ML20071L889

Interrogatories & Request for Production of Documents,Second Set.Certificate of Svc Encl.Related Correspondence

ML20071L889
Person / Time
Site:	Perry
Issue date:	09/22/1982
From:	Willmore R CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	OHIO CITIZENS FOR RESPONSIBLE ENERGY
References
NUDOCS 8209240157
Download: ML20071L889 (13)

Text

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1. Es@ED September 22, Iggy SEP23 pjgg, Crrm-UNITED STATES OF AMERICA UJA$ff[{":W'tr

~,l NUCLEAR REGULATORY COMMISSION Before The Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR OHIO CITIZENS FOR RESPONSIBLE ENERGY (SECOND SET)

These Interrogatories and Request for Production of Documents are filed by Applicants pursuant to the Licensing Board's Special Prehearing Conference Memorandum and Order, LBP-81-24, 14 N.R.C. 175 (1981), the Memorandum and Order (Concerning Scheduling) dated September 16, 1982, and the Nuclear Regulatory Commission's Rules of Practice. The Interrogatories and Document Requests are directed toward Intervenor Ohio Citizens for Safe Energy ("OCRE") and pertain to Issues No. 8 (hydrogen control) and No. 9 (polymer degrada-tion).

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The Interrogatories submitted herein are filed pursuant to 10 C.F.R. 5 2.740b, which requires that the Interrogatories be answered separately and fully in writing under oath or affirma-tion, within 14 days after service. The Interrogatories are intended to be continuing in nature and the answers must be immediately supplemented or amended, as appropriate, should the OCRE obtain any new or different information responsive to the Interrogatories.

The Request for Production of Documents is filed pursuant to 10 C.F.R. 5 2.741, which requires that OCRE produce and either furnish copies of or permit Applicant,s to inspect and copy any documents responsive to the request and which are in the possession, custody or control of OCRE. The Request for Production of Documents also is continuing in nature and OCRE must produce immediately any additonal documents it obtains which are responsive to the Request. .

l For purposes of these Interrogatories, the term "docu-ment (s)" means all writings and records of every type in the possession, control or custody of OCRE, including, but not limited to, memoranda, correspondence, reports, surveys, i

tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings or recordings of any kind. " Document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, i

i custody, or control of OCRE.

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For purposes of these Interrogatories, a document shall be

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deemed to be within OCRE's " control" if OCRE has ownership, possession or custody of the document or copy thereof, or has the right to secure the document or copy thereof from any person or public or private entity having phyaical 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 appli-cable to the particular document: name, title, number, author, date of publication and publisher, addressee, date written or t

approved, and the name and address of the person (s) having possession of the document.

The purpose of these Interrogatories and Request for Production of Documents is to clarify the scope of Issues No. 8 and No. 9, and to ascertain the factual bases which support each element of the Issues s'o that Applicants adequately can prepare their response to the Issues.

INTERROGATORIES Issue No. 8 (Hydrogen Control)

1. State the name, present or last known address, present or last known employer, and educational and profes-sional qualifications of each person known to you to have first-hand knowledge of the facts alleged in Issue No. 8.

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2. (a) State the name, title, employer and educational and professional qualifications of each person you intend to call as a witness on Issue No. 8.

(b) State the subject matter on which each such person is expected to testify.

(c) State the substance of the facts and opinions to which each such person is expected to testify.

(d) State a summary of the grounds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions.

3. Identify all documents in your possession, custody or control, including all relevant page citations, pertaining to the subject matter of Issue No. 8.

4. Identify all documents which you intend to offer as exhibits during this proceeding to support Issue No. 8 or which you intend to use during your cross-examination of witnesses presented by Applicants and/or the NRC Staff on Issue No. 8.

5. Describe in detail what you understand to be a TMI-2 type accident scenario for a BWR6/ Mark III such as Perry Nuclear Power Plant. Specifically, describe in detail each step of the accident scenario (beginning with the earliest initiating event), the time into the accident each step occurs (beginning with t=O), and the rate and quantity of hydrogen production during the course of the accident. If you assume any operator error, describe such operator error in detail.

6. Describe in detail your bases for believing that the accident scenario described in response to Interrogatory #5, supra, is a credible accident scenario. In this regard, state your understanding of the meaning of the term " credible accident scenario."

7. Describe in detail the off-site radiation doses resulting from the accident scenario described in response to Interrogatory #5, supra. Also describe in detail the bases for your answer.

8. Demonstrate that the off-site radiation doses described in response to Interrogatory #7, supra, are in exc'ess of 10 C.F.R. Part 100 guideline values.

9. With regard to your responses to Interrogatories #5,

1. 6, #7 and #8, supra:

(a) Identify all documents you have relied upon in answering the Interrogatories.

(b) State the name, present or last known address, present or last known employer, and education and professional qualifications of each person known to you to have first-hand l knowledge of the factual basis of your answers.

10. With regard to the use of igniters as a hydrogen control system (including containment strength and equipment survivability):

(a) Identify all related documents in your posses-sion or control.

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(b) State the name, present or last known address, present or last known employer, and education and professional qualifications of each person who has provided you with any related information or expert advice or knowledge.

(c) State whether you believe that igniters will safely control hydrogen generated by the accident scenario described in response to Interrogatory #5, supra. If you do not believe such to be the case, describe in detail the bases c

for your conclusion, including all do'uments and persons relied upon in forming that conclusion.

11. State whether you believe that inerting will safely control hydrogen generated by the accident scenario described .

in response to Interrogatory #5, supra. If you do not believe such to be the case, describe in detail the bases for your conclusion, including all documents and persons relied upon in i

forming that conclusion.

Issue No. 9 (Polymer Degradation)

12. State the name, present or last known address, present or last known employer, and educational and profes-i sional qualifications of each person known to you to have l

[ first-hand knowledge of the facts alleged in Issue No. 9.

13. (a) State the name, title, employer and educational and professional qualifications of each person you intend to call as a witness on Issue No. 9.

(b) State the subject matter on which each such person is expected to testify.

(c) State the substance of the facts and opinions to which each such person is expected to testify.

(d) State a summary of the grounds for such opin-ions, and identify all documents upon which such person relies to substantiate such opinions.

14. Identify all documents in your possession, custody or control, including all relevant page citations, pertaining to the subject matter of Issue No. 9.

15. Identify all documents which you intend to offer as exhibits during this proceeding to support Issue No. 9 or which you intend to use during your cross-examination of witnesses presented by Applicants and/or the NRC Staff on Issue No. 9.

16. Identify every polymer (by its trade or common name) that you believe " degrade [s] more rapidly when exposed to lower levels of radiation for long periods of time than when exposed to high levels for shorter periods." (OCRE Motion for Leave to File Contention 19.) As to each such polymer, describe in detail the bases for your conclusion, including the reasons for identifying the polymer.

17. Identify all equipment and components in Perry Nuclear Power Plant which you believe to be potentially dangerous as a result of the degradation effect described in Interrogatory #16, supra. As to each such item, describe in detail the bases for your conclusion, including the reasons for identifying the item.

18. Identify all locations in Perry Nuclear Power Plant which you believe to be potentially dangerous as a result of the degradation effect described in Interrogatory #16, supra.

As to each such location, describe in detail the bases for your conclusion, including the reasons for identifying the location.

19. State the radiation level above which you believe the degradation effect described in Interrogatory #16,. supra, causes unsafe conditions to occur. Describe in detail the bases for your conclusion.

20. Identify all areas within Perry Nuclear Power Plant, by radiation zone, in which the radiation level during normal I

operating conditions reaches the level above which you believe the degradation effect described in Interrogatory #16, supra, causes unsafe conditions to occur. As to each area (radiation zone), describe in detail the bases for your conclusion, including the reasons for identifying the area (radiation zone).

21. Identify all areas within Perry Nuclear Power Plant, by radiation zone, in which the radiation level during accident conditions reaches the level above which you believe the degradation effect described in Interrogatory #16, supra, causes unsafe conditions to occur. As to each area (radiation zone), describe in detail the bases for your conclusion, including the reasons for identifying the area (radiation zone). Also identify each accident condition assumed in answering the Interrogatory, and which areas (radiation zones) are relevant as to that condition.

22. With regard to your responses to Interrogatories #16,

1. 17, #18, #19, #20 and #21, supra:

(a) Identify all documents you have relied upon in answering the interrogatories.

(b) State the name, present or last known address, present or last known employer, and educational and profes-sional qualifications of each person known to you to have first-hand knowledge of the factual bases of your answers.

General Interrogatories Pertaining to Issues No. 8 and No. 9

23. State the name, title or position, address, employer, and educational and professional qualifications of each person who provided information used in preparing responses to any of the foregoing Interrogatories.

24. For each person identified in response to the Inter-rogatory #23, supra, state the number of the Interrogatories for which information was supplied.

25. State the name, title or position, address, employer, and educational and professional qualifications of each person who searched for documents in order to respond to any of the foregoing requests for identification of dcouments.

26. For each person identified in response to Interroga-tory #25, supra, state the numbers of the Interrogatories for which the search was conducted and the location where the search was conducted.

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27. Identify any written or recorded statement of any individual pertaining to the subject matter of Issues No. 8 and No. 9, not previously identified in response to the foregoing Interrogatories.

REQUEST FOR PRODUCTION OF DOCUMENTS Applicants request that OCRE respond in writing to the following request for production of documents and produce the original or best copy'of each of the documents requested below, at the office of Lawrence O. Beck at The Cleveland Electric Illuminating Company, or at a place mutually convenient to the parties.

The term " document (s)" means all writings and records of every type in the possession, control or custody of OCRE including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings, and all other writings or recordings of any kind. " Document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of OCRE.

A document shall be deemed to be within the " control" of OCRE if it has ownership, possession or custody of the document or copy thereof, or has the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.

Applicants request that OCRE produce each and every document identified or described in the answers to the ab6ve Interrogatories 1 through 27.

Respectfully submitted, f

SHAW, PITTMAN, POTTS & TROWBRIDGE By: -

Jay E. Silberg, P.C.

Robert L. Willmore Counsel for Applicants 1800 M Street, N.W.

I Washington, D.C. 20036 t (202) 822-1000 Dated: September 22, 1982 J

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Interrogatories and Request For Production of Documents To Intervenor Ohio Citizens For Responsible Energy (Second Set) ,"

i were served by deposit in the U.S. Mail, First Class, postage prepaid, this 22nd day of September 1982, to all those on the attached Service List.

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Robert L. Willmore Dated: September 22, 1982 r - - - ' - - * ' ' - - - '- ' - ' * ' " ~?' ' - - - " - " " -'

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440

' ILLUMINATING COMPANY, et al. ) . 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2 )

SERVICE LIST ,

Peter B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office'of the Secretary U.S. Nuclear Regulatory Commission U '. S . Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555

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Mr. Frederick J. Shon -pStech

'en H. . Lewis , Esduire Atomic Safety and Licensing Board Offich'8f the Executive U.S. Nuclear Regulatory Commission Legal Director Wahsington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appea'l Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C. 20555 Mentor, Ohio 44060 Dr. John H. Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing P. O. Box 08159 Appeal Board Cleveland, Ohio 44108 U.S. Nuclear Regulatory Commissica Washington, D.C. 20555 Donald.T. Ezzone, Esquire Assistant Prosecuting Attorney Gary-J. Edles, Esquire Lake County Administration Center Atomic Sa#ety and Licensin9 105 center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John G. Cardinal, Esquire Prosecuting Attorney Atomic Safety and Licensing Ashtabula County Courthouse Board Panel Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Terry Lodge, Esquire 915 Spitzer Building Toledo, Ohio 43604