ML20063M205

Second Set of Interrogatories & Requests to Produce. Certificate of Svc Encl.Related Correspondence

ML20063M205
Person / Time
Site:	Catawba
Issue date:	09/03/1982
From:	Guild R GUILD, R., PALMETTO ALLIANCE
To:	DUKE POWER CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20063M202	List: ML20063M195 ML20063M205
References
NUDOCS 8209100182
Download: ML20063M205 (14)

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@TED CONm- -- USNRC UNITED STATES OF AMERICA NUCLEAR REGUIA'IORY CXMiISSION BEEDRE THE A'IOMIC SAFETI AND LICENSb In the Matter of ) 0FFl0E 07 SECEEL*'

r.r;' lim 3 & SE9 '

• DUKE POWER CDMPANY, et al. I DocketNos.5dM55

) 50-414 (Catawba Nuclear Station,

)

Units 1 and 2)

PAIFETIO ALLIANCE SECOND SET OF INI'ERROGA'IORIES AND REDUESTS 'IO PRODUCE Pursuant to 10 CFR Sections 2.720(h) (2) (ii) , 2.740b, 2.741 and 2.744, Palmetto Alliance (Intervenor) hereby serves its Second Set of Interrogatories and Requests to Produce upon the Applicants and the NRC Regulatory Staff.

These interrogatories involve Palmetto Alliance Contentions 8 and 27.

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 incitxling their officers, directors, cmployees, agents, advisors or counsel. Each request to produce applies to pertinent doctanents which are in the possession, custody or control of the Staff and the Applicants including their officers, directors, sployees, agents, advisors or counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceedina each answer or response. Also, please identify the person providing each answer or response.

These interrogatories and requests shall be continuing in nature. Thus, any time information is obtained which renders any previous response in-correct or indicates that a response was incorrect when made, a suppleent i should be made to the previous response to the appropriate interrogatory 1

9209100182 820903 PDR ADOCK 05000413 C PDR

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 thm.

The term "doctraents" shall include any writings, drawings, graphs, charts, photographs, and other data ccrnpilations frcm 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 'IO 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 these interrogatories, below; including, but not limited to:

(1) any written record of any oral ocr:runication between or a: tong Applicants, their advisors, consultante, agents, 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, correcpondence, letter, mcrnorandum, 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.

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If you maintain same documents should not be made available for inspection, l you should specify the doctnents 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.

INTERROGNIORIES Pursuant to 10 CFR Sections 2.740b, 2.720(h) (2) (ii), Intervenor requests 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 cynployer 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 whm you are considering to call as a witness at the hearing in this matter on this contention, and with respect to each such person, please:

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

b. Give a sunmary 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?

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c. hhen was each calculation performed?

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 the issue.

4. Is your position on the contention based upon conversations, con-sultations, corresponcence or any other type of ccmuunications 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,

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

d. Describe the information received frcm such individuals and explain how it provides a basis for the issue.

e. Identify each letter, mmorandum, tape, note or other record related to each mnversation, consultation, correspondence, j or other ccanunication with such individual.

B. Specific Interrogatories Contention 8

1. Identify all documents, sutdies, technical reports and treatises that provide the applicant and/or subcontractors with scientific, technical, and theoretical information on the subject of operator qualifications.

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2. Identify any and all ccurunications with the NRC on the subject of operator qualifications. Include any and all ccxmunications with NBC on the subject of operator qualifications at all other nuclear facilities operated by the applicant as well as Catawba.

3. Describe in detail the criteria used in selecting all control rom personnel including but not limited to criteria concerning education, work experience, specialized training, physical and mental health, and personal characteristics. List the criteria for each position.

4. What are the bases for determining that the criteria identified in answer to No. 3, above, adequately forecast the person's ability to perform his or her job responsibilities?

5. Are the criteria described in question 3 required by any regulatory agency? Identify the relevant requirements and standards.

6. Do the criteria described in question 3 meet or exceed the standards and requirments of the NRC and/or any other regulatory agency?

If the answer is negative, where specifically are your criteria deficient?

7. Are any of the criteria described in question 3 additional to or different in any way frm the required criteria? If so, describe in detail the additions or differences.

8. If the answer to question 7 is affirmative in whole or in part, why were such additions or changes made in the criteria used in selecting personnel. Identify any studies, documents, oral cxxmunications, testimony, mmoranda and guidelines used in making the determination that such additions and/or changes would be useful in selecting control rom personnel, j 5

9. May any of the criteria described in your response to question 3 be waived in an individual case? If the answer is affirmative in whole or in part, describe in detail the circumstances under which the criteria may be waived.

10. Have any criteria been waived in seleting control rom personnel?

If the answer is affirmative in whole or in part, describe in detail each instance where a waiver has been granted and give the reasons for such waiver. Are these waivers allowable under the relevant requirements and standards?

11. In your FSAR 12.1.3(0) you state:

" Operators, whether or not they are to be licensed by the NRC, should have a high school diplcma, or equivalent, and should possess a high degree of manual dexterity and mature judgment."

a. Are all operators required to be licensed by the NRC? If not, describe in detail the jcb responsibilities of such operators. Why are they not required to be licensed by the NRC?

b. What is your understanding of "a high degree of manual dexterity"?

Describe in detail methods used to determine if a person has such dexterity.

c. What is your understanding of " mature judgment"? Describe in detail the methods used and factors considered in determining if an applicant has " mature judgment".

12. Do you contend that the experience levels now required by the NRC are sufficient to ensure that control rom personnel are adequately prepared to respond in the event of an mergency? If the answer is negative, describe in detail the experience that should be ra[uired for each control rocm position.

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13. Do you contend that actual " hands-on" operating experience would not be beneficial to ensuring better performance by control rocm personnel? Explain in detail your answers.

14. Describe in detail the advantages and disadvantages of requiring hands-on operating experience for control rocm personnel.

15. Explain in detail the bases for your answers to questions 1 - 14 above. List any documents, oral ccrmunications, or other information used in reaching the conclusions to your answers.

16. Identify all control rom personnel by name, position, educationsl level, experience and specialized training. If experience and/or training includes experience at other ccutmercial or government reactors and/or simulators, identify the manufacturers, manufacturer's number, design model of each reactor and/or simulator. Describe in detailthedifferences frm each of these reactors or simulators to the facility at Catawba. Particularly describe in detail the differences in operating navy reactors and the Catawba reactor.

17. Do you contend that these differences are significant regarding the ability of control rocm personnel to perform at Catawba? Explain in detail your answer.

18. What are the bases for your answer to question 17? Identify all f

documents, oral ccrtmunications, testimony or other information on which you relied.

19. Have control rocm personnel been involved in the planning of control rom design and procedures? If so, explain in detail each person's participation.

20. Describe in detail the training program required to be cmpleted by all control rom personnel.

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21. Do you contend that this program is sufficient to insure effective performance by such personnel during routine operation of the plant? Explain your answer in detail.

22. Do you contend that this program is sufficient to insure effective performance by such personnel in the event of an emergency situation?

, Explain in detail.

23. Do you contend that this program sufficiently cmpensates for j actual hands on operating experience? Explain your answer in detail.

24. What are the bases for your answers to questions20-237 Identify all documents, oral ccmnunication, testimony, physical evidence used.

25. Describe in detail the training received by control rom personnel in mergency responses.

26. Is the training program above required or reccmnended by the NRC or any other regulatory agency? Cite the relevant requirments.

27. Does the training program above meet or exceed the standards and/or requirmants of the NBC and/or any other regulatory agency? If not, where specifically is your program deficient?

28. lias your program ever been evaluated? If so, describe in detail such evaluations.

29. Has your program ever been criticized? If so, describe in detail such criticisms.

30. Are any cmponents of the training program described in your response to question 20 additional to or different in any way frm the requirments of the NRC or any other regulatory agency? If so, describe in detail the additions and/or differences.

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31. If the answer above is affinnative in whole or in part, why were such additions and/or changes made? Identify all studies, documents, oral comunications and testimony used in making the determination that such changes and/or additions were necessary and/or useful in providing adequate training.

32. Identify by name, position, experience, educational level and specialized training all persons involved in training and in-structing control roca personnel.

33. Describe and identify all materials used in training personnel.

34. Describe in detail a'.: tests given control rocm personnel during and following the training program.

35. Provide the tests results for all control roca personnel.

36. Describe in detail your involv ment in any NRC rule making pro-ceedings on the subj ct of operator qualifications and identify any documents, studies, cmments or subnissions known to you on this subject.

Contention 27

1. Identify all documents, studies, technical reports and treatises that provide the applicant and/or subcontractors with scientific, technical and theoretical information on the subject of radiation detection and radiological monitoring.

2. Describe in detail the purpose and cmponent parts of an off site radiological monitoring syst s. Identify all requirenents and standards applicable to this systs.

3.. Describe in detail the offsite radiological monitoring syst s to be installed at Catawba. Does this systen meet and/or exceed the requirenents and standards identified above. Discuss in detail any deviation, deficiency and/or addition to the requirenents and standards identified above.

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4. Are there any other methods available for meecing the standards and requirments above? Identify all other methods.

5. Describe in detail the functions and detection capabilities of the offsite radiological nonitoring systs to be installed at Catawba.

6. What is the cost of the systs to be installed at Catawba? In-clude cost of all cmponent parts, installation costs, operating costs, costs involved in collecting the data, costs of processing the data as well as any other costs associatal with the systm.

7. Describe in detail the process followed in selecting the cmponents of the offsite radiological monitoring syst m to be installed at Catawba. Identify in your response all manufacturers consulted, nodels of cmponents considered, costs of such cmponents, capabilities of such cmponents, studies, documents, oral cmmunications and testimony used in the process of selecting this systm.

8. Specify your reasons for rejecting other cmponents considered.

9. Do you contend that thermolununescent dosimeters (TIDs) are superior to any other method of radiological monitoring? Describe in detail how TLDs are superior or inferior to other methods of monitoring.

10. Identify any and all comunications with the NRC on the subject i

of offsite radiological monitoring systms. Include ccumunications about the offsite radiological monitoring systms at other nuclear I

plants operated by Duke in addition to those concerning Catawba.

l 11. Describe in detail the offsite radiological monitoring systes in use at all other nuclear facilities operated by the applicants.

Explain any differences between the systms at all other facilities and the syst s to be installed at Catawba.

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12. Describe in detail any NBC evaluations and the results of such evlauations of the offsite radiological nonitoring systms at all other nuclear facilities operated by the applicant. Identify all documents, studies, oral acrtrunications and testinony relating to such evaluations.

13. hhat has been the experience with the offsite radiological nonitoring syst ms at all other Duke facilities? Discuss in detail any probl ms associated with those systms.

14. hhat is the accuracy level of the systs to be installed at Catawba?

Describe in detail how you reached this level of accuracy.

15. Is the information provided by this systs inmediately ascertainable?

If not, how long does it take to obtain the information?

16. hhere will the reading of the TIDs take place? In the event of an mergency, can the reading be done at the plant site?

17. Are there any standards and/or requirments applicable to the reading of the TIDs in a routine situation and in an mergency situation. Identify all such standards and requirments.

18. Do you contend that the information provided by this monitoring systs will be ascertainable in time to make informed decisions regarding the public health and safety? Explain in detail the bases for your position.

19. hhat is your understanding of the term "real-time monitor"?

20. Was any consideration given to using real-time monitors in place of and/or in addition to TIDs? If so, describe in detail the conclusions you reached. If not, why was no consideration given?

21. Describe in detail the advantages and disadvantages of using real-time monitors in your offsite radiological nonitoring systs.

Identify all studies, documents, oral ocumunications and testimony in support of your position.

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22. Do you contend that having continuous, imnediate infonnation as would be provided by real-time monitors would not be benificial in the event of an mergency? Explain in detail your response.

23. Identify all real-time monitors now available. Describe in detail the detection capabilities, method of transmission, cmponents, meterological measur m ent accessories and cost of each.

24. Identify any probl m s associated with any of the monitors identified above.

25. Are real-time monitors now being used at any nuclear facilities in i

the United States? If so, identify the facilities where in use, number of stations at each facility, the distance frtxn each plant, the manufacturer and nodel of the real-time monitor and the length of time installed.

26. Were the operators of any of these facilities consulted about real-time monitors? If so, describe in detail the questions asked and re-sponses given by those people consulted.

27. Describe in detail the cost effectiveness of real time monitors.

Identify all studies, documents, oral comunications and testimony consulted and/or relied on in your description.

28. Has the applicant undertaken and/or contracted for any study of the cost effectiveness of real time monitors? Describe in detail any such study.

29. Is cost the major factor in your decision not to use real time monitors? If not, what is the major factor?

Septmber 3,1982 -

Robe'rt Guild 314 Pall Mall Columbia, South Carolina 29201 Counsel for Palmetto Alliance 12

. UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE TIE ATOMIC SAFEIY AND LICENSING BOARD In the Matter of )

)

DUKE POWER COMPANY, et_ al. ) Docket No. 50-413

) 50-414 (Catawba Nuclear Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of Palmetto Alliance Motion To Require Staff Answers To Interrogatories and Palmetto Alliance Second Set Of Interrogatories And Requests To Produce in the above captioned matters, have been served upon the following by deposit in the United States mail this 3rd day of Sept aber, 1982.

James L. Kelley, Chairman George E. Johnson, Esq.

Atcmic Safety and Licensing Office of the Executive Icgal Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Ca mission Cm mission Wahsington, D.C. 20555 Washington, D.C. 20555 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 Ccrnpany 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 Atamic Safety and Licensing P.O. Box 11549 Board Panel Columbia, South Carolina 29211 U.S. Nuclear Regulatory Cmmission Executive Director for Operations Washington, D.C. 20555 U.S. Nuclear Regulatory Camission Washington, D.C. 20555 1

}

I Chaiunan Jesse L. Riley

Atcznic Safety and Licensing 854 Henley Place 4

Appeal Board Charlotte, North Carolina 28207 U.S. Nuclear Regulatory Ccrnmission Scott Stucky Washington, D.C. 20555 Docketing and Service Station U.S. Nuclear Regulatory Henry A. Presler Ccmnission Charlotte-Mecklenburg Washington, D.C. 20555 Environmental Coalition 943 Henley Place Charlotte, North Carolina 28207 J. Michael McGarry, III, Esq.

Debevoise & Liberman 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 i ~'

P%rtGuild ,

AttorneyforPalg:oAlliance l

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