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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
MONTHYEARML20151L5181997-08-0505 August 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately) Re SL Nevin Deliberately Falsifying Records of RECW Sample Documentation on 960207 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 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 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 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 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 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 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 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 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 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 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 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 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 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 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 ML20248D5671989-08-0202 August 1989 Affidavit of SE Feld.* Advises That Author Prepared Response to Question 5.W/Certificate of Svc ML20248D6451989-08-0202 August 1989 Affidavit.* Advises That Author Read Responses to Request for Comments by NRC & Knows Contents.W/Certificate of Svc 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 ML20248D4971989-08-0202 August 1989 Joint Affidavit of Gy Suh & CS Hinson.* Advises That Authors Prepared Responses to Questions 1 & 4 ML20248D5311989-08-0202 August 1989 Affidavit of Rj Barrett.* Advises That Author Prepared Response to Question 2 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 ML20245J1321989-07-27027 July 1989 Transcript of 890727 Meeting in Rockville,Md Re Facility Severe Accident Mitigation Issues.Pp 1-130.Supporting Info Encl ML20247N3261989-07-26026 July 1989 Transcript of 890726 Affirmation/Discussion & Vote in Rockville,Md on SECY-89-220 Re Order Requesting Info from Parties for Immediate Effectiveness Review of Full Power Authorization for Limerick Unit 2.Pp 1-4 ML20248D7331989-07-24024 July 1989 Second Rept of Parties & Request for Dismissal of Graterford Inmates Contention & Termination of Proceeding.* Requests Board to Enter Order to Terminate Proceeding Based on Parties Agreeing to Dismissal of Remaining Contention ML20247Q4621989-07-23023 July 1989 Response of Intervenor Rl Anthony to Answer of Philadelphia Electric Co (PECO) to Request for Hearing on PECO Application for Low Power Operation of Unit 2 & Stay of Any Operation in Keeping W/Us Circuit Court Remand Of....* ML20247B7261989-07-20020 July 1989 Notice of Appointment of Adjudicatory Employee.* Advises That H Vandermole Appointed to Advise Commission on Issues in Proceeding Re Severe Accident Mitigation Design Alternatives.W/Certificate of Svc.Served on 890720 ML20247B3821989-07-18018 July 1989 Memorandum & Order.* Orders That Severe Accident Mitigation Alternatives,Per Nepa,To Be Considered Include Containment Heat Removal,Core Residue Capture & Venting.Certificate of Encl.Served on 890719 ML20247B7641989-07-13013 July 1989 Motion of Intervenor,Limerick Ecology Action Inc,To Reconsider/Stay/Suspend/Revoke Order Authorizing Issuance of Low Power OL for Limerick 2.* Consideration of Accident Mitigation Alternatives Imperative.Certificate of Svc Encl 1997-08-05
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of }
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Philadelphia Electric ConPany ) Docket Nos. 50-352
) 50-353 (Linerick Generating Statiou )
Units 1 and 2) )
APPLICANT 'S ANSWERS TO INTERVENOR AWPP 'S FIRST SET OF INTERROGATORIES ON QUALITY ASSURANCE / CONTROL i
i DISCOVERY 15 l DECEMBER 5, 1983 l
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- Interroaatory No. 1 Provide all correspondence or telecon records from the Nuclear Regulatory Commission or any of its agencies, for example, Inspection S Engineering (IE) , to Applicant, and Applicant's response (s) directly or indirectly relating to
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weldina infractions at Limerick from 1974 to present.
Answer Correspondence between Applicant and the U.S. Nuclear Regulatory Commission relating to ISE inspections at Limerick which identified infractions have been previously provided under Discovery 14, Item 1 and is available for inspection and copying under that discovery designation.
Correspondence between Applicant and NRC relating to welding and welding procedure infractions are available for inspection and copying (Discovery 15, Item 1) . This information was previously provided under Discovery 2, Enclosure 2, Items 1, 2, and 3 and has been updated to include correspondence between Applicant and NRC since this information was originally provided.
l l Telecon records relating to NRC inspections relating to i
welding and welding procedure infractions are available for inspection and copying (Discovery 15, Item 1) .
Participants in Preparation of Answer Vincent S. Boyer, Senior Vice President - Nuclear Power l
Philadelphia Electric Company
- 2301 Market Street
! Philadelphia, PA 19101 2
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- J. 5. Csrcoran Cunlity A=curanco Field Branch Head Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Harket Street Philadelphia, PA 19101 3
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InterrnorterY Na. 2 Provide all correspondence or telecon records from NRC, to and from Bechtel Corporation re velding infractions (including Bechtel sub-contractors) .
Answer No correspondence or telecon records between NRC and Bechtel Power Corporation or its subcontractors relating to welding infractions at Limerick have been identified.
Participants in Preparation of Answer Vincent 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 4
Interrocatory No. 3 Provide all documents, work records, and correspondence fro 3 the NRCr via IE reports on weldino infractions in which "use as is" disposition was used with or without NRC approval.
Answer Documents, correspondence and work records rslating to welding infractions identified by NRC in Inspection Reports involving velding done at Limerick and which were dispositioned "use as is" are available for inspection and copying. (Discovery 15, Item 3) . See also Discovery 14, Item 7 relating to the dispositioning of IE 76-06.
Participants in Preparation of Answer Vincent 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 G. Lauderback
' Quality Assurance - Engineer i
Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 5
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Interrocatory No. 4 He 76-06-01*, give names of craft and supnrvision personnel that " revealed plan to perform velding with the electrode fastened to a broomstick". * (NRC-IE 76-06-01-Failure to Weld Structural Steel Per AWS Code.)
Answer The craf t and supervision personnel with the welding with the J. Windsor, Bechtel, electrode fastened to an extension wore:
Structural Steel and Rigging, Superintendent; R. Johnson, Bechtel, General Foreman, Ironwork; R. Seisle, Bechtel, Foreman, Ironwork; G. P. Auclair, Bechtel, Welder.
Participants in Preparation of Answer Vincent 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
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- Interraantory No. 5 Re 76-06-01 give names of licensee, and contractor Q.A. and Q.C- Personnel who confirmed that welding was performed using broomsticks.
Answer The use of broomstick extensions to perform velds was confirmed by:
J. M. Corcoran, Field Quality Assurance Branch Head Philadelphia Electric Company E. R. Klossin, Lead Site Q.A.
Bechtel K. Bishop, Lead Welding Quality Control Engineer Bechtel W. Driver, Assistant Lead Welding Quality Control Engineer Bechtel L. McNamara, Welding Quality Control Engineer f
Bechtel Participants in Preparation of Answer Vincent S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l
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. J. 5. C,orcoran Qunlity Assuranco Field Branch Head Philadelphia Electric Company 2301 Harket Street Philadelphia, PA 19101 8
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Interroaatorv No. 6 He 76-06-01 give name (s) of qualified and unqualifica colders that used unqualified extensions above.
Answer The velder who performed the welds identified in 76-06-01 using an extension was a qualified welder, G. P. Auclair. No unqualified welders were involved.
Participants in Preparation of Answer Vincent 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 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 I
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Interroaatory No. 7 He 76-06-01, how many velds were performed at all locations detailed under 76-06-017 Answer Inspection Report 76-06-01 relates to two beam connections (Beam mark numbers 232B7 and 232B9) which are located in Area 13 near elevation 253', near column line 23 and respectively approximately 6'-5" south of H line and 68-9" north of F line.
The location of the two welded beam connections described above is circuled on drawings (C-193, Rev.17 and C-201 Rev. 8) which are available for inspection and copying. (Discovery 15, Item 7)
Participants in Preparation of Answer Vincent 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 10
Interroaaterv No . 8 Did applicant design and manufacture equipment as required by AWS, D-1-1-72, under Part 3.1.2 so as to enable qualified welders to meet the AWS Code?
Answer Applicant has not designed or manufactured equipment described in AWS, D1.1-72 under Part 3.1.2. Any such equipment needed for use at Limerick would be procured from a vendor of such equipment.
Participants in Preparation of Answer Vincent 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 l
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Interrogatory No. 9 Under 76-06-01, what is the name of the person who is represented as the " licensee" who " disagreed" re need for " visual inspection of the limited access welds performed at elevation 253' on steel bean price numbers 232B7"?
Answer Applicant does not agree with AWPP's characterization of the portion of the Inspection Report identified in this interrogatory. The Licensee did not disagree with the need for visual inspection of the limited access welds at elevation 253' on steel beam piece number 232B7. When the inspector requested provisions to permit visual inspection, such provisions were made. The licensee representative, J. M. Corcoran, disagreed with the inspector's statements on the need for certain qualification tests.
Participants in Preparation of Answer Vincent 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 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 12
- Interroertery N,, 9.5 He 10 CFR 2.790 (a) and 2.790 (b) (1) , supply all written applications asking to withhold information contained in NRC violations involving velding at Limerick.
Answer Applicant made no applications to the NRC as provided for in 10 CFR 2.790 requesting to withhold information contained in NBC violations involving velding at Limerick or Applicant's responses thereto.
Participants in Preparation of Answer Vincent 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 CORPany 2301 Market Street Philadelphia, PA 19101 13
- Interroaatory No. 10 Under 76-06-01, how many welds were involved in othe veld joints designated #3 in the record drawings of the in process check list"?
Answer The section of 76-06-01 quoted in the interrogatory refers to one welded beam end connection for beam mark number 232B7 located in Area 13 near elevation 253', near column line 23 and approximately 6'-5" south of H line. The location is shown on a copy of a record drawing C-41A-515-3 (from Bechtel QC Inspection i
record C-201-W-1 -8) , which is available for inspection and copying. (Discovery 15, Item 10) .
Participants in Preparation of Answer Vincent 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 f
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- Interrnaatory Na- 11 Under 76-06-01, as it relates to (10) above, who was the Bechtel Quality Control inspector involved with checking off "all inspection items, including " Final Quality Yerification"? Was he separated from employment by Bechtel and/or Applicant in 19767 Answer The Quality Control Inspector involved in the cited Inspection Report was V. C. Ferretti, wno was employed by Bechtel Power Corporation until his separation in 1976.
Participants in Preparation of Answer Vincent 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 15
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- Interrocatory No. 12 He 76-06-01, what part of AWS-D-1-1 Section 6 did the Quality Control Inspector not comply with?
Answer NRC inspection report 353-76-06, Item 76-06-01 Page 5, does not refer to specific paragraph numbers in its reference to Section 6 of AWS D1-1. It appears from the description of 76 01 on Page 5 of 353-76-06 that the AWS D' ., Section 6, paragraphs of interest to the NRC inspector would be 6.3.2, 6.5.1, and 6.5.5.
Participants in Preparation of Answer Vincent 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 l
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. Interroantory No- 13 Please provide following documentation ra 76-06-01: QCIR-C-201-N-1-8; C-41A-515-3; QCIR-C-204-N-1-2;.Q-41A-657-3; PI-A_Lh; Q.C. In-Process Check Off-sheet-Welding, C-201-N-1-8.
Answer -
While all of the information requested has been provided previously, except for certain drawings where only the relevant portions were reproduced, the documents requested are available for inspection and copying. (Discovery 15, Iten 13) .
Participants in Preparation of Answer Vincent S. Boyer, Senior Vice President - Nuclear Power Philadelphia Electric CoBPany 2301 Market Street Philadelphia, PA 19101 D. T. Clohecy Quality Assurance - Engineer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 i
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. Interroaatory No. 14 Please provide affidavits from supervisors, and inspectors of P.E . , NRC, and Bechtel that the infractions such as in 76-06-01 did not take place at other construction locations at Limerick.
Answer Applicant is aware of one other instance such as identified
- -in NRC Inspection Report 50-353/76-06, Item 76-06-01 where an l
- l unqualified extension was used in welding at the Limerick site. l l
Documents related to this instance are available for inspection and copying (Discovery 15, Item 14) . To the best of Applicant's
, knowledge, all infractions such as those identified in item 76-l 06-01 relating to welding on safety-related structures, systems or components have been identified and appropriately dispositioned. Applicant is not aware of any such infractions which have not been identified and appropriately dispositioned.
l Participants in Preparation of Answer Vincent 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 18
- Interroqatory N9 15 Re audits of welding gunlity records diccussed under 5 (a) ,
page 11, of Summary of Findings, Inspection 50-353-76-06, what audit findings did inspector observe that required that
" corrective action was documented *?
Answer Audits and associated findings listed in NRC Inspection Report 50-353-76-06 on page 11 under 5 (a) are available for inspection and copying (Discovery 15, Iten 15).
Participants in Preparation of Answer Vincent 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 L%
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i COMMONWEALTH OF PENNSYLVANIA :
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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 to Intervenor AWPP's First Set of Interrogatories on Quality Assurance / Control 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.
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Senidf' Vice P@ident Subscribed and sworn to before me this M* day of December,1983.
aL e k AA.at Notary Public PATRICIA D. SCHOLE Notary Put*c. Phdadelphia, Phdadelphie Cd.
Aly Comanselon Expues February 10,1988
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