ML20079S395
| ML20079S395 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/30/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20079S359 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8402030320 | |
| Download: ML20079S395 (26) | |
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w 1 UNITED STATES OF AMERICA '*?'M"EY NUCIEAR BEGULATORY COMMISSION
'84 ~ RB -2 F2 3
-er., ,
BEFORE THE A'10MIC SAFETY AND LICENSING BOAED '" u
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Glenn O. Efright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )
Units 1 ani 2) )
)
Wells Eddleman's General Interrogatories 6pd ge b#M IdfBry8f+tef N,'
to Apolf.ce.nts Carolina Power & Light et al. g
/ 1 Set)
(SE2mTH ~
FKr-93 + 3-10-f3 N Under 10 CPR 2.7h0, 2.7h1 and the Board 8 s 9-22-82 Memorandun(s) and Orderf Wells Eddleman recuests Applicants to answer separately and fully in writing, under oath o' affirnation, each of the following interrogatories, and to produce a permit insnection and conying of the original' or best copy of all document's identified in resnonse to interrogatories as set forth below. .
( These interrogatories are intended to be continuinF in nature, and I reouest each answer to be cronntly sunplemented oa anended as annronriate unde" 10 CFR P.715(e), should CP4L, NCFPA,.any othe" or any contractor or censultant to any, sone or all cf' those,
[@8
, Apolicant,por any emnloyee of any or some or all of them, or any "a individual acting on Nhalf of any or some of all of them, obtain g
"8 og or create any new or differing information resnonsive to these o< (whM4"Them" refe=s toThe thereouest preceding listing (s))
for production of documents-general interrogatories.
is also continuing and ecuests Applicants to eroduce nromotiv if
. not inmediately any additional documents the Applicants and others acting on their behalf or encloyed by then, as lis'ted in the previous
P .
2
, sentence, obtain which are responsive to t he raqu3st(s) for nroductio'n l 1
of documents below.
Where identification of a document is reguested, clease briefly describe the document (e.g. book, notebook, letter, memo, report, l notes, transcript, minutes , test data, log, etc. ) and provide the document name, title, number, following information as applicable:
author (s), date of writing or of eublication or both, addressee, date aproveo, by whom aproved, and the name and address of the versens ha'ing normal custody of tha document, and name and reddeess of any yerson other than the preceding having actual possession of the document. When identifying documents in resconse to these interroEatories and reouests, please state the portion or portiens of the document (e.g. sections, chafrs, pages, lines) upon which Applicants rely or which Ap{licants swear or affirm is/are responsive to the applicable interrogatory or vequest. I DEFINITIONS herein:
" Harris", " Harris Plant", "SENPP", or " plant" where not specified otherwise, all mean the Shearon Harris wuclear Power Plant.
"Aplicants" means all of the persons, earoloyees , consultants, contractors and corporations as listed in the first sentence of the second paragraph on page 1 of this document, above.
"FSAR" means the Harris Final Safety Analysis "ecort. )
j "ER" means the Harris Environmental Penort. l t yoe, l
" Document (s)" means all writings end records of ever7 )
including electronic and emuter records, in the possessien, control licarts' or custody of Ayplicants or any individual (s) act$ng on A behalf, including, but not linited to: venorts, books, memorande, corresnondence, notes,ninutes, pamphlets, leaflets, magazines, articles, surveys , maps , bulletins , photogranhs , speeches , transcripts ,
voice recordings, com7utar printouts, information stor?d in coyuters or comnuter peripheral devices such as disks, drums , etc. , voice recordings, m'crofilm, microfiche and all other writinEs or scordinF8 1
of any kind (s); and cooies of any of the precedinE even though the oriEi nal(s) are not in the possession of Applicants or in their l
custody or control. Document (s) shall be deened to be within the a any control of Applicants or individual's) acting on their behalf ossession, or custody of the document (s) if they have ownership, oraco{ythereof,orhavetherighttosecurethedocument(s) of a coyv thereof, froin any person or public or private entit7 having ph7sical possersien thereof.
Each definiti.on E lven above a lies within all other definitions above.
GSfiE$.Al, 1NT& kOSUDb G1 (a) Vhich contentiens of Wells Eddleman do Applicants agree are now admitted in this croceeding, NaC Dockets 50-400/kO10.L.?
(b) for each such contentien , provide f or cny answers to interrog-stories by Wells Eddlenan which Aeolicants have previously or uresently received (except those suspended by Sonrd order, if any), the following information:
(c) Please state the nane, present or last known address, and cresent or last known encloyer of each nerson whon Anolicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) uuon when Applicants relied ( other than their attorneys) in making such answer.
(d) elease identify all facts concerning which each such nerson idanHfied in resconse to G1(c)(1) above has first-hand knowledF e.
(e) olease identify all facts and/ov dccumentsuponwhicheach nevson identified in response to G1(c)(2) above relied in pro #1 ding information to respond to the interrogatory, including the { arts of sach documents relied uron.
r tv-Ql(fd j N * ,
licants (f) Please identify any other document (s) used/by A in respondinE to the interrogato7 (g) Please state which specific fact each docunent, identified in resoonse to G1(e) and GL(f) above, sunports, in the oninion er belief of Anolicants, or which Annlicants allege such docunent supnerts. t s
(h) Please state specifically what information er.ch nersen identified in resnonse to G1(c)(1) or G1(c)(2) above If urovided any to or for Anplicar.ts' affiant in answering the interrogatory.
of this information is rot docunented, nicase identify it as "undocunented" in resnonding to this sect".on of General InterreFato*y 01.
G2.{a)*1easestatethenane,presentorlastknownaddress, title (if any), and oresent or last known employer, and econonic interest (shareholder, bondholder, contractor, e7elo7ee , etc. ) if or other any (beyond exnert witness fees) such verson holds in Applicants or exnect j
or an7 of them, for . each nerson you ir'g and to cell as an . exrert l
witness or a witness in this procee' .. if such information has unged since such information not nreviously been supnlied, or was last suoplied, to Wells Eddlenan. This applies to Eddlenen by Annlicants.
and Joint Contentions as admitted'ntertfon o= *t nulated regardirt which each (b). Please identify each co such person is expected to testify.
(c) Please state when you first contacted each such verson with regard to the nossibility of such verson's testifying for Apolicants, if you have contacted such verson.
(d) Please state the subject natter, separately for each contention as to which each such person is expected to testify, whicheachsuchpersonisexpectedtotestifyto.
(e) Please identify all docunents or carts thareof ucon which each such witness is expected to, vlans to, or will rely, in testifying or in preparing testinony.
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5 03(a).Please identify any other sou"ce(s) of information which Applicants have used to resoond to any interrogatory identified under G1 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifyinE where in such source that information is to be found.
(b) Please identify any other sourceh)of information not trevicusly identified upon which any witness identified under G2 above, or or exhibits otherwitness,hasusedinurenaringtestinenp/,orexnectstouse in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the nart or part(s) of such so urce (if applicable) which are expected to be used, and, if not (or both) creviously stated, the fact (s) or subject matter to which such source relates.
and which Gh(a) please identify all documents,guages or sections thereof Applicants intand or expect to use in cross-exanination of any witness I call in this hearing. For each such witness, clease orovide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject natter Aeolicants believe they l relate to, and nake the document (s) available for inspection form intent and conying as soon as possible after Applicants decide orp tFturd l to use such document in cross-examination.
(b) please identify any undocumented information Applicants intend to use in cross-exanination of each such witness for ne.
G5 (a) for each contention Apolicants state or admit is an admitted Eddleman contention under G1(a) above, or an admitted i
joint intervenor contention, please state whether Auplicants have available to them experts, and information, on the subject matter of the contention.
t (b) If the answer to (a) above is odaer U2an affirmative, l
state whether Aeolicants exoect to be able to obt&in exoertise in the subject matter, and information on it, and if not, why not.
G-6(a) for each document identified in resnonse to any interrogatory herein, or referenced in response to any interrogatory herein, please supply all the following infornatien which has not already been supplied:
(1) date of the document F
(ii) title or identification of document (iii) all authors of the document, o= the author (iv) all qualifications (professional, technical) of each author of the dccunent of the docunent, (v) the specific narts, sections or nages, if any, unon which Aunlicants rely (vi) the specific information each nart, section or uage identified in resnonse to (v) above contains.
(vii) identify all documents used in urenaring the docunent, to the extent known (and also to the extent not identified in the doc unent itself)
(viii) state whether Annlicants possess a co-v of the doc ument (ix) state all exnert ouiniors contained in the document, upon which Aunlicants rely, or identify each such oninion.
(x) identify the contention (s) with resnect to which An 1? cants rely upon (a) the exnert ocinions (b) the facts identified in the docunent (xi) state whether Aunlicants now ennloy any author (s )
of the document, identifyinE each such nerson for each docunent.
(xii) state whether inplicants have ever ennleyed any authdis) of the docunent, identifying each such person for each docunent.
-(xiii) identify all sources of data used in the docunent.
Answers to all the above may be tabulated or grouned for efficiency.
G-7(a) Please identify all documents which Applicants plan, exnect or a intend to offer an exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which !
to G1(a), or (ii) is the !
(i) is included in youe current resnonse subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is exnected to be offered.
(b) Please identify all documents which Auplicants nian, expect or intend to use in cross exanination of any other perties' witnesses or joint intervenor witness in this proceeding, with resnect to (i) Eddlenan contentions identified under G-7(a)(1) (or G1-(e))
above, or any other Eddleman contentien w' *.ch is the subject of 4.nt er-rogatories in this set; (ii) each Joint contention now adnitted in this proceeding; (iii) per our agreenent of h-8-83, each contention of _each other party to this nroceeding which is cu rertly admitted.
Please identify for each such document the witnesses, or witness, and all contentions with resnect to whon (or which) that document
- is planned, expected, or intended to be offered or used.
(c) Please identify which of the documents identified in response (i) to (b) above will be offeved into evidence by Anulicants, and (11) which of the same documents Anulicants exnect to offer into evidence orintendtoofferasevidenceorexhibitsinthisproceeding.
Mb/of spcific (UfevYyalonas be[op, G-10(a) Where the above general interrogatories, or any of then, call for identification of documents, (i) and no documents are identified, is that the sane as Apnlicants stating that there are no documents resconsive to this general interrogatory, in each case where no documents are identified? (ii) and documents a_re identified, is that the same as Anplicants stating that the identified
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' documents are the only ones presently known which are responsive to the interrogatories ? (iii) If your answer to G-10(a)(ii) is other than. affirnstive, please state all reasons for your answer.
(iv) If your answer to G-10(a)(1) above is other than affirnative, please state all reasons for your answer.
(b) Where any interrogatory, general or specific, herein, calls i
for factual information (1) and an opinion is stated in resnonse, !
is that the excert opinion of any person (s) identified as having l
l contributed information to that resnonee? (ii) and facts are given or 1
identified (or a fact is) in resnonse, but no documents are identified, does that mean Applicants have no documents contc'ning such fact (s)?
(iii) If your answer to -(i) above is affirmative, please state fer each each such response all quelifications of _ expert upon whom Applicants rely for each such answer. The qualifications need be stated only once for each such person if they are clearly referonced in other answers. (iv) if your answer to (1) above is other than affirmative, please state which oninions, if a ny ,
given in response to interrogatories (general or snecific) herein is the opinion of an expert, identify each expert whose oninien you used in resnonse tc each interregatory, and state in full the qualifications of each such expert. (v) If your answer to (1) above is other than affirnative, please identify all opinions of non-experts used in your resconses, and identify each non-expert whose oninion is included in each answer herein.
(vi) If your response to (ii) above is other than affirmative, please identify each document which contains a fact not previously docunented in your resnonse(s ), stating what the fact is, and at what page, nlace, chapter or other snecific nart the dccunent contains such fact.
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m, g G-11 For' each answer to esch interrogatcry herein (c: any subpart or part , thereof), please . identify each iten of inforration in possession of Anplicants-(includirg facts, oniniens of e.rports, and[docur.ents ) uhich -(n) contradicts tl.e answer rou r. ado, (1)
.lin .whole (ii) in 'part I (clea re identify each such part for each item of .informatien idortified); (b) carts drubt on your answer
'(1)'in whole (ii)' in part- (picase identify er.ch such ntet for t
esch.itcr. of'infortatice identified). (c) F1ence liar.tify all i decur.onte -not already identified in ecnonse to r4=tn (a) and (b) ;
1
' nbove (tnd their rubparts ) which contains any iter of' info at. ten
. asked fer in (a) or (b)~above. fleano identify ec- ecch ruch decunent what inferr.ution iten(c } -it .contains and what ansuaqc')
each such:' iter. is related to.
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65-b$-(a).PleaseanswereachpartofGeneralInter"o6& tories G-10 and G-11 above with respect to all cnswers previously provided to Wella Eddleman by Applicants re Contention 65 on dinscovery. (b) Please identify all documents responsive to 3-10 and/or G-11 or any part or s ubpart(s) thereof, which have not already been identified in your discorewy responses.
65 9 (a): cf the concrete sanples mentioned in (i) Exhibit 1 (ii) Exhibit 2 of your 11-11-83 Supplenental Resnonse re Fddlencn 65, which of the sannles numbers listed thereon were retained? ,.
(b) If your answer to (a)(1) or (a)(ii) is other than "all" o'r wordns to that effect, please state (1) which sannles were ret retained, (ii) when each non-retained sannle was x disnosed of, if known, (iii) whether CP&L has a policy that deternines which semples will be retained (xis) if answer to (1$1) is affirnative, whether the sanples not retained were disuosed of in accovaance with that nolicy, and who ordered or oversaw such disnosal, and whether tre sannles disrosed of or not retained were selected in accordan,ce with that pox 11cy and if so by whon. (v) nicase state which sanples now in CP&L's possessf on 4 anong those listed in Exhibits 1 and 2 refer-ed to above can end will be made available to Wells Eddlenan or his censultant(s) f or insnect$ on; (vi) please state for which samples of these the test rerorts by CP&L or other tester (aa) were retained (bb) will be nade tvailable for inspection and conying to Wells Eddlene.n and/or his consultant (s9; (vii) if your answer to (vi) or (v) above withholds any samples or renorts you now retain, rlease state each reason for wf thholding or renort each such sannle g fron insnection and/or conying.
(b) were any sannles fron any of the nours listed in ExPibits 1 and/or 2 referred to above taken, but not listed on either 7xh! bit 1 or Exhibit 2? (c ) If answer to (b) is affirnative, niense list each such sample frc.n each such cour cnd state, if kncwn (i) l(y?fttGtoneE,
i why it was not retained (ii) who took this samnle (iii) whether it was taken in accord with aupliccble concrete placement procedure (s)
. (iv) any reason why it was not listed on the Exhibit in ouestion, (v) whether there is a teEt renort on it in CP&L's or a Cr&L consultant, employee contractorforsubcontractor'snossession(vi)whethertherenort and the sample will be made available to Wells Eddleman and/or his consultant for insnection and/or copying (no, I don't want to copy concrete' samples, tho a photo might be of use).
65-10(a) what were the weather conditions at the time of
("216002")
the 8-17-78 placenent'ECBSL216002 1dentified on Exhibit 1 of 7
your 11-11-83 resuonse? If you don't know, say so. (b) will you make the pour package on this single placement, or a e ory of it, available to Wells Eddlenan for inspection and conying? (c) will you make the concrete placement renort on this pour available to
-Wells Eddleman for insnection and conying? (d) how nany voids were found in this nour? If you don't know, please say so. (e) how large an area of honeycombing was found in this nour? If you don't know, please say so. (f) ilas this nour et elevation 216?
(g) Was this nour part of the construction of the level at elevation 2167 (h) Ifxxxxxx what is the significance of the numben 216 in the placement number? (1) was there a placement number ICB."L 216001?
j (j) was placenent nunber IC32L 216001 part of the containnent building?
(k) was niacenent " " "
nart of the base mat?
(1) was placenent " "
" sinilar to #216002 ?
l (m) did placement " " "
cover or abut placement 216002?
(n) do you possess the pour uackage for placement ICBSL 216001?
l l (o) If response to (n) is affirmative, will you make this pour package for ICBSL 216001 available to Wells Eddleman for connarison, xinsnection and copying, or will you make a copy of it and/or a cony of its concrete placement renort available to W.E. for inspection & conying?
p c
65-11(a) Are there any concrete nours in the Harris containnent L'e[3 cr base nat
~ j\ for which the concrete placenent renort does not new exist? (b)
If response to_(a) is affirnative, niease identify each such nour and give all explanation you know as to why the concrete placenent
-report does not now exist. (c ) Are there any concrete pou"s in the Harris containment building or base nat for which CD&L does not possess a copy of the concrete placenent renort? (d) If answer to (c) is affir:.mtive, please identify each such nour not already identified in resnonse to (b) above, and give all exnlanation CD&L
.knows as to why CP&L does not a nossess a e ony of such renort.
(e) For each report identified in response to (d) above, does someone else possess a cony of the ccncrete ple.cenent report?
(f) If ansuar to (e) above is affirnative, nlesse iddrtify who possesses a cony of each such report and state all *easons known to you why that pewson or enatity, cornoration, etc vocsesses a' cony of the concrete placenent renort. (g) does CP&L o" Daniel policy or e have any procedural rec,uirenent to reta' n correte viscenent repn=ts (1) for safety-related concrete (ii) for concrete in the containment
, building (iii) for concrete in the base nat? (h) If answe* to any naat of (g) above is affirnative, niease identify each such policy and state whether it would annly to any concrete placenent renort(s) identified in response to (b),(d) or (e) above, and if so, to which renort(s) for each such policy or nrocedural recuirenent.
(j) Is there any renort identified in resnonse to (b),(d) or (e) above for wnich ~ failure to retain the renort is a violaticn of NFC regulations or a deficiency or nonconn11ance or failure to follow procedure under NRC regulations? (k) If answer to ( j ) is affirmative, please identify each such report and give deta*ls of the EPC regulations not conplied with and when NRC was first made aware of this failure to connly.
l .
or sunevvised or observed 65-12(a) Does CP&L employu anyone who didg concrete work on the '(1) base mat (ii) containment of (aa) Callaway (bb) Volf Creek (cc) Farley (any unit of such plant (s))? (b) Does CP&L emnloy anyone who observed ulacement of concrete in the base nat or containnent cf.Farley, Woff Creek, or Callaway? (c) Does CP&L employ anyone who designed conrete nixes or mixed concrete or supervised or verified coverete nixing at the sites of WoIf Creek, Callaway, of Faricy? (d) If resnonse to (a),(b) or (c) or any subnart thereof is affirnative, clease idct?tify each such nerson, state the plant (s) each worked at or observed at, and state the nature of (1) the work done by the nerson (ii) the work observed by the person (iii) the work supervised by the person. (e) State which of the persons identified in resncnse to (d) above is available for deposition (1) before February 15 (ii) before March 1 (iii) before March 15, 1085k.
65-13(a) Does Co&L have any record of the tines of pouring all the concrete pours in the Harris containment, base nat, ha exteDior (containment) wall, and done? (b) Does C?&L have any explanation for the fact that every pour listed in Exhibit 2 of vour 11-11-83 sunplemental response is in the morning houns excent one at 12 noon?
(c) Does CP&L know how many or what ne=centage of the concrete tours made at Harris 1 for the containment buildinF were made in the morning, and how many ef ter noon? (d ) 'Till CP&L nake available for inspection And cooying any docu: cents giving the times of the concrete nours for Harris 1 as inquired abcut in (a) above ? (e)
If answer to (d) is other than affirnative, or there is an objection to (d), will-CP&L nake the time data for the nours available to Wells Eddlenan? (f) Please give (1) the nercentage of norning pours (ii) the percentage of noon-or-after nours of concrete for the Harris 1 containnent building (iii) any exnlanat tnn asked about in
r 65-13(f) continued (b) above as to why all the nours in the Exhibit 2 sanole are at noon or earlier in the day. (g) Is it true that no nore answers br. information concerning Eddleman 65 was made available to Wells Eddleman in the Applicants ' 1-13-84 sunnlenental " responses on contentions 41 and 65"?. (h) If answer to (g) is other than affirmative, state what information re Eddlenan 65 was provided, since I cannot find any. (j) which of the pour sunenvisors identified in Exhibits 1 and/or 2 to your 11-11-63 s unnienental response re Eddleman 65 are still employed by (aa) Daniel (bb)
CP&L (cc) any other CP&L subcontractor? (k) which persons inquired about in (j) above will CP&L provide the last known or tresent address of to Wells Eddlenan for contact for possible deposition? (1) If your answer te (k) abo m is other than affirmative, or if (k) is objected to, niease give all reasons for your answer or objection, including any reasone that differ between individuals inquired about in (j) above, statinF to which person (s) each reason anplies.
65-14(a) Are IC?SL216001 and IC3SL216002 ika two large pours in the Harris containnent base nat? (b) Will Co&L excitin, mark on bluenrints or otherwise identify where each of the 2 pours asked about in (a) above was a located in the Harris containment?
(c) If answer to ('o) is affirmative, please identify where each is located (can be done org117 or in documents at document production);
not affirnative, or is if answer to (b) is negative, nicase give all reasons sky for that answer. (d) How were voids detceted in pour 21600P? (e) How was honeyconbing detected in pour 216002? (f) whe*e, and to what extent were (1) voids (ii) honeyconbing (iii) other defects found in nour 216002? (g) Nnhat nethods were used to detect (*) voids (ii) honeyconbing (iii) other defects in pour 216002?
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- 65-14 continued (h) were the same methods described in , your response to (g) above used to check pour IC3SL216001 for (i) voids (ii) honeycorSing (iii) other defects? (j) Were the same nersons in charge of checking noun IC3SL216001 and 216002 for (i) voids (ii) honeyconbing (iii) other defect (iv) defects? (k) were the same nethods used and/
to check these x 2 pours for voids, honeyconbing, or Rother defects?
(this may have b'een covered in a ,. E past answer, if so , so state).
(1) identify each person who achecked or insnected the 2 pours (or either of then) inquired about in (j) above for (i) defects (ii) noncompliance with apolicable NRC regulations (iii) non compliance with anplicable NRC requirements (iv) connliance with anplicable procedures (v) conpliance w ith anplicable codec ( e .g . AS?3E )
(vI) voids (vii) honeyconbirg (viii) concrete star.*encth (ix) slump (x) other defects (xi) taking of sannles (xii) connosition of the concrete (xiii) consistency of concrete concosition throughout the pour, i.e. in various batches used in it.
(n) identify which of the person (s) identified in response to (1) now above (1) Kiili work for (aa) Daniel (bb) CP&L (cc ) NDC (dd) other encloyer, please state enployer's nane, to your knowledge (ii) are available for denosition (aa) before Feb 16 (bb) befo=e March 2 (cc) before March 16, 19854 65-15(a) Which of the pour nackages identified in Exhibit 2, other
- than IC3SL216001, will CP&L make available (1) an copy of (ii) the original of, to Wells Eddlenan for inspection and copying?
(b) for any package you will not nake available either as an original or as a copy, please state all reasons you will not make it available for insnection and conying. (c) "hnt does ICBSL stand for? (d) What does IC3XW stand for? (e) Who filled out the infornation on ExRbits 1 and 2 of your 11-11-83 response?
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65-15 continued
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or versons (f) did the person who filled out thefinformation on Exhbits 1 and/or 2 obtain that information fron direct inspection of the (i) nour tackages (11) concrete . placement renorts, fon the tours listed on those 2 Exhibits? (g) If answer to any nart of (f) above is other than affirnativer please identify each individual who compiled the data in (1) Fxhibit 1 (ii) Exhibit 2 inouired about above, stating which individual conpiled which data, fron which source docunent(s),
stating whether each such document will be nade available for insoection and copying and ~whether each s uch individuti is available for.denosition at any time nrior to March 16, 198h.
65-16'/5Please identify the specific procedures annlicable to each pour identified in your 11-11-83 Fxhibit 1 o" "xhibit R 2 which aconprise those referred to in your response to interrogatory 65-1(a) (5-12-83 response at 29) as " site work nrocedures, technical procedures and adninistrative nrocedures".
(b) -Please state exactly how the batching process is monitored, at what intervals, and identify each procedure for batching process nonitoring used in connection with concebte '.n each nour incuired about in (a) above (i.e. those identified in 11-11-83 Exhibits 1 or 2).
(c ) Please state what tests were aoplied to the concrete constituent
-naterials of each batch of concrete used in each nour in nxak inquired about in (a) above. Please identify each document giving t
results of each such test, and all documents which soecify ghe procedures for each such test. (d) Please state the criteria used to accept or reject a batch of concrete (e.g. those used for the Harris (1) base nat (ii) other port! ons of cor'a'enent) End identify all docunents specifying nrocedures and/o* criteria for such accettance er rejection.(e) Please state who puts the nix design identification number on each. truck transporting concrete tc the pour locatien n aad
65-16 continued
- who takes it off and who holds onto the m'x design ID number and whether it is recofded in the pour package or retained in the pour package. (By "who" I mean job descriution or title unless you can readily identify specific individuals who did the actions. asked about for the pours inquired about in (a) above). 1 (f) Are the records and noriginal notes of the Construction Insnector wno"follown all aspects of the placing operation" in the pour package for each pour inquired about in (a) above?
(g) Are the test results of the OA insnector w: o "perforns air content, slump, unit weight and tennerature tests in addition to molding comoressive strength cylinders" for each ulacenent, and any original notes of this insnector, included in the pour nackage for that ulacenent! (h) Are the orig? nal notes
.and all reports of the Construction Insnector about " curing operations, concrete tennerature and noisture conditions" in the pour naczkage for each cour? (1) Uhat is checked for in the "nost placement check" by the Construction Insnector on the final quality of the placement? Is there a checklist used? What notes and documents on this check are in the pour package? Are there any that are not in the nour nackage?
or stages (j) At which stage of the inspections and checks desc=ibed in your answer to 65-1(a) were the voids and/or honeycombing in pour 216001 detected, and by whon? (k) Eow was each such defect identified? (1) were other defects identified in pour 216001?
(t) werc xikar any defects identified in any nour listed in Exhibit 2 of your 11-11-33 Resnonse? (n) ~f answer to (n) is affirnative, which defects were identified, in which nour(s), at Nhat stage of the checks and inspection described in vour answer to 65-1(a),
and by whon. (o) Is anything asked about in (j) through (n) for above which ixxmak all docunentation is not in the pour packages?
G ~
6 I '
65-16 continued
.(p) If answer to (o) is affirmative, for each such thing for each
-pour identified in Exhibit 1 or 2 of 11-11-83 response, identify all-documents known.or believed to contain the information a sked about.
' Identify who possesses each such document.
(q) Please identify each person not listed in resnonses above who
. identified any defect in any pour listed in Exhibit 1 on 2 of 11-11-832, which. Exhibits are referred to above.
(r) Which repair procedure (s) were used to *epair each defect each in (i) pour 216001 (ii) any pour listed in Exhibit x 2 where_ any defects have yet been fouhd.? (s) For each nrocedure nxsdrurWx identified in x response to (r) above, please state (i) the date it was used (ii) the date the uroceduwe was originally anpaoved (iii) the date any revision of the nrocedure which was actually used for the repair was anproved (iv) identification of each document containing (aa) the original proceduwe (bb) the nrocedure used to make the actual renair (ce) any further revisions of the trocedure since the repair was nade; (v) identificat"on of any document (s) referred to in the procedure or any version of it which was actually used to nake the renair, and of any docunent(s) requesting and/or anproving change (s) in the urocedure eithe" before or after the renair was made.
(s) Who verffied, x for each wurh renair nade to each nour listed in Exhibit 1 or 2, that the repair was nade "using presc*ibed repair
. procedures? (t) Did the nerson making tha verification asked about in (s) above have in hand a cony of each nrescribed renair nrodcedure at the time of making the verification? (u) If answer to (t) is other than affirnative, did that nerson have available readily a cony of each nrescribed repair urocedure actually being used in the repair, at or within one hour on so of the time the renai* wanus l
made?
k 65-16 continued (v) Descri'oe the procedure used to sunmarize "all inanection docunents" into a concrete nour package. Is this a written If so, procedure? Who kniease identify did the each docunent summarizing for eachtelling how the sunnarizing's pour package done.
identified in Exhibit 1 or 2? Vno was the Construct *on Insnection Sunervisor who " reviewed" each such pour package "for accuracy and conformance to procedures"? (cf. page 30
~
of 5-12-83 responses)
(w) Were any inaccuracies or noncoxnfornances to nrocedures identified by the Construction Insoect?en Sumevvisor prior to the subnission of each pour nackage for each pour identified
'in Exhibit 1 or 2, prior to "being subnitted to or fo* ff nel =eview"?
If so, please state what (i) inaccuracies (ii) non m='ornances, to which nrocedures, were ' identified, by when, for which nou=(s),
and state whether the nerson who identified then still works at Harris, and if so whether s/he is available for deposition be o-ec March 16, 198h and if not whether CP&L will nake available the nerson's lart known address to Wells Eddlenan.
C)
(x) Were any inaccu"acies or nonconformances to procedu*esj found by or (ii) reported to 01, (aa) during final review (bb) aftew final review, for any pour or pour package for any tour identified in Dthibit 1 or 2?
.(y) If answer to (x) or any part thereof is affirnc.tive, clence identify each such inaccuracy or nonconfornance, when it was found or reported to OA, who found or renorted it, what was done abotit it, and identify all docunents renorting it, describing n=ocedures used lor for dealing with it, stating what was doneaboutit,andfannroving what was done about it. Please also state whether there was a proceduve in place for dealing with the inaccuracy or nonconfo= nance at or before the time it was found or renorted, identifying all
g- _ _ _ _.
(
65-16 continued documents containing each such trocedure, and to what nour(s )
each procedure applies. Please state also if the nerren who found or. renorted each such inaccuracy or nonconfornance still works at Harris, and if so, is s/he is available for denosition before March 16,198h and if .not, whetnher CP&L will nake available such nerson's last known address to Wells Eddlenan.
(z) Which of the nouns identified in Exhibit 1 o* 2 has the NRC inspected l(i) prior to nouring (ii) .during couring (iii) after nouring, including insnection of the finished concrete; (iv) the renairs of (aa) during repairs (bb) after repairs were completed.
Please state also if any violations or nonconpliances with NRC regulations or failures to follow urocedu"es or deviaticns or deficiencies were found related to any nour identified in Exhibit 1 or 2 (cc) by CPhL (dd) by N9C (es) by CFAL but not recorted toENRC.
65-17 (a) For each cour identified in Exhibit 1 or P, identifv (1) the itens rlaced for enbedding in the niacenent (ii) the inspectur(s) who "exanine(d) all items to be enbedded ... pwlor to the actual nlacement and document (ed) the insnections for accent /we ject criteria. (b) What are the accept / reject criterid of of for (1) olacenentg(ii) alignnent4(iii) distance betwee6 rebars (aa) used in tour LC3SL 216001 (bb) used in nour ICBFL 21600P (cc) used in other pours. identified in Exhibit P. Please identify all documents Eiving each such accept / reject criterion and stating to which pour (s) each applice if it does not ann 1t to all of then.
(c) Please identify, for each tour in Exhibit 1 or 2, the Construction Insnector who exanined the itens rrio" to niacenent, and the Construction Insnection Sunervisor vlo reviewed the cour package prior to nlacement. Vlease also state how the inspection docunents nrior to placenent ave combined into a " pour
-P1-package" and whether this is done by a written nrocedure and if so identify the written vrocedure used for each conbining of documents into a nour nackage fo* each tour in Exhibit 1 or P, and' identify all docunents conta$ ning each such ovocedure.
-(d) State which, if any, inaccuracies uere found bv the - Construction LInspection Supervisor in the nre-clacenent pour nackage for (zi) pour ICBSL 216001 (ii) nour 216002 (iii) each othe* pour identified in Exhibit 2. (e) were any rese*ve cylinders tested on rour P16001?
If so, what were the results? Please identify all docunents whrich (1) ordered or requested such testing -(ii) contain urocedu*es actually used in such testing (iii) F ives results of such testing.
65-18(a) What measures were taken on nour P16002 to" prevent the formation of honeycombs and voids" (cf. 5-12-83 resnnroe at 31).
(b)-,Were the neasures taken on nour IC3SL 216001 any different, for preventing the formation of honeycombs and voids, than on P16002? (c) Were-the measures taken on pours after 21600P in the containnent building at Harris revised in any way (1) after nour 216002 was found to have void / honeycomb defect (s) in it?
(ii) in resconse to the defect (s) in nour 21600P? (d) If answer to (c ) above is affirnative for (i) or (ii) in (c),
please identify all docunents (1) reonestinF the chance in procedure (ii) anproving the change in nroncedure (iii) justifying or weighing the nerits of the change in nrocedure (iv) Ei ving the new nrocedure. (e) Please identify any docunent 6 or docunents which give the nrocedure(s) to be used to prevent formation of noneycombs or voids which were used (1) on nour ICESL 216001'(11) on cour 216002 (iii) on other cours listed in Exhibit 2.
(f) Please state whether a written deternination of the dif ficulty of olacenent for nour (1) ICBSL 216001 (ii) P16002 (iii) or other
65-18. continued pours found in listing in Exhibit 2, was nade prior to each such placement. ~(6) If answer' to any pa*t of (f) above ig affirmative please identify each'docunent containing such written deternination, state whather such- document is in the possession of CP&L, state whether it is in the pour ra0kage, state whether CP&L knows if
' anyone else has a cony of the document (and if so who, nicase identify)
(giving name and address). (h) Nere any of the nocrs listed
-irf Exhibit 1 or 2"deternined to be difficult" naior to nouring?
(cf. pp- 31-32 of 5-1P-83 responses) . If so niease list which ones and state how the difficulty was determined if not already stated in response to interrocatories above. (j) w'.o f selected the concrete nix for nours (1) IC3_SL ?16001 (ii) 21600P (iii) otherwise listed _in 7xhibit ?? (k)was a" super ulasticized mitx" (cf. p 32 of 5-12-83 resnonse) used in nours (1) P16001 (211) P1600?
_(iii) otherwise listed in Exhibit 2? If so, who desiF ned it?
(1). das the " preventative progran . . . used during actual nlacenents ...
(in which) construction insnection versonnel constantly watch the placenent to insure that adecuate consolidntion is being used to effect'a demnse and honogeneous concrete placenent" in use on nour 216002? If so, who were the personnel who continuously
. watched the niacement, and how long did each one wa yh 'or,1f known?
(n) Was "special attention given" (cf n.32 5-13 83 rasnonse) to vibration of concrete during pour 21600P? If so, by when? If not, why not? (n) were craft nersonnel on prur P16002 already instructed, unior to the pour, on tho innortance of adecuate vibrat* on?
(o) does CP&L or Dnniel have iny infonnation on whethe= the voids and/or honeycombing on nour 216002 were caused by o- contributed to by (1) the concrete nix (ii) its niacenent (iii) inadequate watchfulness l
i over the nlacenent (iv) inadec.uate vibration du-ing or afte" the placenent (v) other causes known to you or identified in reno"ts?
p.
L F:m
- 65-18 continued (p) If' answer to any part of (o) is affirnative, please identify all docunents containing such information.
(q) Were voids and/or honeycombing detected in pour 216002 during its nlacenent? (r) were voids and/or honeycombing detected in nour 216002 after its placenent but befo=e its " Post Placenent v s Insnection" .(cf 5-19-83 at 32) (s) were foidd and/or honeyconb_ing detected in nour,21600P at its Post Blacenent Inspectien?(t)
Were voids or honeyconbing detected in tour x 216002 after its nost placement inspection.at any time up to the present?
(u) For each affirmative answer to any of (q) thru (t) above please state (1) who found the voids (ii) how they were found (iii) who found the honeycombing (iv) how it was found (v) when the voids and/o" honeycombing were first renorted to RA, and when they were first renorted to the Construction Insnection Supervisor, identifying the Sunervisor to when they (or it) was/were renorted; (vi) uhen repair oneration began (vii) who sunervised the repair overations -- if nore than one person sunervised then, identify each one and state what nart(s) or the repair each suneavised (viiil who inspected the renair oneration (ix) whether the insnector had in hand at tha tina of the .inenect'n- the n~ocedure(s) nxmixxx then annroved *or making such recairs (x) whether any insnection other than of exnosed concrete surfaces of nou" 216002 was over
_nade for honeyconbing and/or voids, and if so when, by whon and how, with what results, identifying all docunents requesting such insnection, giving the insnection nrocedure used, or docunenting the results of such insnection (x1) how thick the nortion(s) of cour P16002 exanined visually at the surface for honevconkiing n
and/or voids are (e.g. vertical denth or hori=otal thicknest at each point inspected, or overall denth or thickness); (xii) how, and for how long, each repair in nour 216002 was cured, and who inspected
C
= .
65-18 continued ths curing and who supervised it (xiii) whether each person identified in response.to other parts of (u) above still works at Harris, and if so, whether that verson is available for denosition before March 16, 1984, and if not, whether that person's last known address will be'nade available to Wells Eddleman.
65-19. Why was no ultrasonic testing or inspection _ nersforned (1) on concrete at Harris, e.g. in the containment (ii) on nour 216001 (iii) on nour 216002? Please state all rensnne for your answens.
(cf. 5-12-83 at 32).
65-20. - Please explain the apparent discrepancy between your answer to 65-1(h) that there were 103 areas of veoids/hencyconbs out of corroxinately 500 niaconents in the Unit 1 containment Suf _nF that -eauired structural renair- (5-12-83 at 33) and your answer to 65-1(b) at o.9 of 11-11-83 Snecifically, what concrete in the unit 1 containment building that is NOT nart of the base na t, exterior walls or done, has honeyconbing or voids in it? Were all 103 voids or honeycon#s in pour 2160027 Were sannles of the renair concrete taken for all 106 repairs? "fere any of these sa:~nles retained more than 30 days?
Does CPL:L or Daniel or anyone else known to you stilpossess any of then?
65-21 Who crecared each repair nrocedure used on voids /honnycorbs
-(i) in nour 216002'(11) elsewhere in Ear-is 1 containment?
Ebasco?
Dcniel? CP6:L? - Who annroved each, and when? ' ras thir before or after each repair was nade? Have any such venairs exhibited cracking or chinning to date to your knowledge (aa) in nour P1600P (bb) elsnewhere in Unit 1 containnent" (cf 5-12-83 at 33 and 'h) 65-22 were any drawings nrenared or nade of the retnixrs to voids and/or honeycombs in (1) nour 216002 (ii) other pouns in Ea--is 1 containment? If so, niease identify each such d-awing and which rour(s) it relates to (cf. h(a) answer, 5-12-83 a t 37 )65-23d were any nonstandard clearances between reba-d involved in
c-65-23 continued c -the area of (i) nour 216002 (ii) pour 216001 (iii) other nours in Exhibit 2 inside Harris containnent? If so, niease identify all docunents stating the nonstandard clearance or the reason ifor it and/or requesting it or atproving it.(hWere any bars in (1) nour 216001 (ii) nour 216002 (iii) other nours inside Harris containnent nade with rebar nove than 18" from center to center at any point, to your knowledge? If so, which ones, who apuroved it and when (e.g. before or after conex 2ete niacement,
. on what date) and was such apuroval inx accord with any anuroved nrocedure? If so, identify all docunents anproving it' and for giving the trocedure ander which it was ann"oved and/or reouesting it.
65-2dWhatwastheslumnofsmarxeachnourlistedinExhibit2?
~ lbWhat was-the slunn of nour 216002? (c ) does "fif ty yards" in your answer to 65-k(g) of 5-12-83 refer to each fifty cubic yards of concrete? (d) if not, what does " fifty yards" in that answer mean or refer to? (e) Was the sluno unifora across nour 216001?
(ii) across nour 216002? (iii) If not, nlensc give all the slumn levels for each nour, 216001 and 216002.
65-25 (a) Is nour 216002 in the Harris conta$nnent 2x1 wall?
(b) or is it-in the base nat?
65-RR26(a) Was any concrete in nour 216002 rejected ',y any inspector or check at any tine, and still noured in that nour?
(b) Was any concrete prepared for cour 216002 rejected? If so, what was done with it? Does CP&L or Daniel know where it is now?
If so, where is it? Does CP&L or Daniel know anything about whe*e it would be or could be or is, regardless of knowing its exact location?
65-27 (a) Was. any concrete in any nour identiried in xxhibit 1 or 2 (to your 11-11-83 resoonses) found to be "out of snecification" during or after the . pouring? (b) If so, how did it get by the careful inspection you say is done-on the concrete nixx? (c)
. fcr each such pour, niease state which discrenancy renorts apply to- (1) pours inside liarris containment (ii) pour 216001 (iii) pour 216002 (iv) other nours listed in Edibit 2, identifying each~ such discrenancy renort and all docudents of (c) containing it. above, identify each (d) For (i) thru (iv)A deficiency and disposition report.that anulies to each
- discrepancy lrenort for each such nour. If you thf nk it burdensone, do-only (11)~thru (iv). (e) For (i) thru (iv) of (0) above, niease state which civil Non-Confornance Report (s) apply to that nour and/or each discrenancy recort
. or. deficiency and disposition renort for that nour. Are these ,
renorts_(dierepancy renort, civil non-confornance renont,
. deficiency cnd disposition renort) identified in the nour package for each such noub? If se, will vou nske the identificatfon available for insnection and conying? If not, where if anywhere are they listed or referenced in your records? Will vou nroduce any records licting then or raferencing then for insrect* en and conying, at least for the nours listed on Exhibits 1 and 2? 7 If not, why not? bh E' N*E V OOU ?
houNau m PRODUCTION OF DOCM'NTS nsJ5wh* IkC P'25)1'[l f cddrad-Wells Eddleman hereby recuests Arnlicants to nake available for insnection and copying the orig *nal or bent copv o# all documents identified in resnonse to the above inte~og atovies, or at least a copyable, legible cony of each cour package and the best available cony of everything else identified abeve oft in Exh! bits 1 and 2 of 11-11 93 resnonse. /