ML20077P291
| ML20077P291 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/08/1983 |
| From: | Carr A DUKE POWER CO. |
| To: | PALMETTO ALLIANCE |
| References | |
| NUDOCS 8309130334 | |
| Download: ML20077P291 (14) | |
Text
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UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION
S NE BEFORE THE ATOMIC SAFETY AND LICENSING BOARR SEP 12 Pi252 w
In the Matter of
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DUKE POWER COMPANY, et al.
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Docket Nos.
50-413'
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50-414 (Catawba Nuclear Station,
)
Units I and 2)
)
APPLICANTS' SUPPLEMENTAL RESPONSES TO PALMETTO ALLIANCE'S INTERROGATORIES AND REQUESTS TO PRODUCE RELATING TO CONTENTION 6 Pursu' ant to 10' CFR 92.740(e), Applicants supplement their responses to Palmetto Alliance's Interrogatories and Request to prodace as follows:
Palmetto Alliance First Set of Interrogatories and Requests to Produce (AprH 21, 1982)
GENERAL INTERROGATORIES 2.
Please identify each and every person whom 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:
a.
State the substance of the facts and opinions to which the witness is expected to testify; b.
Give a summary of the grounds for each opinion; and c.
Describe the witness' educational and professional background.
Lewis E. Zwissler
- Applicants may offer.the testimony of Lewis E.
Zwissler of Management Analysis Company as an expert witness in the area of quality assurance. Mr.'
Zwissler will testify about his review of the Welding Inspector Task Force investigation and will offer testimony on his opinions of the Task Force
' methodology, findings, and recommendations.
The grounds for Mr. Zwissler's testimony and a description of his educational and professional background are set forth in his Reports to Duke Power Company, which were provided to Palmetto Alliance during discovery on this contention.
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W. H. Owen -
- Applicants may offer the testimony of Mr.
W. H. Owen.
Mr. Owen is an Executive Vice-President with Duke Power Company and is responsible for the company's Construction, Design Engineering, and Quality Assurance Departments.
Mr. Owen will testify about the constriaction and design of the Catawba Nuclear Station, the-pay reclassification and resulting recourses of welding inspectors at Catawba, and the task force investigations of the concerns expressed by welding inspectors.
The substance of the facts and
. opinions to which Mr. Owen is expected to testify and a description of his educational and professional background are set forth in the transcript of his deposition taken by Palmetto Alliance.
J. - R. Wells Applicants may offer. the testimony of Mr.
J.
R.
Wells.
Mr. Wells is the a
former Quality Assurance Manager for Duke Power Company, and is expected to testify about the establishment and organization of the Quality Assurance Department and the pay reclassification and resulting recourse of welding inspectors at Catawba.
The substance of the facts and opinions to which Mr.
Wells is. expected to testify and - a description of his educational and professional background are set forth in the transcript of his deposition taken by Palmetto Alliance.
G. W. Grier Applicants may offer the testimony of Mr.
G. W.
Grier.
Mr. Grier is the Corporate Quality Assurance Manager for Duke Power Company and is expected
- to testify about the Quality Assurance Program, the pay t*aclassification and resulting' pay recourse of welding inspectors at Catawba, the task force investigations of 'the concerns expressed by welding inspectors, implementation 2-
a t
c of thecrecommendations made[by the various task forces which investigated the concerns cexpressed by _ welding inspectors, and the - Quality Assurance management h esponse ts the concerns expressed by welding inspectors.
The
- substance of the facts and opinions to which Mr. Grier is expected to testify and' a description of his' educational and professional background are set forth in the transcript cf his deposition taken by Palmetto Alliance.
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' B. Gail - Addis
[
. Appli5nts may offer : the. testimony of Ms.
B.
Gail Addis.
Ms. Addis is expedted. to testify concerning her role ~ -in the pay recourse processed by b
welding-inspectors at. Catawba.
The substance of the facts and opinions to
-.which Ms. Addis is expected to testify and a description of her educational and professional background 'are set forth in - the transcript of her deposition taken by. Palmetto Alliance.
- T. C. - McMeekin i
. -Applicants may offer the testimony of Mr. T. 'C. McMeekin. Mr. McMeekin was a qmember of. the initial task force appointed to investigate the - concerns expressed. by.. welding inspectors at Catawba.
Mr. McMeekin will testify concerning the investiga~tions of his task force, including their findings and e
recommendations.
The substance,of the facts and ' opinions to which. Mr.
McMeekintis-expected to testify are set forth_ in the Report of his task force
~
- which has been provided to Palmetto Alliance during discovery. Mr. McMeekin has a Bachelor of Science degree -in electrical engineering from Pennsylvania
. State University.and is a registered professional engineer.
He has more than eighteen years 'of experience in nuclear operations : and design, and is presently. involved in the control and instrumentation design section of the Duke Power Company Design Engineering Department. a.
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.A. Parks Cobb
. Ap}51icants may offer the testimony of Mr. A. Parks Cobb.
Mr. Cobb was the
' Chairman of' the Technical Task. Force appointed to investigate the technical
- concerns expressed by welding inspectors at Catawba.
Mr. Cobb will testify concerning the work of the Technical Task Force, their fin: lings, conclusions, and recommendations.
The substance of the facts and opinions to which Mr.
Cobb - is expected to. testify are set forth in the Reporte issued by the
- Technical Task Force, which have been provided to Palmetto Alliance during discovery.
Mr. Cobb is. a mechanical engineer with almost twenty years experience.
A summary of Mr. Cobb's educational and professional experience, as well as a similar summary for the other members of the Technical Task Force, is contained In the Report issued by Mr. Lewis E.
Zwissler of the
' Management-Analysis Company, which has been provided to Palmetto Alliance during discovery.
' C. N. Alexander Applicants may offer the testimony of Mr. C. N. Alexander.
Mr. Alexander was. the Chairman of the Non Technical Task Force appointed to inves'tigate the 1
non technical concerns of the welding inspectors at Catawba.
Mr. Alexander will testify concerning ' his review of. the concerns, and the findings and recommendations made by his task, force, as' well as implementation of those recommendations.
The substance of the facts and opinions to which Mr.
. Alexan' der - is ' expected to' testify are contained in his Report and correspondence with Duke Power Company management, which have been made available 'to Palmetto' Alliance during ' discovery.
In addition, this information concerning th'e substance of the facts Mr. Alexander will testify to, as well as a description of his educational and professional background, are set forth in the transcript of his deposition taken by Palmetto Alliance.,
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L. R. - Davison and R. A. Morgan Applicants roay offer the testimony of Mr. L.
R.
Davison and Mr. R.
A.
Morgan.
Mr. Davison is presently QA Manager of Projects for Duke Power
- Company.
Mr. Morgan is presently the Senior Quality Assurance Engineer at the Catawba site.
Both Mr. Davison. and Mr. Morgan are expected to testify concerning the Quality Assurance Program at Catawba, the pay reclassification and the resulting recourse of welding inspectcrs, the concerns expressed by welding inspectors, the task force investigations of those concerns, and implenientation of the recommendations of the task forces at Catawba, including procedure revisions and other changes in the QA Program. The substance of the facts and opinions to which Mr. Davison and Mr. Morgan are expected to
- testify, as well as' a description of their educational and professional
~ backgrounds are set forth in the transcripts of their respective depositions taken by Palm'etto Alliance.
J. C. Shropshire, A. E. Allum, and C. R. Baldwin Applicants may offer the testimony of Mr. J. C. Shropshire, Mr. A. E. Allum,
. and Mr.
C.
R.
Baldwin.
Mr. Shropshire is an engineer in the Quality l
l Assurance Program at Catawba, and is responsible for QA engineering in the mechanical, welding, and non destructive examination areas.
Mr. Allum is a Technical. Supervisor in Quality, Assurance at Catawba and has had responsibility for non destructive examination,
- welding, and mechanical inspection.
Mr. Baldwin is a Technical Supervisor in Quality Assurance at
' Catawba, and has been responsible for non destructive examination and welding inspection.
Each of these witnesses will testify concerning the Quality Assurance Program at Catawba, the concerns expressed by the welding inspectors', and the implementation of the recommendations of the task forces.
i The substance of the facts and opinions to which each will testify, as well as a h
description of their educatiorial and professional backgrounds are set forth in the transcripts of their respective depositions taken by Palmetto Alliance.
Welding Inspectors Applicants may call - as witnesses welding inspectors and supervisors who worked at Catawba at the time of the pay reclassification and resulting pay recourse, and at the time of the expressior. of technical and non technical
, concerns by welding inspectors.
A definite determination as to which
-inspectors and supervisors will be called as w.stnesses at the hearing has not been made, and in all likelihood will not be made until close to the time for submission of written testimony as set by the Board. When such determination has been made, this Ihterrogatory Response will be promptly updated.
SPECIFIC INTERROGATORIES During.the course.of discovery, Applicants made various documents available to Palmetto Alliance for inspection and copying at the offices of Duke Power Company in Charlotte, North Carolina.
Applicants made these documents available in a room in the Legal Department during the entire course of discovery as an accommodation to the intervenors, and at the close of discovery, Applicants -advised Palmetto Alliance that they would no longer maintain a. document room for the inspection and copying of these discovery documents.
' Palmetto has requested that the Board require that these
. discovery documents be made available in a similar manner for their continued inspection and review.
The Board has indicated that the parties 'should attempt to. resolve this matter without~ the necessity of-a Board ruling.
Applicants indicated earlier to Palmetto Alliance that, although the document room would be closed at,
? Applicants' offices, Applican'ts would continue to copy and mail to Palmetto Alliance -any documents identified and requested by Palmetto Alliance which were made a"vailable during discovery under the 'same terms and conditions as existed while discovery remained open.
Applicants remain willing to provide to Palmetto Alliance any documents that were made available during discovery as
- ' long as Palmetto specifically identifies the documents, and pays five cents per j
page for copying-as previously agreed between Applicanb and Palmetto Alliance.
4 Documents. identified in this supplemental response to intervenors discovery requests will be provided to Palmetto Alliance if requested.
e
-Interrogatory 3 In response to this interrogatory, Applicants made available the Duke Power
- Company Topical Report.
Duke _ Power Company has prepared a -proposed amendment to' the Topical Report which is currently being submitted to NRC for approval.
This proposed amendment is available if requested-by Palmetto Alliance.
4 Interrogatories 12 and 13 In' response to these interrogatories, Applicants made available for' inspection and copying Significant Deficiency Reports which list deficiencies as defined in 10 - CFR 950-55(e).
Applicants supplement their earlier response by adding report No. 83-09 to the reports previously identified.
In accordance with the practice which Applicants have. followed. since November of 1981, Palmetto Alliance was mailed a. copy of this report.
(See letter dated Septimber,2, -1983 from H.'B. Tucker to James P. O'Reilly of the NRC.)
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Interrogatory 14 This interrogatory sought identification of audits conducted pursuant to 10 CFR Part Sb, Appendix B, Criteria XVIII which reflected deficiencies.
In response to this interrogatory, Applicants identified and made available for inspection and copying all departmental audits pursuant to 10 CFR Part 50 Ap;.endix B, Criterion XVIII of design and construction at Catawba which reflected deficiencies.
Such list was current through December 1982.
This list' of audits is supplemented by those listed below, which will be provided to Palmetto Alliance if requested.
- 1982 Corporate Audit
NP-83-1 (CN)
- CD-82-10 (CN)
- CD-82-13,
(CN)
- CD-82-15 (CN)
- CD-82-17 (CN)
- CD-82-18 (CN)
- CD-83-1 (CN)
- CD-83-3 (CN)
- CD-83-7 (CN)
- CD-83-9 (CN)
- DE-82-5 (CE)
- DE-82-6 (ED)
- DE-82-7 (MD)
- DE-82-9 (PM)
DE-83-1 (PM)
- DE-83-2 (GS)
- DE-83-4 (ED)
- DE-83-5 (MD)
- Indicates audits which were identified in Applicants' earlier Responses as open and are now closed.
- Indicates audits which are still open.
Interrogatory 21 This interrogatory reque'sted identification of NRC Regulatory staff inspection reports and files regarding Catawba.
In response to this interrogatory, Applicants identified and made available for inspection and copying the NRC Inspection Reports for Catawba.
Applicants supplement their earlier response to include the reports identified below. This listing includes all 1983 reports.
The NRC Inspection Reports for 1983 which were available before the close of discovery were placed in Applicants' document room prior to the close of discovery.
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9 413-414/83-01 413/83-13 413-414/83-02 413/83-14 414/83-13 413-414/83-03 413/83-15 413-414/83-04 414/83-14 413-414/S3-05 413/83-16 414/83-15 413-414/03-06 413/83-17 413-414/83-07 414/83-16 413-414/83-08 413/83-18 413-414/83-09 413/83-19 414/83-17 413-414/83-10 413/83-20 413-414/83-11 414/83-18 413-414/83-12 Interrogatories 23 and 25 These interrogatories requested information regarding disputes and disagreements between quality control inspectors and their supervisors or Duke Power Company management, and complaints by workers known by Duke Power Company regarding substandard workmanship.
During the course of -witness preparation, and while reviewing materials to be used in updating prior
- responses to interrogatories, Applicants determined that documents reflecting a recourse action not completed until August 16, 1983, and other Mformation relating to James S. Henson,- an employee of the Construction Department, had l
not previously been made available.
Because Palmetto Alliance had previously requested copies of all such documents covered by these interrogatories relating to other employees, Applicants are forwarding copies of the Henson documents to Palmetto Alliance with this Supplemental Response.
Applicants I
would ask Palmetto Alliance -to treat 'the medical information contained in the Henson recourse file as sensitive information, and not to disclose such infor$1ation without first discussing it with Applicants.
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' An investigation was undertaken in an _ attempt to determine why the Henson documents 'had not been provided earlier.
As a result, Applicants obtained the following documents,. located ' in the files of Construction Employee
-. Relations :
A.
Exit Interview Report of Francis M. Buckley,- dated April 25, 1983.
B.
Exit Interview Report of John Mallen, dated June 27, 1983.
C.
Exit Interview Report of Raymond Austall, dated June 7,1983.
These documents are also being _ forwarded to Palmetto Alliance.
These documents do.not provide ' additional substantive information beyond that already made available to Palr'etto Alliance during~ discovery.
During the depositions of certain Duke Power Quality - Assurance employees, documents related to the Recourses of John Rockholt and Eddie Feemster were provided to Palmetto Alliance.
Documents generated subsequent to the depositions are included with -these Supplemental Responses.
In addition, the Recourse documents of _ Tony Bagwell, dated August 26, 1983 are included with
.this Supplemental Response.
Palme'tto Alliance Follow-Up Interrogatories -(March 17, 1983)
Interrogatorv 6 This ' interrogatory _ requested the identity of Duke Power Company employees principally responsible for the development, management, and implementation of the company's Quality Assurance Program at the Catawba Nuclear Station.
In its March 25: Responses, Applicants provided a chart setting forth the positions held _by various employees.
During the course of depositions, certain errors in the chart were identified.
Applicants are providing a corrected chart with these Supplemental Responses.,
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3 Interrogatory 9 a
~
- This1 interrogatory requested background information ' relating to the Welding Inspector Task-~ Force investigation.
During the course of preparation of the
. testimony of the - i Task Force ' Chairman,.. Applicants. determined that the
-documents described below were not placed in the document room. during
- discovery:
p A.
Inspector Feedback Notes
-Section - 10.0 of the Technical. Task Force Report describes the inspector f'eedback activities conducted ' by : the Task-Force.
The Tack Force members reviewed their findings, conclusions and : recommendations with the inspectors'. 'Although the results of these interviews are included in
^
the. Report, the handwritten notes of the Task Force members were not included in the document room.
These notes will be provided to Palmetto -
Alliance if requested.
B.
-other Notes And Drafts The task Force members took notes during the course of their work, and
.had other personnel perform work for them ranging from clerical duties 'to c
. complex-analyses, including. interviews with : the_ welding ' inspectors.
' Although ithe E substance of this-work was included in the Task Force
~
1
' Report,. the notes'. and -drafts of this work was not included in the document room.
Applicants wi)1 provide these notes to Palmetto Alliance if requested.
During ' the deposition of R. A. Morgan (p. 90-93), he described a process known' as " stickman". ' This process, though in effect prior to the welding inspector. concerns, was modified' during the implementation of the Task Force recommendations. -If requested by. Palmetto Alliance, Applicants will make
, available the documents. relating to the stickman process, which consist 7
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c primarily of technical questions from inspectors and responses from the
. appropriate technical support area.
Finally, the items of correspondence pertaining to Finding 9.3.1 of the Management Analysis Company Report were not in the Duke Power document room.
This correspondence is a November 8, 1982 memorandum from W. O.
Henry to W.
H. Bradley and a September 10, 1982 memorandum from C. N.
Alexander to W. H. Bradley.
These documents are being provided to Palmetto Alliance with these Supplemental Responses.
AIFert V. Carr, Ronald L. Gibso DUKE POWER C MPANY P.O. Box 33189 Charlotte, North Carolina 28242 (704) 373-2570 J. Michael McGarry, III Anne W. Cottingham DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202) 857-9833 Attorneys for Duke Power Company, et al.
September 8,1983
4 00LKETED
+-
UNITED STATES OF-AMERICA
$U:
. NUCLEAR REGULATORY COMMISSION EFORE THE ATOMIC SAFETY 'AND LICENSING BOAR'S SEP 12 R2 :32 CFil:E CF SEuriu
-In th'e ' Matter of-
)
00CHETir4G & SEpvia.
-)
BRANCH DUKE POWER. COMPANY, et al.
)
Docket-Nos.
50-413
)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
CERTivlCATE OF SERVICE l' hereby certify that copies -of " Applicants' Supplemental Responses To Palmetto Alliance's Interrogatories And ' Requests To Produce Relating To Contention '. 6."
in the above-captioned matter have been ~ served upon the following1 by dep'osit in the United States mail this 8th day of September,1983.
James -L. Kelley, Chairman Richard P. Wilson, Esq.
Atomic Safety and Licensing Board Assistant Attorney General Panel State of South Carolina
- U. ' S. Nuclear Regulatory Commission P. O. Box 11549
' Washington, D.C.
20555 Columbia, South Carolina 29211 Dr. A. Dixon Callihan R.obert Guild, Esq.
l-
'Uniod Carbide Corporation Attorney-at-Law
-P. O. Box Y P. O. Box 12097 Oak Ridge, Tennessee 37830 Charleston, South Carolina 29412 Dr. Richard F. Foster
- Palmetto Alliance P. O. Box 4263-2135 Devine Street
~
l
.Sunriver, Oregon' 97702 Columbia, South Carolina 29205 Chairman Jesse L. Riley l
. Atomic' Safety' and Licensing 854 Henley Place Board -Panel '
Charlotte, North Carolina 28207 L
U. S. Nuclear Regulatory Commission
'3 Washington, D.C.
20555:
L
. Chairman -
Henry A. Presler
~ Atomic Safety and Licensing Charlotte-Mecklenburg Appeal Board Environmental Coalition U. S..; Nuclear Regulatory Commission 945 Henley Place Washington, D.C.
20555~
Charlotte, North Carolina 28207 I-w,--
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. George E. Johnson, Esq.
Carole F. Kagan, Attorney Office of the Executive Legal Atomic Safety and Licensing Board Director Panel U. S. Nuclear Regulatory. Commission U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 J. Michael McGarry, III, Esq.
Scott Stucky Anne W. Cottingham, Esq.
Docketing and Service Section Debevoise' & Liberman '
U. S. Nuclear Regulatory Commission 1200 Seventeenth Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20036 Don R. Willard Mecklenburg County Department of Environmental Health 1200 Blythe Boulevard Charlotte, North Carolina 28203
- Hand delivered on Septe'mber 8,1983 with documents enclosed.
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