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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20245L4191989-05-0404 May 1989 Graterford Inmates First Set of Interrogatories for Commonwealth of PA Dept of Corrections & Production of Documents Request.* Certificate of Svc Encl.Related Correspondence ML20245L4941989-05-0404 May 1989 Graterford Inmates First Set of Interrogatories for Commonwealth of PA Emergency Mgt Agency & Production of Documents Request.* Certificate of Svc Encl.Related Correspondence ML20238D1101987-12-29029 December 1987 Licensee Response to Request for Production of Documents by Air & Water Pollution Patrol Dtd 871207.* List of Available Requested Documents Provided.W/Certificate of Svc.Related Correspondence ML20238D0771987-12-29029 December 1987 Licensee Objections to Request for Production of Documents by Air & Water Pollution Patrol & Motion for Protective Order.* Request Re Records of False Activation of Monitor Alarms Requires Extensive Research.Certificate of Svc Encl ML20096E4661984-08-31031 August 1984 Supplemental Response to Applicant 840625 Discovery Request & Interrogatories Re Admitted Offsite Emergency Planning Contentions.Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20096B4071984-08-30030 August 1984 Answer to Applicant First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20094C3131984-08-0303 August 1984 Revised Answer to Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions ML20094A6791984-08-0101 August 1984 First Set of Interrogatories & Request for Production of Documents to City of Philadelphia Re Offsite Emergency Planning Contentions City-18 & City-19.Certificate of Svc Encl.Related Correspondence ML20094C2121984-07-31031 July 1984 Answer to Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions (Discovery 35). Certificate of Svc Encl ML20094E5921984-07-23023 July 1984 Amended Answers to Util First Set of Interrogatories Re Offsite Emergency Planning Contention Lea/Foe 24.Certificate of Svc Encl ML20090D9621984-07-16016 July 1984 Response to Limerick Ecology Action Second Set of Interrogatories & Request for Production of Documents on Offsite Emergency Planning Contentions.Related Correspondence ML20093D4071984-07-11011 July 1984 Response to Limerick Ecology Action First Set of Interrogatories & Request for Production of Documents on Offsite Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20090A7091984-07-10010 July 1984 Objections to Limerick Ecology Action First & Second Sets of Interrogatories on Offsite Emergency Planning Contentions. Related Correspondence ML20090A7211984-07-0909 July 1984 Answer to First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Util & Certificate of Svc Encl.Related Correspondence ML20092P7691984-07-0303 July 1984 Second Set of Interrogatories & Request for Production of Documents to State of PA Emergency Mgt Agency on Admitted Offsite Emergency Planning Contentions.Related Correspondence ML20151K0601984-06-25025 June 1984 First Set of Interrogatories & Requests for Production of Documents to Limerick Ecology Action & Friends of the Earth Re Offsite Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20092P7761984-06-25025 June 1984 Second Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Certificate of Svc Encl. Related Correspondence ML20092K7191984-06-22022 June 1984 First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Certificate of Svc Encl. Related Correspondence ML20092J7561984-06-21021 June 1984 First Set of Interrogatories & Request for Production of Documents on Limerick Ecology Action Admitted Offsite Emergency Planning Contentions.Notice of Appearance for M Mulligan & Svc List Encl.Related Correspondence ML20091K1841984-06-0101 June 1984 Answer Opposing Friends of the Earth 840518 Motion for Admission of New Late Contentions Re Applicant 840509 Motion for Expedited Partial Initial Decision & Issuance of Low Power License.Certificate of Svc Encl ML20091K1771984-06-0101 June 1984 Answer Opposing Del-Aware 840517 Proposed Late Contentions Re Applicant 840509 Motion for Expedited Partial Initial Decision & Issuance of Low Power License.Contentions Should Be Denied & Action Taken Against Del-Aware ML20084D9241984-04-27027 April 1984 Response to First Set of Interrogatories on Severe Accidents.Related Correspondence ML20088A4251984-04-0909 April 1984 First Set of Interrogatories & Request for Production of Documents to Limerick Ecology Action Re Severe Accident Contentions.Certificate of Svc Encl.Related Correspondence ML20088A4231984-04-0909 April 1984 First Set of Interrogatories & Request for Production of Documents to City of Philadelphia Re Severe Accident Contentions.Related Correspondence ML20087F2071984-03-12012 March 1984 Responses to Util Interrogatories on Contention I-42. Certificate of Svc Encl.Related Correspondence ML20086U0501984-03-0202 March 1984 Response Opposing Air & Water Pollution Patrol 840221 Request for Extension of Discovery Period for Contention VI-1.Certificate of Svc Encl.Related Correspondence ML20086U3431984-03-0202 March 1984 Response to Air & Water Pollution Patrol Motion to Compel Discovery.Applicant Denies That Answer to Interrogatory Evasive.Related Correspondence ML20080T9501984-02-27027 February 1984 Answers City of Philadelphia Interrogatories on Sys Interaction Contention.Certificate of Svc Encl.Related Correspondence ML20080R9931984-02-21021 February 1984 Answers to City of Philadelphia Interrogatories (Discovery 27).Certificate of Svc Encl ML20080N7201984-02-10010 February 1984 Motion to Compel Answers to Listed Interrogatories ML20080E8571984-02-0606 February 1984 Responds to Applicant First Set of Interrogatories Re Contention I-42.Certificate of Svc Encl.Related Correspondence ML20080E8031984-02-0606 February 1984 Interrogatories & Request for Production of Documents of City of Piladelphia to Util Re Sys Interaction.W/Certificate of Svc.Related Correspondence ML20080C5911984-02-0303 February 1984 Interrogatories 14-21 Re Environ Qualification ML20080C5961984-02-0303 February 1984 Interrogatories 22-30 Re Environ Qualification ML20080B8761984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-41.Certificate of Svc Encl ML20080B8301984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-41 ML20080B8201984-02-0303 February 1984 Second Set of Interrogatories & Request for Production of Documents on Contention I-42 ML20080B8081984-02-0303 February 1984 First Set of Interrogatories & Request for Production of Documents on Contention I-42 ML20080A4501984-02-0202 February 1984 First Set of Interrogatories & Request for Production of Documents Re Limerick Ecology Action Onsite Emergency Planning Contentions.Certificate of Svc Encl ML20080B9231984-02-0101 February 1984 Answers to Twelfth Set of Interrogatories on Qa/Welding Contention (Discovery 24).Certificate of Svc Encl ML20080B9121984-02-0101 February 1984 Answers to Eleventh Set of Interrogatories on Qa/Welding Contention (Discovery 23) ML20080B8911984-02-0101 February 1984 Answers to Tenth Set of Interrogatories on Qa/Welding Contention (Discovery 25) ML20080A6251984-02-0101 February 1984 Answer to Applicant Second Set of Interrogatories & Request for Production of Documents on Contention VI-1.Related Correspondence ML20079S2721984-01-25025 January 1984 Answer to Sixth Set of Interrogatories on Qa/Welding Contention ML20079S2901984-01-25025 January 1984 Answer to Seventh Set of Interrogatories Re Qa/Welding Contention.Certificate of Svc Encl ML20079S2851984-01-25025 January 1984 Answer to Seventh Set of Interrogatories Re Qa/Welding Contention ML20079J4541984-01-20020 January 1984 Preliminary Set of Initial Interrogatories & Request for Production of Documents Re Onsite Emergency Planning Contentions.Certificate of Svc Encl ML20086J9981984-01-14014 January 1984 Twelfth Interrogatory Re Contention VI-1 (Qa/Qc).Documents, Logs & Repts on All safety-related Welds Requested ML20086J9921984-01-14014 January 1984 Eleventh Interrogatory Re Contention VI-1 (Qa/Qc).Details Pertinent to safety-related Pipe Failures Due to Freeze Induced Bursts Requested ML20079F2101984-01-13013 January 1984 Second Set of Interrogatories & Request for Production of Documents on Contention VI-1.Certificate of Svc Encl 1989-05-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20247L8591998-05-19019 May 1998 Confirmatory Order Modifying Licenses Effective Immediately Re Thermo-Lag 330-1 Fire Barrier Sys ML20203A1701998-01-30030 January 1998 Exemption from Requirements of 10CFR70.24 for Limerick Generating Station,Unit 1 ML20151L3671997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Orders That SA Blacklock Prohibited from Engaging in Activities Licensed by NRC for 5 Yrs from Date of Order ML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 ML20203H6891997-06-0202 June 1997 Transcript of 970602 Enforcement Conference in King of Prussia,Pa ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20080D8351994-12-22022 December 1994 Exemption from Certain Requirements of 10CFR50,App J Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors Allowing Continuation of Plant Operation within 24 Month Cycle ML20078K1441994-11-0909 November 1994 Exemtion Granted from Requirements of 10CFR73.55(d)(5) Re Returning of Picture Badges Upon Exit from Protected Area Such That Individuals Authorized Unescorted Access Into Protected Area Can Take Badges Offsite ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20045D8121993-06-14014 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54 Re FSAR Update Submittals ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20062C6561990-10-22022 October 1990 Affidavit Requesting Withholding of Summary Rept on Evaluation of Recirculation Nozzle to Safe End Weld Indication & Proposed Disposition to Permit Unit 1 Cycle 4 Operation, from Public Disclosure,Per 10CFR2.790 ML20006D3821990-02-0606 February 1990 Comment on Proposed Rule 10CFR2 Re Policy & Procedures for Enforcement Actions;Policy Statement.Util Uncertain as to Whether Changes Necessary ML20246J4521989-08-30030 August 1989 Memorandum & Order (Terminating Proceeding).* Terminates Proceeding Per Settlement Agreement Between Limerick Ecology Action,Inc & Licensee.W/Certificate of Svc.Served on 890831 ML20246F1011989-08-25025 August 1989 Joint Motion for Termination of Proceedings.* Board Moved to Accept Encl Settlement Agreement,Dismiss Limerick Ecology Action,Inc (Lea) Contention W/Prejudice,Dismiss Lea as Party to Proceeding & Terminate Proceeding ML20246F0121989-08-25025 August 1989 Memorandum & Order CLI-89-17.* Staff Authorizes Issuance of Full Power License to Licensee to Operate Unit 2 After Requisite Safety Findings Under 10CFR50.57 Completed. W/Certificate of Svc ML20246F1471989-08-25025 August 1989 Settlement Agreement.* Certificate of Svc Encl ML20246E8351989-08-24024 August 1989 Second Supplemental Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission & Memorandum & Order of 890807.* W/Certificate of Svc ML20246E3431989-08-22022 August 1989 Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc ML20246C0271989-08-18018 August 1989 Notice of Appointment of Adjudicatory Employee.* Informs That D Nash Appointed as Commission Adjudicatory Employee to Advise Commission on Issues in Proceeding.W/Certificate of Svc.Served on 890818 ML20246B7721989-08-17017 August 1989 Correction of Memorandum & Order of 890815.* Advises That Refs to 49CFR2.730(c) on Page 1 & 49CFR2.710 & 49CFR2.711 on Page 2 Should Be Corrected to Read as 10CFR2.730(c),2.710 & 2.711,respectively.W/Certificate of Svc.Served on 890818 ML20246D7411989-08-17017 August 1989 Transcript of 890817 Meeting in Rockville,Md Re Discussion of Full Power OL for Facility.Pp 1-58.Supporting Documentation Encl ML20246B7751989-08-16016 August 1989 Memorandum & Order.* Denies Rl Anthony 890623 Request for Hearing for Intervention in Remand Proceeding & for Stay of Low Power Authorization.W/Certificate of Svc.Served on 890816 ML20246B7571989-08-16016 August 1989 Order Responding to Limerick Ecology Action Motion for Reconsideration.* Denies Motion to Reconsider,Stay,Suspend or Revoke 890707 Order on Basis That Order Appropriate.W/ Certificate of Svc.Served on 890816.Re-served on 890818 ML20246B7931989-08-15015 August 1989 Memorandum & Order (Request for Expedited Answer).* Denies Licensee 890811 Request for Expedited Answer from NRC & Limerick Ecology Action on Basis That Request Lacks Good Cause.W/Certificate of Svc.Served on 890816 ML20245H8491989-08-14014 August 1989 Notice of Change of Address.* Advises of Council Change of Address for Svc of Documents ML20245H8061989-08-14014 August 1989 Supplemental Response of Intervenor Limerick Ecology Action, Inc to Memorandum & Order of Commission & to Memorandum & Order of 890807.* Requests Further Extension of Time in Which to Reply.Certificate of Svc Encl ML20245H5991989-08-11011 August 1989 Memorandum & Order (Terminating Proceeding).* Dismisses Graterford Inmates Contention Re Adequacy of Training for Drivers Responsible for Evacuating Graterford & Terminates Proceeding.Certificate of Svc Encl.Served on 890814 ML20245H7341989-08-10010 August 1989 Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing & Request for Expedited Answer to This Motion.* Divergence in Positions of Respective Parties Emphasizes Need to Conclude Proceeding.W/Certificate of Svc ML20245F7161989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Environ Benefits for Operating Unit 2 Outweigh Small Risk of Severe Accident ML20245F7511989-08-0909 August 1989 Reply by Licensee Philadelphia Electric Co to NRC Staff Response to Commission Questions.* Commission Should Rely on Licensee Cost Analysis in Response to Question 5 & Rc Williams Affidavit.W/Certificate of Svc ML20245F7341989-08-0909 August 1989 NRC Staff Response to Commission Memorandum & Order of 890807.* Advises That NRC Will Provide Comments on Limerick Ecology Action 890814 Filing Prior to Commission Meeting Scheduled for 890817.W/Certificate of Svc ML20245F7291989-08-0808 August 1989 Affidavit.* Discusses Costs Incurred While Plant Inoperable. Allowance for Funds Used During Const,Security,Maint & Operational Costs Considered Proper for Calculating Costs for Delay ML20248D9241989-08-0707 August 1989 Memorandum & Order.* Extends Limerick Ecology Action Response Deadline to 890814 to Respond to Five Questions Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890807 ML20248D7871989-08-0303 August 1989 Correction for NRC Staff Response to Commission Questions.* Forwards Corrected Page 5 to NRC Response to Questions Filed on 890802,deleting Phrase by Nearly Factor 2.5 in Next to Last Line.W/Certificate of Svc ML20248D5671989-08-0202 August 1989 Affidavit of SE Feld.* Advises That Author Prepared Response to Question 5.W/Certificate of Svc ML20248D5981989-08-0202 August 1989 Response by Licensee Philadelphia Electric Co to Commission Request for Comments by Memorandum & Order Dtd 890726.* Licensee Requests Commission Issue Full Power OL for Unit 2 Conditioned Upon Outcome of Pending Litigation ML20248D7111989-08-0202 August 1989 Response of Intervenor Limerick Ecology Action,Inc to Memorandum & Order of Commission Dtd 890726.* Commission Order Fails to Provide Intervenor Adequate Time for Response & Should Therefore Be Revoked.W/Certificate of Svc ML20248D5391989-08-0202 August 1989 Affidavit of MT Masnik.* Advises That Author Prepared Response to Question 3 ML20248D5311989-08-0202 August 1989 Affidavit of Rj Barrett.* Advises That Author Prepared Response to Question 2 ML20248D4971989-08-0202 August 1989 Joint Affidavit of Gy Suh & CS Hinson.* Advises That Authors Prepared Responses to Questions 1 & 4 ML20248D4721989-08-0202 August 1989 NRC Staff Response to Commission Questions.* Provides Info for Use in Commission Effectiveness Review of Plant Full Power Operation,Per Commission 890726 Memorandum & Order. Supporting Affidavits Encl ML20248D6451989-08-0202 August 1989 Affidavit.* Advises That Author Read Responses to Request for Comments by NRC & Knows Contents.W/Certificate of Svc ML20245J1321989-07-27027 July 1989 Transcript of 890727 Meeting in Rockville,Md Re Facility Severe Accident Mitigation Issues.Pp 1-130.Supporting Info Encl 1998-05-19
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
1 1
Philadelphia Electric Company
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Docket Nos. 50-352 a
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50-353 (Limerick Generating Station
)
Units 1 and 2)
)
ij APPLICANT'S ANSWERS TO INTERVENOR AWPP'S EIGHTH SET OF
~~
l INTERROGATORIES ON QA/ WELDING CONTENTION i
.i DISCOVERY 22 JANUARY 25, 1984
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1 h
Q
Interrogatory No. A AWPP requests specific naterial that will not require searching through voluminous records.
Please provide corresponding full Finding Reports indicated on the following Audit Reports:
Date Audit Number Report # (or FBP) 2/6--8/1/80 P 169 FBP 351; 355; 354 2/5--8/29/80 P 171 P 318; P 360 4/17/80 P 182 P 324 FRP 329 6/6--6/13/80 P 192 FRP 349 12/3--12/5/80 P 218 12/15-23-31/80 and 1/3-; 3/81 P 211 FRP 382; 395; 396 4/27-5/4/81 and 5/11-14/81 P 242 P 424, 435 n/30, 5/4-8/81 P 244 FRP 429;430;431;433 5/26-6/5/81 P 248 FRP 442 8/17-11/17/81 P 267 FRP 462 10/8-11/13/81 P 270 FBP 461 11/12-30/81 278 467;464:465;466 11/24-12/3/81 279 453 1/4-8/82 284 482 1/13-2/18/82 285 489;490;491;492;493;494; 495;496;497;498;499;G-208 2/18-3/4/82 287 S00:501:502;503;504 505:506:507:508 Where Finding Report number (s) does not apply, provide one.
Answer The Finding Reports listed above are being provided for inspection and copying except that Finding Report P-382, which does not relate to Audit Report P-221, is not provided but Finding Report P-392, (Not listed above but referenced in Audit Report P-221), is provided and similarly Finding Report P-432, (not listed above, but referenced in Audit Report P-244), is provided (Discovery 22, Item A).
Participants in Preparation of Answer 2
V. S. Boy;r, S:nior Yica Presid!nt - Nuclear Power Phileds1phin Electric Coup 2ny 2301 Markat Str@st Philadelphia, PA 19101
-D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street j
Philadelphia, PA 19101 1
i 1
i
's 3
Interrogatorv No. 1 WhOro are radicgraphs involved and cubtit caco.
F*
I
~ '
Answer The radiographs and records of other nondestructive examinations are stored on site or at other records storage locations.
Applicant, in response to previous interrogatory l
requests, had offered to make specifically identified radiographs available to AWPP's technical representative upon reasonable notice after receiving information indicating that the AWPP representative is qualified to evaluate the radiographs, e.g.
SNT-TC-1A, Level II or III certification in radiography.
Participants in Preparation of Answer V.
S. Boyer, Senior Vice President - Nuclear Power
'~
Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Barket Street Philadelphia, PA 19101 4
Interroaatory No. 2 Are all of these welds safety related welds?
Answer The welds identified in the Audit Finding Reports listed in Interrogatory A are safety related welds.
Participants in Preparation of Answer i
V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street I
Philadelphia, PA 19101 1
D. T. Clohecy i
Quality Assurance'- Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 5
5
Interrogatory No. 3 How cany welds did each audit represent?
That is, give the number of safety related welds covered by each Audit, also giving the welding activity time, in months, the audit represents.
Answer The number or type and location of welds or other items or activities audited are described in the " Purpose and Scope" and g
l "Sommary" section of the Audit Reports, which have been made available previously.
I Audits are not generally scoped by time period but rather by I
QA program aspect or activity, (i.e. pipe installation).
Audits are planned and periodically performed to verify compliance with the various aspects of the QA program and to determine the
~
effectiveness of the program.
PECo QA audits of radiogaphs of Bechtel Field welds are generally conducted on an annual basis.
PECo QA audits of field subcontractor radiographs were not conducted annually but by QA program aspect or activity.
Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 6
l
Interrogatory No.
4' i
Frca 1976 to 1983, give yearly total nucbsr of safcty related welds performed by Bechtel and subcontractors.
AnsvgI An estimate of the number of safety related welds joining safety related piping, reactor vessels, and reactor vessel 3
internals for the Limerick Generating Station was previously provided (Discovery 16, Interrogatory No. 1).
-l Records are not maintained of the total number of safety h
related welds performed each year, nor can this be estimated-with any degree of accuracy.
Participants in Preparation of Answer V.
S.iBoyer, Senior Vice President - Nuclear Power Philadelphia Electric-Company 2301 Market Street Philadelphia, PA 19101
~
D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Harket Street Philadelphia, PA 19101 7
Intorrnaatery No-5 vsro all of ths above rcdicgraphsd?
Answer No.
Participants in Preparation of Answer 4
V.
S. Soyer, Senior Vice President - Nuclear Power i
Philadelphia Electric Company I-2301 Market Street Philadelphia, PA 19101 i
D. T. Clohecy Quality Assurance - Engineer i
Philadelphia Electric Company l
2301 Harket Street I
Philadelphia, PA 19101 e
8
Interrocatory No. 6 For sane years (as in #4) provide records showing total number of radiographs P.E. (Corcoran) took to audit.
Answer Forty (40) audit reports listed below document audits perf ormed by PECo. QA on radiographs taken at Limerick.
l P-31 5-86 M-253 M-320 M-383 P-33 l
P-96 M-93 5-258 M-326 5-455 P-171 M-113 M-271 M-335 C-107 P-175 M-130 M-272 M-338 P-218 M-147 M-281 M-344 M-32 M-204 M-289 M-346 j
M-36 M-208 M-295 M-351 M-46 M-241 M-302 M-355 M-83 M-251 M-313 M-360 i
The radiographs and other aspects audited are described in the " Purpose and Scope" and " Summary" section of the Audit Report.
These audit reports have been previously made available for inspection and copying (Discovery 14, Item 2).
Participants in Preparation of Answer V.
S.
Boyer, Senior Vice President - Nuclear Power I
Philadelphia Electric Company 2301 Market Street i
Philadelphia, PA 19101 9
J. B. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 m
10
l Interroaatory No. 7 Provid@ neto cf consultant ustd by PE's Corcoran, togsthsr
.with address of organization. (MPR)
Answer MPR Associates 1140 Constitution Avenue Washington, D.C.
'20036 j
Participants in Preparation of Answer Y. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company
?
2301 Market Street f
Philadelphia, PA 19101 I
J.M. Corcoran Quality Assurance Field Branch Head g
Philadelphia Electric Company i
2301 Market Street Philadelphia, PA 19101 0
11
Interrogatory No. 8 Has anyone in "MPR" ever worked for Bechtel Corp.?
Answer A representative of MPR has informed Applicant that to the of his recollection no employee of MPR was formerly employed best by Bechtel Power Corporation.
f Participants in Preparation of Answer V.
S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
.J.
M. Corcoran Quality Assurance Field Brsach Head Philadelphia Electric Company e
2301 Market Street Philadelphia, PA 19101 12
l Intorrecrtery No. 9 Hn3 CMPRC cr eny of it0 coploys@s corked for Bachtel at any other reactor?
Answer A representative of HPR has informed Applicant that to the best of his recollection MPB has not done any work under a contract for Bechtel Power Corporation at any other reactor.
i Participants in Preparation of Answer V.
S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J.
M. Corcoran Quality Assurance Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 13 L
Interrogatory No. 10 Is there any NRC, or PE, or Bechtel rule that specified the number of safety related welds that must be radiographed?
Answer The requirements to radiograph a particular saf ety related weld are based on consideration of weld configuration, pipe class, service and found in the ASME Boiler Pressure Vessel Code, other applicable codes, or as specified by the responsible design organizations.
Participants in Preparation of Answer V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 14
2nterrocatory Noo 11 Regarding 10 above, is there a rule as to % of radiographs
)
that must be audited?
Answer No.
Participants in Preparation of Answeg V. S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street d
Philadelphia, PA 19101 i
i 15
COMMONWEALTH OF PENNSYLV?.NIA ss.
COUNTY OF PHILADELPHIA V. S. Boyer, being first sworn, deposes and states:
That he is Senior Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Applicant's Answers tc Intervenor AWPP's Eighth Set of Ir.terrogatories on QA/ Welding and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
Sedior ViYe Presi p Subscribed and sworn to before me this O b day of January, 1984.
Ojazia6.i Notary Putlic PATRictA O. s; sos _L Netvv s y.:.., _, ;
g. s.,
e I bCT%U;3 U;.a L, d a
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sDNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
,x
)
Philadelphia Electric Company,,-.3
)\\ Docket Nos. 50-352
)
50-353
~
(Limerick Generating Statidn,'a
)
Units 1 and 2)
)
V N
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Answers to Intervenor AWPP's Sixth Set of Interrogatories on QA/ Welding Contenticn,"," Applicant's Answers to Intervenor AWPP's Seventh Set of' Interrogatories on QA/ Welding Contention,"aad
" Applicant's hnswers to Intervenor AWPP's Eighth Set of Interrogatories ~on QA/ Welding Contention," dated January 25, 1984 in the ' captioned jmatter, hsve been served upon the following by deposit in the United States mail this 27th day of January, 1984:
Lawrence Brenner', Esq. (2) '
Atomic Safety and Licensing Atomic Safety /ad;i Licensing.
Appeal > Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington,.D.C.
20555 s.
Washington, D.C.,
20555 g-Docketing and Scyv,ipe Section Dr. Richard F. Cole Atomic Office of the Secretary Safety and Licensing U.S.sNuclear Regulatory C0mmission Board U.S.liuclear Re,7ulatory l' Washington, D.C.
20555 Commission
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s Washington, D.C.
20555 Ann P.
Hodgdon, Esq.
Counsel for NRC Staff s
Dr. Peter A. Mo;ris Atomic N Office of the Executive
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Safety and picensing Legal Director Board U.S. Nuclear Regulatory U.S. Nuclear.Pegulatory CommissioD Commission-Washington, D.C.-
20555 Washington, D.C.
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Atomic Safety and Licensing Steven P. Hershey, Esq.
Board Panel Community Legal U.S. Nuclear Regulatory Services, Inc.
Commission Law Center West North Washington, D.C.-
20555' 5219 Chestnut Street Philadelphia, PA 19139 Philadelphia Electric Company ATTN:
Edward G. Bauer, Jr.
' Angus Love, Esq.
Vice President &
107 East Main Street General Counsel Norristown, PA 19401 2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue
-Mr. Frank R. Romano Ardmore, PA 19003 61 Forest Avenue Ambler, Pennsylvania' 19002 Robert J. Sugarman, Esq.
Sugarman & Denworth Suite
~Mr. Robert L. Anthony 510 North American Building Friends of the-Earth of 121 South Broad Street the Delaware Valley Philadelphia, PA 19107 106 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Director, Pennsylvania Emergency Management Agency Mr. Marvin I. Lewis Basement, Transpcrtation 6504 Bradford Terrace and Safety Building Philadelphia, PA 19149 Harrisburg, PA 17120 Phyllis Zitzer,-Esq.
Martha W. Bush, Esq.
-Limerick Ecology Action ~
Kathryn S. Lewis, Esq.
P.O. Box 761 City of Philadelphia
-762 Queen. Street Municipal Services Bldg.
Pottstown, PA 19464 15th and JFK Blvd.
Philadelphia, PA 19107 Charles W. Elliott, Esq.
Brose and Postwistilo Spence W.
Perry, Esq.
1101 Building lith &
Associate General Counsel Northampton Streets Federal Emergency Easton, PA 18042 Management Agency 500 C Street, S.W.,
Rm. 840 Zori G. Ferkin, Esq.
Washington, DC 20472 Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director Governor's Energy Council Bureau of Radiation
! 1625 N. Front Street Protection Harrisburg, PA 17102 Department of Environmental Resources 5th Floor, Fulton Bank Bldg.
Third and Locust Streets Harrisburg, PA 17120 p
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1 Jay M. Gutierrez, Esq.
U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Nils N. Nichols
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