operating experience of the emergency diesel generators, the components and related components identified in No. 6 at each other Duke Power Company nuclear power plant under construction or in operation? Identify the manufacturer, model number, date of manufacture, place of manufacture, rated capacity, testing and operational history including any Licensee Event Reports or other record reflecting such experience.

13. What is the necessary electric power requirements (kVA or other units of measure) for each component of the Reactor Protection Systems (RPS),

the Engineered Safety Features (ESF), the vital controls and instru-ments, and any other components or systems required to achieve safe shutdown following an off-site electrical grid disturbance or loss of off-site power? For each component of the Emergency Core Cooling System (ECCS)? For each reactor coolant pump? For both units simul-taneously in the event of an accident in one unit, an accident in both units, a single failure in one unit, a multiple failure in one unit, and a multiple failure in both units?

14'. Describe the priority of load sequencing and the sequence of opera-tions for each component and in each circumstance identified in No.

13. Can the emergency diesel generator systems at the facility meet all necessary electric power requirements to achieve safe shutdown under each such circumstance? If not describe in detail the respects in which it can not.

15. How much time does it take'to start each diesel, generator?

16

16. How many sequential starting attempts are possible for each unit?

17. What maintenance or manual starting procedures are to be employed in the event of air starting system failure in order to achieve success-ful start?

18. Under what circumstances would the emergency diesel generator system i

, and related components fail to assure that reactor core cooling, l

l containment integrity and other vital safety functions are maintained?

19. For each of the types of on-site electrical system malfunctions listed below what features of this facility's design, fabrication, construc-i tion and proposed operation, if any, provide assurances that such malfunction will not occur or impugn the health and safety of the public?

I. Offsite Circuits and Startup Transformers a loss of offsite circuits;

b. electrical power system underfrequency;

c. electrical power system undervoltage; II. Switchyard Breakers and Autotransfer Logic

a. breaker failure to transfer following plant trip;

b. incorrect manual operation of the breaker contrcis;

c. failures in the autotransfer logic; III. Load Sheddi.ng Systems

a. stuck breakers;-

b. non-conservative setpoint drift; IV. Engineered Safety Features Loss of' Normal Power Protectiye Logic

a. non-conservative setpoint-drifts; 17

b. incorrect input setpoints for protective actions;

, V. Diesel Generator Air Starting Systems

a. air leak from the air starter lines, reservoirs, and compressors;

b. control air system failures caused by small valves sticking or pl_ugging by foreign objects;

c. electrical malfunctions which disabled the control logic;

d. operator ermrs; VI. Diesel Generators

a. relays failing to make proper contact;

b. inadequate field flashing of the. generator;

c. diesel governor control system failures;-

d. clogging of the lube oil system;

e. foreign material in the fuel lines;

f. failure of the cooling system;

g. protective logic trips;

h. operator error;

i. fires in the exhaust manifold; .

VII. Diesel Generator Load Sequencers

a. overloading resulting from design errors, improper tuning, or timer failures;

b. latchup; VIII. Battery Charger Systems

a. electrical failures in the charging control circuit causing the charger to trip; 18

b. operator error in setting the charging current too high; IX. Station Batteries

a. excessive discharge;

b. low specific gravity of electrolyte;

c. short circuits;

d. open circuits; X. Inverters and DC/AC Motor Generator Sets

a. failure of the inverter control circuitry during normal operation;

b. interactions with the' battery charger in plants using inte-gral battery charger / inverters; XI. Fusing and Protective Relaying

a. short circuits (potential electrical fires) that result from insufficient fusing or protective relaying;

b. improper rated fusing and protective relaying setpoints causing vital components to trip spuriously;

c. failure to replace, or install, proper fusing on vital electrical equipment after servicing.

20. What are the bases' for your responses to Nos.11-197 Identify all documents, testimony or oral statements by any person and 1.egal re-quirements on which you rely in support of your position.

l CONTENTION 43

1. What consideration has been given to the effects of'Corbicula on the performance of the facility's cooling tower system?

2. Do you agree that Corbicula are known to infest the Catawba River and Lake Wylie?

19

1

3. What surveys have been conducted which would pennit quantification of the number and concentration of Corbicula in the Catawba River and Lake Wylie? Describe in detail the methodology and results.

4. Do you agree that Corbicula larvae will be drawn into the Nuclear Service Water and Low Pressure Service Water Systems from Lake Wylie?

5. Will Corbicula live in the facility cooling system or any portions

~

or components of the cooli.ng system? If so, describe in detail the portions of the system which may be affected, the consequences of Corbicula infestation on the operation of the system, including the costs and means for controlling or correcting the problem.

6. Why do you believe that the combination of warm water and chlorina-tion will preclude Asiatic clam infestation?

7. Do you believe the Asiatic clam will present a problem at the facility whether or not similar to problems at other power plants?

8. What is the experience with Corbicula infestation at other nuclear power plants with cooling towers or with once-through cooling systems?

Why will the effects on Catawba be different?

9. In the event that significant Corbicula infestation occurs at the l facility what would be the effects on each component of the cooling system in terms of efficiency of operation, safety, costs and in l tenns of the relationship among degree of blocki.ng, water flow, water l

l temperature and turbine power output?

10. What are the bases for your responses to Nos.1-9? Identify all documents, studies, publications, testimony or oral statements by any 20

person and legal requirements on which you rely ir, support of your position.

I k y ,

April 20, 1982 Robert Guild V 314 Pall Mall Columbia, South Carolina 29201 Counsel for Palmetto Alliance 21

. . . . _ . _ _ . . . _ . . . _ , _ . _ . . . _ _ . _ _ _ _ . _ _ _ _ . _ _ _ _ . . _ _ _ . . . _ _ . _ _ . . . . . . _.