ML20065H551

Third Set of Interrogatories Re Issue 3 & Requests for Production of Documents.Proof of Svc Encl.Related Correspondence

ML20065H551
Person / Time
Site:	Perry
Issue date:	09/30/1982
From:	Wilt D SUNFLOWER ALLIANCE, WILT, D.D.
To:	NRC
References
ISSUANCES-OL, NUDOCS 8210050173
Download: ML20065H551 (7)

Text

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DOCKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'82 OCT -4 N0 :55 Before the Atomic Safety and Licensine Boar:dy-Q;, -

iw ,f In the Matter of ).

)

CLEVELAND ELECTRIC ILLUMINATING ). ~ Docket Nos. 50-440 COMPA NY, et al.

) 50-441

) (OL)

(Perry Nuclear Power Plant, )

Units 1 and ,2) ) -

SUNFLOWER ALLIANCE et al. THIRD SET OF INTERROGATORIES (WITH REQUESTS FOR PRODUCTION OF DOCUMENTS)-TO NR These interrogatories (Third Set) are filed by Sunflower Al-liance Inc., et al., pursuant to the previous orders of the Atomic Safety and Licensing Board and pursuant to 10 CFR 2.740 b.

Tnese interrogatories are directed to the NRC Staff and pertain to Issue #3 which is admitted in this proceeding.

It is required that each interrogatory be answered separately and fully in writing under oath or affirmation, within 14 days of service.

Tnese interroEatories shall be continuing in nature andappropriate, as the answers must be immediately supplemented or amended, information responsiveshould the Staff offer any new or differing to the interrogatories.

For purposes of these interrogatories the term " documents" means all records of every type in the possession, control, or custody of the Staff or of the Staff's attorneys, including, but not limited to, memoranda, correspondence, reports, surveys, tabula-tions, charts, books, pamphlets, photographs, maps, bulletins, minutes, and all other notes, speeches, articles, transcripts, voice recordings, writings, recordings or video tapes of any kind.

"originals Documents" shall also mean copies of documents even though the thereof are not in the possession, custody, or con-trol of the Staff. -

For purposes of these interrogatories, a document shall be deemed to De within the " control" of the Staff or Staff's attorneys if they have ownership, possession, or custody of the document or copy thereof physical from any possession person or public or private entity having thereof.

When identification the document, of a document is requested, briefly describe i.e., letter, memorandum, book, pamphle t, etc., and state the following information as applicable to the particular document: name, title, number, author, date of publication and 8210050173 820930 PDR ADOCK 05000440 G

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publisher, addresses, date written or approved, and the name and address of tne person (s) having possession of the document.

Statement of

Purpose:

The following interrogatories deal with lasue #3 wnich r$s been admitted into this proceeding. The purpose of the interrogatories is to discover information which will show that Applicants have an inadequate QA program that has caused or is causing unsafe construction at the Perry plant.

1. Produce tht SALP reports issued in 1980 and 1982 concerning the Perry Nuclear Power Plant, and produce also any notes, memoranda, or correspondence upon which the reports were based.

2. Produce the findings (and any notes, memoranda, or corres-pondence) made by the NRC Special Assessment Team for Region III in their recent inspection of Perry.

3. Is it the NRC's practice to make unannounced inspections at nuclear facilities? List every unannounced inspection made at the Perry site, and indicate whether the findin5s made then were any different from those made during announc~ed inspections.

4. Has the NRC ever requested of Applicants the information detailed in 10 CFR 50.54(f)? If so, produce all such requests and Applicants' responses.

5. What type of action or response does the NRC require of applicants / licensees for each of the following: IE Bul-letins; IE Circulars; IE Information Notices.

6. Does the NRC consider Applicants ' methods of evaulating.

and responding to the 3 IE publications above to be adequate? Outline any deficiencies.

7. Explain why, since 1981, very few IE Bulletins an'd Circulars were issued and most items of interest are now distributed through Information Notices.

8. Does the Staff consider repaired welds and patched concrete ,

to oe as good as if the work were done properly the first time? Explain why or why not.

9. Describe in detail the Staff's procedures for closing out open items identified in inspection reports, e.g., non-compliances and resolved items. Does the NRC rely on the Applicants' assessment, or are actual inspections made by the NRC to ensure the proper resolution of the problem?

10. To what extent is- engineering judgement used-in NRC in-spections and in the closing out of open items? Upon what is this judgement based? .

11. Approximately how much actua. construction work is seen by NRC inspectors? How much of the inspector's time is spent in paperwork review?

12. To what extent is the NRC's inspection program based'on voluntary reporting of violations by the applicant / contractor?

13. To what oxtent is the NRC's inspection program based on allega. ions made by workers at nuclear sites?

14. For every Nhc inspector who has been at PNPP, provide:

(a) name and business address and phone number (b) education, experience, and professional qualifications.

(c) date when the inspector was first employed by the NBC, and if employment was terminated, indicate why.

, 15. Produce any trend analyses performed by the Nhc concerning QA performance at PNPP.

16. List all violations identified at PNPP, from the inception I

of construction to the present, and list their severity and specific section of Appendix B to 10 CFR Part 50 with which Applicants were in non-compliance.

17.

Has any monetary penalty ever been imposed on Applicants for QA violations at PNPP7 If so, provide all details.

18. Is Applicants' QA program approved by the NRC? Explain how the NRC evaluated the QA program. Describe any de-ficiencies which the NRC has identified in Applicants' construction QA program. ~

18. For problems not identified with the 1978 work stoppage, was any work redone at PNPP?

If so, provide ~com~plete details, including date, specific location in the plant, relevant inspection reports and other documents, reason for reCaing the work, and evidence of the satisfactory completion of the work.

19.

In the Staff's response to Sunflower's Interrogatory 6 ,

(First Set) it is stated that, as a result of the 1978 work stoppage, no structural or erection work was redone at the plant.

What, if any, other type of work was redone?

20. Set forth the number of times (other than those associated with the 1978 work stoppaSe) the NRC has received complaints or allegations from employees of Applicants or their contractors concerning a failure of the Perry QA program. For each such occurrence, state:

(a) date of the complaint or alleEation -

(b) nature of complaint and specific area of construction involved (c) NRC response to the complaint.

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21. Is the Nhc aware.of any Perry plant worker who was or may have been fired because of making allegations to the NRC, news media, or any other person or entity?

If so, provide all details.

22. Is the Nhc aware of any instances of harassment or in-timidation of inspectors at Perry? If so, list every such incident and provide all details.

23. Is the NRC aware of instances of drug and/or alcohol use or abuse by workers on the Perry site? If so, provide all details. What procedures should be implemented by Applicants to avoid'auch p'roblems? Have Applicants donc so?

24. List every act of vandalism known to the NRC directed at the PNPP structure of components thereof. Does the NRC have any measures Applicants should. implement to avoid such incidents? If so, have Applicants done so? -

25. Does the NRC consider PNPP to be subject to State and

. local fire and building codes? If not, why not?

26. List all local, State, federal or independent agencies or organizations having jurisdiction or authority over the construction activities at PNPP. Do such organizatiors routinely communicate with the NRC concerning possible QA problems at Perry? If so, detai,1 all such communication, giving also the NRC's response.

27. What inspection programs exist for the NRC inspection of non-safety related equipment at nuclear facilities?

28. Define " safety related". What criteria are used for classifying.

structures, equipment, or components as safety related or non,-safety related? Who is responsible for this clhasifica-tion, the NRC or Applicants?

29.

One of the criticisms made by the Technical Staff Analysis Report on Quality Assurance to the President's Commission on the Accident at Three Mile Island le that " safety rel'ated" is too narrow a classification and that quality control for non-safety related equipment is inadequate. Does the NRC agrpe? If not, why not? What-improvements have been made in this situation by the NRC since the Report was issued?

30. Define specifically the influence of cost and scheduling considerations on the NRC's inspection program. I.e.,

are decisions to cite applicants / licensees influenced in any way by the utility's financial situation or impending schedules, or are Nhc inspections ever curtailed due to lack of time or allocated funds by the NRC?

31. NRC Chairman Palladino has stated that quality must be built into a plant and cannot be inspected in. Explain how the NRC's inspection program meets this goal.

32. List all items (unresolved, non-compliance, responses to IE Bulletins, Circulars, or Information Notices, and occurrences reportable under 10 CFR Part 21 or 10 CFR 50.55(e)) concerning the Perry plant or any subpart thereof

. whien still have open status. Provide the following infor-mation:

(a) when the item was identified (b) nature of the item, system of the plant affected, and location in the plant

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( c ) Applicants ' efforts to correct the situation (d) why the item is still open.

33. Are there any QA problems or violations which seem repet-itive at Perry? If so, d-scribe these.

34. Are there any contractors / subcontractors at Perry which have a continuin6 history of QA deficiencies? If so, provide all details.

35. List sll documents relied upon in preparing these responses, and list eli persons responsible for -these responses.

Respe ctfully -submitted, I hw .

Dpnrel D. Wilti Esq.

Attorney for Sunflower Alliance P.O. Box 08159 Cleveland, OH 44108 (216) 249-8777 .

i PROOF OF SERVICE This is certify.that a copy of this Third Set of Interrogatories has oee senJteo gJ1 persons on the Service List on this C? C) day of j/?,b7,mVWA , , 1983.

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1 0 0 d' D niel D. Wily, Erq.

/lhf torney for % nflower Alliance

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