ML20065H783

Third Set of Interrogatories W/Requests for Production of Documents Re Issue 3 on Adequacy of Applicant QA Program. Proof of Svc Encl.Related Correspondence

ML20065H783
Person / Time
Site:	Perry
Issue date:	09/30/1982
From:	Wilt D SUNFLOWER ALLIANCE, WILT, D.D.
To:	CLEVELAND ELECTRIC ILLUMINATING CO.
References
ISSUANCES-OL, NUDOCS 8210050252
Download: ML20065H783 (12)

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00CKETED dMEC UNITED STATES OF AMERICA NUCLEAR HEGULATORY COMMISSIONi2 GCI-4 A10:55 Before the ' Atomic Safety and Licensinf 56(Ml1,' .

l In the-Matter of )

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CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 COMPANY, 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 APPLICANTS These interrogatories (Third Set) are filed by Sunflower Alliance, Inc. et al. , pursuant to the previous orders of the Atomic Safety and Licensing Board and pursuant to 10 CFR 2.740 b.

These interrogatories are directed to each utility making up the Applicants and pertain to Issue #3 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 interrogatories shall be continuing in nature and the answers must be immediately supplemented ot amended,.

as appropriate, should the applicants, or anyone of them, offer any new or differing information responsive 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 applicants or any one of them, or of the Applicants' attorneys, including, but not limited to, memoranda, corres-pondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings," Documents" and all other writings, shall also mean recordings, copies or video tapes of'any kind.

of documents even though the originals thereof are not in the possession, custody, or control of the Applicants.

For purposes of these interrogatories, a document shall be deemed to be within the " control" of the Applicants or Applicants' .

attorneys if they have ownership, possession, or custody of the document or copy thereof,'or have the right to secure the document or copy thereof from any per' son or public or private entity having physical possession thereof.

When identification of a document is requested, . briefly describe the document i.e., Letter, memorandum,. book, pamphlet, etc., and-state the following information as applicable to the particular M0 40

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h document: name, title, author, number, date of publication and publisher, addresses, date written or approved, and the name and address of the person (s) having possession of the document.

Statement of

Purpose:

The following interrogatories deal with Issue y3 whien has oeen admitted into this proceeding.' The purpose of the interrogatories is to discover information which will show tnat Applicants have an inadequate QA program that has caused or is causing unsafe construction at the Perry plant.

1. Provide a list of all contractors and subcontractors engaged by Applicants to perform any activities pertaining to the construction of the Perry Nuclear Power Plant, Units 1 and

2. (" Activities" includes QA documentation and . audit work as well as physical construction.) Include contractors and subcontractors which were previously engaged by Applicants, as well as those presently so. For each contractor or sub-contractor' listed, briefly describe the area and type of work they are responsible for, give the date on which they ,

became involved with the Perry project, and if their contract has. been terminated, give the date of termination and in-dicate why.

2. Produce a list of all trade unions whose members are in-volved with the Perry project, and for each union listed, give the number and address of the local most directly involved.

3. Provide a list of all persons who have been or are presently employed at the Perry site; for each person listed, give the name of the company emp,loying the person, date on which the person began work at the Perry site, date such employ-ment terminated, name of the union to which the person ,

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belongs, and current or last known address of the person.

4. For any of tne persons listed in response to Interrogatory 3, above, who is or was an inspector, indicate this, and list what areas of the plant the inspector was responsible for.

5. Who is responsible for training workers (laborers, crafts-men, inspectors, etc.) at the plant, CEI, Kaiser, the in-dividual contractor / subcontractor, or the unions? What c.

l assurance is there that workers kre_ properly trained and i

qualified before they are permitted to do work? List all recognized industrial standards (e.g., ANSI) for

! the training of workers which are applicable to PNPP

-and indicate how they are being met.

6. Discuss in detail the specific functions and involvement of Kaiser EnEi neering,at Perry. Discuss how haiser's involve-ment has changed since the inception of construction.

7. Explain how Chapter 17 of the PSAR relates to the Perry

" Corporate Nuclear Quality Assurance Program Manual"; do revisions of the QA manual also result in revisions of the PSAR? List all amendments (and date of same) to Chapter 17 of the PSAR.

8. Produce all Quarterly Performance Analysis Reports (refer to CNQAP Project Administration 0204) from the inception of construction to the present.

9. Have there been any instances of harassment or intimidation of inspectors at PNPP? If so, list every such incident and provide all details.

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j, 10. List every act of vandalism directed at the PNPP structure or components thereof, giving the date, extent, and loca-f tion of each incident, and explain how the vandalism was dis covere d. _

11. Produce all documents pertaining to the firing of a quality control electrical inspector for alleged falsified creden-tials (see PNO-III-82-33).

12. Produce any statements or agreements which Applicants or their' contractors / subcontractors say require workers to j or otherwise affirm sign /which prohibit employees from talking to (or being l

involved with)~the'IEC, news media,. interVB~nors, public l

interest groups, or any other person or entity concerning

, the construction of the Perry plant. .

13. . Produce all nonconformance reports, deviation analysis reports, action requests, corrective action requests, I

audit action requests, field variance authorizations, -

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deficiency reports, field questions, stop work notifica-tions, stop work releases, field disposition instructions, field deviation disposition requests, Perry construction work' authorizations, conditional relenses, and audit re-ports generated at PNPP from the inception of construction to the present.

11 4 . Produce any trend analyses performed at PHPP.

15. Produce the master deficiency list.

16. Have any engineering change notices been generated at PNPP due to the use of equipment that could not meet the original specifications? If so, produce same. ,

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17. Explain the process by which the documents listed $n Interrogatories 13, 14, 15, and 16, above, are generated and closed out. Also explain how these documents are inter-related.

18. Produce all reports filed pursuant to 10 CPR Part 21 and/or 10 CFR 50.55(e) pertaining to construction or components of PNPP, from the inception of construction to present.

19. For each of the contracters/ subcontractors identified in response to Interrogatory 1, above, list all other nuclear

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projects the company has worked on.

~20. List all vendors engaged .by Applicants and/.or .their con-tractors / subcontractors, from the inception of construction to the present, to provide materials or equipment for use in the construction of PNPP. List what types of materials or equipment each vendor is responsible for.

~ 21. Have any vendors been rejected / replaced? If so, explain all details.

22. Do Applicants consider PNPP to be subject to State and local fire and building codes? Explain any provision thereof which Applicants feel does not apply to Perry.

23. If any State or local building and/or fire inspectors have visited the Perry site, list all such visits, by date, giving the nametof_the inspectors.and.any. findings they made.

24. List all local, State, and/or federal agencies (NRC, OSHA) or organizations (ASME, ANSI) having any authority or .

jurisdiction over the construction activities at Perry.

Do such agencies or organizations (other than NRC) send inspectors to the site? If so, outline all such inspections,

[ giving the date, agency / organization, name of inspector,  !

l areas-inspected, and any findings made, i

! 25. Have. any procedures been changed (either Applicants' or contractors ' ) because workers could not comply with the  ;

original procedures? If so, produce these. k

26. What QA procedures and standards do Applicants and their -

contractors have for non-safety related structures and components? Briefly describe the QA program for non-  !

safet.y related work. -

27. Define " safety related" as it relates to PNPP. What criteria are used for classifying structures, equipment, or components as safety related or non-safety related? I Who is responsible for this classification? ,

28.

One of the criticisms made by the Technical Staff Analysis heport on Quality Assurance to the President's Commission on the Accident at Three Mile Island is that the " safety ,  ;

related" classification is too narrow and that quality control for non-safety related equipment is-inadequate.

Do Applicants agree? If not, why notY ,

29. If Applicants object to the consideration of non-safety related items in this proceeding, state why, giving every applicable reference in the Atomic Energy Act, Energy Reorganization Act, NHC regulations, case law and court'.

decisions.

30. Have Applicants verified that Class lE cables pulled by - '

L.K. Comstock prior to the November 1981-stop work order ,

have met specified requirements (as required by the con-firmation of action letter, November 18, 1981 from J. .

Keppler to D.'Davidson)? Define the "specified require-ments." Were all such cables checked, or only a sampling?

Detail any deficiencies discovered and how they were cor-rected.

31. Why does Amendment 8 (dated August 25, 1982) to FSAR page 3.8-95 change the value for density of the bioshield concrete from 190 pcf to 140 pcf and totally delete any reference to the compressive strength of the concrete?

Is this a result of the voids and lightweight concrete discovered in the bioshields?

32. What repair procedures will Applicants use to correct the _

problems with the bioshield concrete? Will these methods result l'n the same density and compressive strength for the concrete as was originally designed? If not, why not?

33. Discuss tne safety implications of the bioshield concrete deficiencies. I.e.,

would this problem accerelate neutron activation of containment equipment, result in higher radia-tion exposures for workers, or aggravate the course of any accident?

34. Has the cause of the bioshield concrete deficiencies been determined? If so, explain in full.

35. Do any other structures at PNPP use the same type of heavy-If so, have weight concrete' as is used in the bioshields?

they been inspected for deficiencies? With what results?

Were the bioshields subject of any inspections.before the 36.

deficiencies were identified? If so, produce all' records pertaining to any such inspection. ~

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37. .In the August 16, 1982 letter from D. Davidson to A. Sc wen

l it is stated that it is now necessary for Applicants to take credit for the str ength the annulus concrete supplies to the containment shell because of " increased loads, methods of applying load calculations, and construction problems." Explain in detail exactly what types of con-struction problems are involved and -how the annulus con-crete will alleviate thair effects on containment strength.

38.- Is this annulus concrete been placed yet in Unit l?

In Unit 2? .If not, when is it expected _to be placed? _

If the concrete has been placed, provide documentation that it meets all applicable criteria. _ . _ .

39. Has the re-examination of the containment weld radiographs (see letter from D. Davidson to J. deppler, May 3,1982) been completed? Describe in detail all results of this 9 re-examination.

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40. If any welds in the containment have to be repaired, explain how this will be done. -Are all such welds still accessible?

Approximately how many welds will need reptir?

41. Explain how the containment weld radiographs became a point of concern in 1982 when the welds were done in 1978? -Why the delay?

l 42. Discuss the safety significance of these rejectable welds if they had not been identified and repaired. Would they weaken the-containment?

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> 43. Has an evaluation of the causes of the welding deficiencies -

in the Unit 1 suppression pool floor plates (see April 23, 1982 letter from D. Davidson to J. Keppler) been completsd?

Describe any such findings. What repairs an4/or corrections

will be made to tne existing welds? What changes to welding procedures will be made to avoid similar problems in the future?

44. Discuss the safety implications of such deficiencies in the suppression pool welds.

45. The April 23, 1982 letter states that "all floor plate welds in this area contain one or more of the above noted defects to some degree." What " area" is referred to? How many welds.are involved? -

46. Has an investigation'been completed concerning the problem with the identification and traceability _of safety related valves (see March 25, 1982 letter from D. Davidson to J.

Keppler)? Describe the results of the investigation; i.e.,

what caused the problem, have all valves been identified /

traced, can the problem be prevented in the future? Generallyc in what plant systems are the valves used?

47. Has repair of the suppression pool clad floor plate weld which was concealed (see March 31, 1982 letter from D.

Davidson to J. Reppler) been completed? Exactly how large was this weld defect? If the attempted concealment had not been reported, would regular inspections have discovered it? Explain why or why not. j

48. Have there been'any instances of drug and/or alcohol use or abuse by workers at the Perry site? If so, provide all details. .

,, .49. Have any workers been fired by Applicants and/or their contractors / subcontractors because of allegations of poor construction or QA practices at Perry.they made to I

the NRC, news media, or any otner person or entity? If so, provide all details.

50. Explain fully any problems or deficiencies concerning Dikkers safety relief valves and how they were corrected.

51. Explain fully any problems or deficiencies concerning the Unit 2 polar crane welds and how they were corrected.

52. NRC Chairman Palladino has stated that quality must be built into a plant and cannot be inspected in. Do Ap:-

plicants agree? If not, why not? Explain how Applicants' QA program ensures that quality is built in.

53. Define specifically the influence of cost and. scheduling considerations on the Perry QA program. E.g., are decisions to write non-conformance reports or to use defective com- ,

ponents or materials "as-is" influencied in any way by cost and scheduling factors?

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54. Document each and every instance in which eouipment and/or materials not meeting specifications were,used "as is."

For each case, name all personnel responsible for this decision to "use as is" and their qualifications, list any instance in which an engineering judgement was used in reaching that decision a) I the basis of that judgement.

55. Provide all documentation concerning corrective actions  ;

takenregardingtheimproperalignmentofthekinit1RPV ~

(see Unresolved Item 440/78-12-05). The following questions relate to the closure of the above unresolved item in the .

NRC inspection report and related correspondence dated November 21, 1979.

(a) On what previone experience was the "use as is" deci-

sion made by GE safety / reliability personnel based?

(b) Was this decision based on any engineering judgement?

If so, provide the basis of that judgement.

(c) Give the names of the GE personnel responsible for that decision, and list their professional qualifica-tions.

56. Describe in detail the " fabrication deficiencies" which caused rejection of service water intake structures, as documented in NHC Inspection Report 50'-440/80-09, p. 4.

(a) Were any design changes amde as a result of this

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problem?

(b) Provide the names of all personnel involved in this decision and give their qualifications.

(c) Was this decision based on any engineering judgement?

If so, give the basis of that judgement.

57. Have Applicants determined whether any pip 3.ng subassemblies .

from either Associated Piping and Engineering or ITT Grinnell Industrial Piping are used at Perry? (IE Bulletin 82-01 describes practices by these firms involving the alteration of radiographs.) If such components are being used at Perry, what corrective actions are being taken?

58. Have Applicants determined whether main control panels at Perry have any weld defects (see IE Information Notice 82-34)? What actions are being taken to assess, and if

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necessary, to correct this problem?

59. Produce all-responses to and notes, memoranda, or other documents pertaining to NRC IE Bulletins, Circulars, and'

Information Notices.

60. Have Applicants determined wnether any electrical penetra-tion assemblies supplied by the Bunker Ramo Corporation have been used at Perry (see IE Information Notice 82-40)?

What actions are being taken to assess, and if necessary, to correct this problem?

61. Describe in detail Applicants' procedures for evaluating of Circulars, the significancegand responding to NRC IE Bulletins, and Information Notices.

62. Define specifically the role of engineering judgement in the Ferry QA program. E.g., are decisions to write non-conformance reports or to use "as is" defective components or materials based on engineering. judgement? Upon "what are such judgements based? ,

s Respectfully submitted, ,

$4// $0 Daniel D. WQ.t, E1fq.

[ Attorney for Sunflower Alliance P.O. Box 08159 Cleveland, OH 44108~

(216) 249-8777 PROOF OF SERVICE -

This is certify t at a copy of this Third Set of Interro atories has bee ent oa persons on the Service List on this' day of p O. .

, 1982.

v i/d (

aniel D. Wil6 Esq.

cA Attorney for Sunflower Alliano O

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