ML20080B808
| ML20080B808 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/03/1984 |
| From: | Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | PHILADELPHIA, PA |
| Shared Package | |
| ML20080B812 | List: |
| References | |
| NUDOCS 8402070282 | |
| Download: ML20080B808 (11) | |
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'84 fen -6 D1 :37 UNITED STATES OF AMERICA NUCLEAR BEGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
APPLICANT'S FIRST SET OF INTERROGATORIES AND PEQUEST FOR PRODUCTION OF DOCUMENTS TO CITY OF PHILADELPHIA ON CONTENTION I-42 Pursuant to the Rules of Practice of the Nuclear Regulatory Commission ("NRC"), 10 C.F.R. 52.740(b), and the Atomic Safety and Licensing Board's Memorandum and Order (October 28, 1983), Philadelphia Electric Company ("Appli-cant") hereby propounds the following interrogatories to the City of Philadelphia
(" City")
to be answered fully in writing, under oath, in accordance with the definitions and instructions below.
Additionally, pursuant to 10 C.F.R.
S2.741, Applicant requests that the City produce for inspection and copying 7,
(or provide copies of) those documents designated by it in its respective answers below.
Definitions and Instructions 1.
For each interrogatory, please state the full name, work address, and title or position of each person providing information for the answer to the interrogatory.
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The following definitions shall apply:
a.
" City" shall refer to the City of Philadelphia or any ' of ficial,
- officer, member, employee or consultant thereof.
b.
" Document" shall mean any written, printed, typed or other graphic matter of any kind or nature, and all mechanical and electronic sound recordings or transcripts thereof, in the pos-session, custody, or control of the City, or its officials, employees, or agents; it shall also mean all copies or draf ts of documents by what-soever means made, c.
"Date" shall mean the exact day, month and year, if ascertainable, or, if not ascertainable, the best approximation (including the event's relationship to other events in the relevant t
context of the interrogatory).
d.
"NRC" or " Commission" shall mean either the Atomic Energy Commission or the Nuclear Regulatory Commission, as appropriate, including its regu-latory staff and adjudicatory boards, as indicated by the context of the interrogatory.
e.
"Specify",
when referring to a proceeding before the Nuclear Regulatory Commission, means that the answer shall set forth the proceeding, applicant, docket number, relevant date, and any 4
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f.
"Specify" or " identify", when referring to an individual, corporation, or other entity, means that the answer shall set forth the name, present or last known work address, and, if a corporation or other entity, its principal place of business or, if an individual, his or her title or titles and employer.
Once an individual corporation or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereaf-ter when identifying that individual, corporation or other entity to state merely his, her or its name.
3.
These interrogatories request all knowledge and information in City's possession and/or knowledge and information in the possession of city officials, officers, agents, representatives, consultants, and unless privileged, attorneys.
4.
In each instance in which an interrogatory re-quests a statement of City's assertion, contention, view or opinion, the answer shall also contain a full discussion of the factual basis for the assertion or opinion.
Interrogatories 1.
State whether the City intends to present any expert witnesses on the subject matter at issue in Con-tention I-42, as stated in Limerick Ecology Action's letter
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' 9 dated July 11, 1983 and admitted by the Licensing Board in its Memorandum and Order dated October 28, 1983 (slip op. at 2).
If so, identify each expert witness and state (a) his professional qualifications; (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) the grounds for each opinion.
Identify by court, agency or other body, each proceeding in which such individual rendered testimony on this subject.
2.
State whether the City intends to present any factual witnesses on the subject matter at issue in Con-tention I-42.
If so, identify each such factual witness and further state (a) his profecsional qualifications; (b) the subject matter on which the witness is expected to testify; (c) the substance of the facts to which the witness is expected to testify.
Identify by court, agency, or other body,. each proceeding in which such individual rendered testimony on this subject (s).
3.
Identify by title, author, publisher and date of issuance or publication, all documents that the City relies upon as a basis for contentions or that the City intends to use (by way of reference or evidentiary proffer) in present-ing its direct case in cross-examining other witnesses on Contention I-42 and all documents to which the City intends to refer in conducting cross-examination of other witnesses who may testify in connection with any such contention.
. 9 4.
To the extent that your answer to any interroga-tory is based upon one or more documents, (a) identify each such document on which your answer is based; (b) identify the specific information in such document upon which you rely; (c) explain how the information provides a basis for your answer.
S.
To the extent that your answer is based upon any study, calculation, research or analysis, (a) describe the nature of the study, calculatin, research or analysis and identify any documents which discuss or describe the study, calculation, research or analysis; (b) identify the per-son (s) or entity (ies) who performed the study, calculation, research or analysis; (c) describe in detail the information which was the subject of the study, calculation, research or analysis; (d) describe the results of such study, calcu-lation, research or analysis; (e) explain how such study, calculation, research or analysis'provides a basis for your answer.
6.
To the extent that your answer is based upon conversations, consultations or correspondence or other communications with one or more individuals or entities, please identify each such individual or entity; (b) state the educational and professional background of each such individual, including occupation and institutional affil-iations; (c) describe the nature of each communication, including time and context, and describe the information
F 4 9 received from each such individual or entity; (e) explain how such information provides a basis for your answer.
7.
To the extent that the City possesses information or documents expressing facts or opinions which are relevant to the specific interrogatories below, but which do not support intervenor's position or which have not otherwise been fully provided in the answers thereto, please provide such information and documents.
8.
Specify each system, component or part of the Limerick Generating Station which the City asserts is "important to safety" within the meaning of 10 C.F.R.
S50.49(b) which has not been included in Appendix B of the Environmental Qualification Report
("EQR")
for Limerick.
Your response to this and subsequent interrogatories should consider the revisions made to that document transmitted to the NRC (Mr.
A. Schwencer) by Philadelphia Electric Company (John S.
Kemper) on January 16, 1984, including the revised Appendix B.
As to each such component or part, (a) describe in detail the component or parts and their exact location at the Limerick Generating Station; (b) identify the manufacturer, if known; (c) identify whether the component or part is asserted to be within the category "important to safety" because of its inclusion within 10 C.F.R. 550.49b (1) (2) er (3), describing in detail the reason for classification in one or more of these categories; (d) describe in detail the alleged "important to safety" function which the ccmponent or part will perform; (e) state
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the basis which the City used in concluding that another system, component or part, or combination thereof, which is being qualified or which is not within a harsh environment cannot perform the function instead of the subject part or component; (f) state the basis, if any, upon which the City acaerts that environmental qualification ~of such component or part will not or could not be performed prior to fuel loading for Limerick Unit 1 or 2, as appropriate; (d) the exact event or events for which the City asserts that the equipment must be qualified, the time or times after the initiation of the most critical event during which the part or component is asserted to be necessary to operate, and the exact environmental conditions which the component or part would experience.
9.
Identify any and all components or parts listed in Appendix B of the EQR, as updated, which the City asserts will not be environmentally qualified by the time of fuel loading for each unit, giving the basis for such conclusion and stating when the City believes such part or equipment will be qualified, giving the basis for such conclusion or estimate.
10.
-With regard to each of the following
- parts, components, or systems which intervenor LEA alleges should be included in the equipment qualification program, (1) feedwater control; (2) emergency lighting and communications systems; (3) plant process computer system; (4) computer software, to the extent the City agrees with LEA that such
> y equipment must be included in the environmental qualifica-tion program; (a) identify the exact
- systems, part or component
- involved, with reference to the description contained in the FSAR or P&I.D.'s, if possible; (b) identify the location or locations of the systems, parts or compo-nents at the Limerick Generating Station; (c) identify the conditions, e.g.,
LOCA or HELB, which the City asserts require that these systems be qualified; (d) identify the operations that such equipment would have to perform for such conditions and the time frame in which these actions are required; (e) identify the harsh environment that such equipment, part or component would experience; (f) state the City's understanding of systems, equipment, parts or compo-nents which can perform functions equivalent to those identified above and which are either being qualified or are not located in a harsh environment and state why this other system, equipment, part or component is not sufficient to perform the intended function.
11.
As to each " human interaction problem" which the City asserts should be addressed by Applicant in its En-vironmental Qualification Report for Limerick, if any: (a) specify what is meant by the term " human interaction prob-lem"; (b) identify the exact location of such component or part; (c) specify each component or part which the City alleges should be the subject of such a " human interaction review";
(d) icentify the manufacturer of the part or component, if known; (e) specify the "important to safety"
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function which requires analysis of human interaction with regard to the particular part or component; (f) state the specific basis in NRC regulations or regulatory guidance for performing such a review as to the particular human inter-action and part or component; (g) state the elements of the human interaction
- review, including
- goals, methodology, experimental work, studies, data analysis techniques and basis for evaluating the results which the City asserts is necessary.
12.
As to each component or part for which the City asserts that an Equipment Qualification Review Record
("EQRR") has not been provided in Applicant's Environmental Qualification Report for Limerick, (a) specify each part or component allegedly omitted; (b) identify the exact location cf such component or part; (c) identify the manufacturer, if known; (d) state the basis upon which intervenor relies to assert that such part or component should have been included in an EQRR.
I 13.
As to each part or component for which the City asserts that the EQRR specifies a qualified life of less 1
than 40 years, (a) specify the part or component; (b) 1 identify the manufacturer, if known; (c) the corrective action which intervenor asserts should be taken by Applicant to correct the alleged deficiency, the basis upon which the means for identification of such itema by Applicant as discussed on page 8.2 of the Environmental Qualification Report is insufficient to meet NRC requirements.
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14.
State the City's basis, if any for the assertion I
that the key switch in the control room for the standby liquid control system' is in a harsh environment and thus subject to. qualification pursuant to NRC requirements.
15.
State what electrical equipment in the PASS system, if any, the City asserts must be qualified; specify how failure in such electrical equipment could mislead the operator.
16.
Identify each and every way which the document, Philadelphia Electric Company Q*5 Component Classification Program Rules fails to provide a methodology for assuring that equipment, parts or components falling in the defini-tion of 10 C.F.R.
S50.49(b) are not properly identified.
The response to this interrogatory may contain proprietary material; if so, it should be sent only to Applicaat's 4
counsel in Washington, D.C.
Request for Productidn of Documents Please attach to your answers to the interrogatories listed - above a copy of all documents applicable to such answer or upon which you otherwise intend to rely in the presentation of your direct case or in the cross-examination of other witnesses, whether or not they support your 9
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Alternatively, please state that all such documents will be produced at a reasonable time and place to be agreed upon by the Applicant for inspection and copying.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Mark J. Wetterhahn Counsel for Philadelphia Electric Company February 3, 1984 l
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