ML20063M337
| ML20063M337 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/03/1982 |
| From: | Bielawski A COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| References | |
| ISSUANCES-OL, NUDOCS 8209100261 | |
| Download: ML20063M337 (14) | |
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k [C DATED: 9/3/82 UNITED STATES. C NUCLEAR REGULAT Wid ddM S 050 grnce v pcm . .
BEFORE TIIE ATOMIC SAFETY-AND LICENSING BOARD In The Matter of )
)
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL
) 50-455 OL
)
(Byron Nuclear Power Station, )
Units 1 & 2) )
COMMONWEALTH EDISON COMPANY'S AMENDED SECOND ROUND OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO BE ANSWERED BY THE ROCKFORD LEAGUE OF WCf4EN VOTERS Pursuant to 10 CFR SS 2.740b and 2.741 and the
" Stipulation" among the parties dated August 18, 1982, Commonwealth Edison Company (" Edison") requests the Rockford League of Women Voters (" League") to answer separately and fully in writing, under oath or affirmation, each of the following Interrogatories and to produce the requested documents at the offices of Isham, Lincoln and Beale, Suite 5100, Three First National Plaza, Chicago, Illinois 60602, not later than October 3, 1982.
INSTRUCTIONS AND DEFINITIONS
- 1. As used in these Interrogatories, whenever appropriate, the singular form of a word shall be inter-l preted as plural and the masculine gender shall be deemed to include the feminine. -
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- 2. As used in these Interrogatories, the term "and," as well as "or," shall be construed either disjunc-tively or conjunctively as necessary to bring with'.n the scope of these Interrogatories any information which might
. otherwise be construed to be outside their scope.
- 3. As used in these Interrogatories, the term
" person" includes, without limiting the generality of its meaning, every natural person, corporate entity, partnership, association, governmental body or agency.
- 4. As used in these Interrogatories, the term
" document" shall mean all written or recorded material of any kind or character known to the League, its agents or consultants or in the possession, custody or control of the League, its agents or consultants, including, without limita-tion, letters, correspondence, telegrams, memoranda, notes, records, minutes, contracts, agreements, records or nota-tions of telephone or personal conversations or conferences, interoffice communications, microfilm, bulletins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, invoices, tape recordings and worksheets. The term " document" shall also include copies containing information in addition to that contained in or on the original and all the attachments, i
l appendices, enclosures or documents referred to in any docu-L ments produced pursuant to this Request.
- 5. When used with respect to any act, occur-rence, transaction, statement, request, conduct, communica-
_3 tion, instance, aspect of any event, defect, or omission,
" Identify" means, without limitation, to describe in com-plete detail the event or events constituting such act, the location, the date, the individuals involved, the indivi-duals having knowledge thereof, and the documents referring or relating thereto.
- 6. When used with respect to a document, "Identi-fy" means, without limitation, to state its date, the type of document (e.g., letter, memorandum, telegram, chart, photograph, sound reproduction, et cetera), the author and addressee, the present location and the custodian, and a description of its contents.
- 7. If any of the information contained in the answers to these Interrogatories is not within the personal knowledge of the person signing the Interrogatory, so state and identify each person, document and communication on which he relies for the information contained in answers not solely based on his personal knowledge.
- 8. If you cannot answer any portion of the fol-lowing Interrogatories in full, after exercising diligence to secure the information to do so, so state and answer to the extent possible, specifying your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portions.
- 9. If you claim privilege with respect to any information which is requested by these Interrogatories, specify the privilege claimed, the communication and/or
answer as to which that claim is made, the parties to the communication, the topic discussed in the communication'and the basis for your claim.
- 10. Pursuant to the Licensing Board's " Memorandum and Order" of August 18, 1981, at page 11 paragraph 2 there-of, these Interrogatories are continuing Interrogatories and require supplemental answers if Intervenors obtain further information between the time the answers are served and the time of an initial decision in the proceeding.
INTERROGATORIES
- 1. With reference to Contention lA, (a) identify all instances demonstrating how Edison's quality assurance fonction is not independent of Edison's other departments; and (b) identify and produce all documents which support your answer to this Interrogatory.
- 2. With reference to Contention 8, (a) identify and produce the NRC studies, referred to in the second sentence of the contention, which have been carried out to identify
" accident mechanisms, considered credible, which would lead to uncontrollable accidents and release to the environment of appreciable fractions of a reactor's inventory of radio-active materials;" (b) identify and produce the NRC studies, referred to in the fifth sentence of the contention, "which are not common public knowledge" but have cast doubt upon various conclusions of the Rasmussen report; (c) identify the specific conclusions of the Rasmussen report that have
been questioned by the NRC studies referred to in subpart (b); (d) identify and produce a copy of the " secret NRC study" referred to in the contention as the " unpublished document from Brookhaven National Laboratory;" and (e) identify the General Accounting Office report referred to in the contention.
- 3. With reference to Contention 19, (a) identify the "[r]ecently developed information" referred to in the first sentence thereof; (b) identify the "Information" referred to in the third sentence thereof and which allegedly
, shows that " evacuation regarding Byron in an acceptable time cannot be accomplished;" (c) identify the "other emergency measures" referred to in the eighth sentence of Contention 19; and (d) identify and produce all documents which con-stitute, refer or relate to the "information" identified in your answers to subparts (a) and (b) of this Interrogatory.
- 4. With reference to Contention 22, (a) identify all other plants where there presently exists an " extremely serious problem" of degradation of steam generator tube integrity and describe the specific nature of the " problem";
(b) for each of the plants identified in your response to part (a) of this Interrogatory, identify both the differences and the similarities between the identified plant and the Byron plant, in relation to (i) materials in the secondary system; (ii) secondary water chemistry control, and (iii) operating procedures; (c) identify each fact which would tend to indicate the " serious problem" referred to in the
first sentence of the Contention is "likely to occur at CE's Byron Plant"; (d) identify what would constitute an adequate resolution at Byron of the problem referred to in the last sentence of this Contention; and (e) identify and produce
. all documents which support your answers to parts (a), (b),
(c) and (d) of this Interrogatory.
- 5. With reference to Contention 32, (a) specify what would constitute " adequate qualification methods with which to satisfy the objective of the requirement that all safety-related equipment conform to the requirements estab-lished in IEEE Standard 323-1974"; (b) identify and produce all documents which support your answer to subpart (a) of this Interrogatory; and (c) identify each factual issue which this Contention purports to raise which is not encompassed within Contentions 61, or 77.
- 6. With reference to Contention 34, (a) identify each inadequacy in the provision for overpressure protection at Byron; and (b) identify and produce all documents which support your answers to subpart (a) of this interrogatory.
- 7. With reference to Contention 39, (a) identify each deficiency alleged to exist in the method of evaluating and analyzing radionuclide sediment transport through the hydrosphere in the Environmental Report for Byron; (b) identify the relationship, if any, between the " serious and unresolved problem" referred to in the last sentence of this Contention and the findings required by 10 CFR SS 50.57 (a) (3) (i) and 50.57 (a) (6); and (c) identify and produce all documents
which support your answers to parts (a) and (b) of this Interrogatory.
- 8. With reference to Contention 41, (a) identify each safety related water supply at the Byron Station which is subject to ice build-up; (b) with respect to each safety related water supply identified in response to subpart (a) of this interrogatory, identify the manner in which such Water supply would be affected by ice buildup; (c) identify what would constitute an adequate resolution of the problem referred to in the last sentence of this Contention; and (d) identify and produce all documents which support your answers to parts (a) and (b) of this Interrogatory.
- 9. With reference to Contention 42, (a) identify the "new information on low-level radiation effects" refer-red to in this Contention; and (b) identify and produce all documents which (i) constitute, refer or relate to the "new information" identified in your answer to subpart (a) of this Interrogatory and (ii) support your allegations in Contention 42.
- 10. With reference to Contention 47, (a) specify what is meant by the phrase " seismic design sequence" as used in the first sentence of the Contention; (b) identify all inadequacies in the conservatism of the " seismic design sequence" for the Byron site; (c) identify all measures which would have to be taken to provide an adequately con-servative " seismic design sequence" for the Byron site; (d) identify all factual issues that this Contention purports to
raise which are not raised by Contentions 61, 71 or 77; and (e) identify and produce all documents which support your answers to parts (b), and (c) of this Interrogatory.
- 11. With reference to contention 53, (a) identify the " associated controls" which along with the pressurizer heaters the League believes are necessary to maintain natural circulation at hot standby conditions; (b) identify the
" Staff's resolution" regarding pressurizer heaters and associated controls at Byron; (c) identify the modifications to the Byron design and/or operating procedures which you believe are necessary to provide an " acceptable level of protection" at Byron; and (d) identify and produce all documents which support your answers to subparts (a), (b),
and (c) of this interrogatory.
- 12. With reference to Contention 54, (a) identify the basis for your assertion that proper operation of power-operated relief valves, associated block valves and the instruments and controls for these valves is essential to mitigate the consequences of accidents; (b) describe the manner in which a failure of the power operated relief valves, associated block valves and the instruments and controls for these valves can aggravate a LOCA; and (c) identify and produce all the documents which support your answer to subparts (a) and (b) of this interrogatory.
- 13. With regard to Contention 61, (a) identify the " equipment previously deemed to be environmentally p - - - m v-----m
qualified" which failed during the TMI accident; (b) identi-fy each piece of equipment for use at the Byron station which is identical to equipment identified in response to part (a) of this Interrogatory; (c) identify the " safety-related equipment at Byron", the environmental qualification of which is deficient and the nature of the deficiency; (d) identify and produce all documents which support your answers to subparts (a), (b) and (c) of this Interrogatory; and (e) identify each factual issue which this contention purports to raise which is not raised in Contentions 32, 47, 71 or 77.
- 14. With reference to Contention 62, (a) identify the accident scenarios within the category of " Class 9" accidents which the League believes are credible; and (b) are the accident scenarios referred to in subpart (a) the ones that the League believes must be accommodated within the design basis for Byron.
- 15. With reference to Contention 63, (a) identify specifically those " systems and components presently classified as non-safety related" which you contend should be identified and classified as " components important to safety"; and (b) identify and produce all documents which support your answer to subpart (a) of this Interrogatory.
- 16. With reference to Contention 71, (a) identify each requirement of the general design criteria in Appendix A to 10 CFR Part 50 with which Byron is not in compliance; (b) identify each of the effects of aging and cumulative radiation on the ability of electrical equipment to with-
_lo_
stand seismic stresses which have not been considered for the Byron Station as alleged in the first sentence of the third paragraph of this Contention; (c) identify each factual issue which this Contention purports to encompass which is
. not encompassed within Contentions 47, 61 or 77; (d) identify and produce all documents which support your answers to parts (a) and (b), of this Interrogatory.
- 17. With reference to contention 77, (a) for each component which you believe will be progressively weakened by aging, explain (i) the relationship between aging of that component and the extent to which that component may be weakened as a result of aging and (ii) the extent to which aging will impair the ability of that component to withstand natural for;es such as earthquakes and the accident environ-ment and still perform its safety functions; (b) identify and produce all documents which support your answer to sub-part (a) of this Interrogatory; and (c) identify all factual issues raised in this contention which purport to address new issues not raised in contentions 32, 47, 61 or 71.
- 18. With reference to Contention 106, (a) identify each " serious seismic related site (problem] discovered sub-Lequent to the construction permits herein" referred to in the first sentence of this Contention; (b) identify all of the "recent information" which indicates that the Plum River Fault should be considered a capable fault as alleged in the third sentence of this Contention; (c) identify each "new
fact" referred to in the second to the last sentence of this Contention which calls into serious question the decision at the construction permit phase; and (d) identify and produce all documents which support your answers to parts (a), (b) and (c) of this Interrogatory.
- 19. With reference to Contention 109, 'a) provide page citations to NUREG-0440 where the subject matter of this Contention is addressed; (b) identify the "recent events" which " indicate that [ Applicant] has not complied with" the commitments referenced therein; (c) (i) identify the " commit-ments" which Applicant has not complied with and (ii) state specifically how Applicant has failed to comply with such
" commitments"; and (d) identify and produce all documents which support your answers to subparts (b) and (c) of this Interrogatory.
- 20. With reference to Contention 111, (a) identify the specific " deficiencies in the Byron plant which fail to keep radiation levels as low as achievable"; (b) identify what steps would constitute an adequate resolution of the problem; (c) identify and produce all documents which support your answers to parts (a) and (b) of this Interrogatory.
- 21. With reference to Contention 112, (a) identify the " plant designs" and "new evidence" referred to in part (a) of this Contention; (b) identify the nature of the
( " improved record keeping" referred to in part (b) thereof; (c) identify each improvement to applicant's training called for in part (c) thereof; and (d) identify and produce all documents which support your answers to this Interrogatory, l
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- 22. With reference to each of the above Inter-k rogatories, identify all persons who participated in the ~
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preparation of the answers, or any portion thereof, or wh . s-directly provided information to the League; its counsel or
- agents for use in the preparation of the answers or any portion thereof, to these Interrogatories.
Dated: September 3, 1982 Respectfully submitted, i
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' Alan P. BYelaWski One of the Attorneys for Commonwealth Edison Company Michael I. Miller '
Alan P. Bielawski ISHAM, LINCOLN & BEALE Three First National Plaza Chicago, Illinois 60602 (312) 558-7500 t i 9
., s EU 00pf,{gfc CERTIFICATE OF SERVICE 82, BEE
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The undersigned, one of the attbrneyebfbr Common-
. wealth Edison Company, certifies that on this date he filed two copies (plus the original) of the attached pleading with the Secretary of the Nuclear Regulatory Commission and served a copy of the same on each of the persons at the addresses shown on the attached service list in the manner indicated.
Date: September 3, 1982 I /
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SERVICE LIST COMMONWEALTH EDISON COMPANY -- Byron Station Docket Nos. 50-454 and 50-455
- Morton B. Margulies, Esq.
- Atomic Safety and Licensing Administrative Judge and Chairman Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Secretary Attn: Chief, Docketing and
- Dr. Richard F. Cole Service Section Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Ms. Betty Johnson 1907 Stratford Lane
- *
- Myron M. Cherry, Esq. Rockford, Illinois 61107 Cherry & Flynn Three First National Plaza *
- Ms. Diane Chavez Suite 3700 SAFE Chicago, Illinois 60602 608 Rome Ave.
Rockford, Illinois 61107
- Atomic Safety and Licensing Board Panel
- Dr. Bruce von Zellen U.S. Nuclear Regulatory Commission Department of Biological Sciences Washington, D.C. 20555 Northern Illinois University DeKalb, Illinois 60115
- Chief Hearing Counsel Office of the Executive
- Joseph Gallo, Esq.
Legal Director Isham, Lincoln & Beale U.S. Nuclear Regulatory Commission Suite 840 Washington, D.C. 20555 1120 Connecticut Ave., N.W.
Washington, D.C. 20036
- Dr. A Dixon Callihan Union Carbide Corporation
- Douglass W. Cassel, Jr.
P.O. Box Y Jane Whicher Oak Ridge, Tennessee 37830 BPI Suite 1300
- Mr. Steven C. Goldberg 109 N. Dearborn Ms. Mitzi A. Young Chicago, IL 60602 office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Via U.S. Mail
- Via Express Mail -
- Via Messenger