ML20083A634
| ML20083A634 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/15/1983 |
| From: | Churchill B METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| Shared Package | |
| ML20083A637 | List: |
| References | |
| 83-491-04-OLA, 83-491-4-OLA, ISSUANCES-OLA, NUDOCS 8312200353 | |
| Download: ML20083A634 (38) | |
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'I December 15',1983 53 DEC 19 p;o;gg UNITED STATES OF AMERICA CFr!- c -
NUCLEAR REGULATORY COMMISSION CCCh 7Tj 'r JJ. -
ER3h;;ii
Before the Atomic Safety and Licensing Board In the Matter of
)
)
Docket No. 50-239-OLA METROPOLITAN EDISON COMPANY, ET AL. )
ASLBP 83-491-04-OLA
)
(Steam Generator Repair)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR TMIA This set of interrogatories and request for document pro-duction are filed by Licensee to 11.tervenor TMIA pursuant to the Licensing Board's Memorandum and Order of November 29, 1983, which requires that discovery requests be expeditiously initiated such that the responses can b'e received on a schedule to enable completion of discovery by January 31, 1984.
I.
INTERROGATORIES Pursuant to 10 C.F.R. 6 2.740b, Licensee hereby requests that Intervenor Three Mile Island Alert, Inc. ("TMIA") answer separately and fully in writing, and under oath or affirmation, each of the following interrogatories.
Answers must be signed 8312200353 831215 PDR ADOCK 05000289 O
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by the person making them and u9ust be served within 14 days after service of the interrogatories.
These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R.
$ 2.740(e),
should TMIA or any individual acting on its behalf obtain any new or differing information responsive to these interrogatories.
When asked in the interrogatories below to identify a person, please state that person's full name, present or last known address, telephone number, employer, and job title.
Where an individual interrogatory calls for an answer which involves more than one part, each part of the answer shall be clearly identified and correlated with the part of the interrogatory to which it is responsive.
Where identification of a document is requested, briefly describe the document (e.g.,
book, letter, memorandum, transcript, report, handwritten notes, test data, etc.) and provide the following information as applicable:
document name,' title, number, author, date of publication and publisher, addressee, date written or approved, and the name and address of the person or persons having possession of the document.
Also identify by page number and chapter or section number the specific portion or portions of the document upon which you t
rely. <
As used herein, the following definitions shall apply:
" Document (s)" means all writings and records of every type in the possession, control or custody of TMIA or any individual acting on-its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, handwritten notes, speeches, articles, transcripts, audio and video record-ings and all other writings or recordings of any kind.
" Writ-ings" and " recordings" consist of letters, words or numbers, or their equivalent, set down by handwriting, typewriting, print-ing, photostating, magnetic impulse, mechanical or electrical recording, or other form of data compilation.
" Document (s)"
shall also mean copies of documents even though the originals thereof are not in the possession, custody, or centrol of TMIA.
A document shall be deemed to be within the " control" of TMIA or any individual acting on its behalf if it has ownership, possession or custody of the document or copy thereof, or has the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
"You" or "your(s)" means TMIA, its members or any person
= authorized to'act on its behalf.
"SER" means the Staff's Safety Evaluation Report on Steam
. Generator Tube Repair and Return to Operation, NUREG-1019, and Supplement 1 thereto.
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I.
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A.
General Interrogatories 1
(a)
For each interrogatory answer, and each subpart thereto, identify each person who participated in the prepara-tion fo the answer, and who provided information to you upon which you relied in preparing the answer.
(b)
Identify all such information which was provided by ecch such person and the specific interrogatory in which such information is contained.
2.
For each person identified in your answers to the following interrogatories as being a proposed witness, state:
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(a)
The educational and professional qualifications (including a complete list of publications) of each such person;-
(b)
The precise subject matte on which each such person is expected to testify; (c)
The substance of the facts and' opinions as to which each such person is expected to testify; and (d)
A summary of the grounds for any opinions iden-tified in subparagraph (c) above and identification of all documents upon which such person relies to substantiate such opinions.
B.
Interrogatories on Contention 1.a 1.a-1.
Specifically identify and describe in detail each aspect of "[p]ost repair and plant performance testing and >
analysis" which you allege is inadequate to provide sufficient assurance that tube ruptures will be detected in time and prevented to avoid release of radiation beyond permissible limits.
1.a-2.
State in detail each and every fact upon which you base your allegation that each aspect of the testing and analysis identified in your answer to Interrogatory 1.a-1 is inadequate.
1.a-3.
Explain in detail how each fact stated in your answer to Interrogatory 1.a-2 supports your allegation that each aspect of the testing and analysis identified in your answer to Interrogatory 1.a-1 is inadequate.
1.a-4.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1.a-1 through 1.a-3 above, and correlate each such document as specifically as possible (page and paragraph number) with each
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such fact.
1.a-5.
Specifically identify each proposed license condition, or portion thereof, which you allege is inadequate to provide sufficient assurance that tube ruptures will be de-tected in time and prevented to avoid release of r~adiation be-yond permissible limits.
1.a-6.
State in detail each and every fact upon which you base your allegation that each proposed license condition, or portion thereof, identified in your answer to Interrogatory 1.a-5 is inadequate..
1.a-7.
Explain in d.etail how each fact stated in your answer to Interrogatory 1.a-6 supports your allegation that each proposed license condition, or portion thereof, identified in your answer to Interrogatory 1.a-5 is inadequate.
1.a-8.
Identify each and every document which you claim supports each fact set forth in your answer to Interrogatory 1.a-7 above, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
1.a-9.
Do you allege that those portions of the steam generator tubes which have been kinetically expanded have not been adequately repaired to prevent the occurrence of a tube rupture in the expanded portion?
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1.a-10.
If your answer to Interrogatory 1.a-9 is other than an unqualified "no":
(a) State in detail each and every fact upon which you base your allegation that the expanded tube portions have not been adequately repaired to prevent a tube rupture in the repaired portion of the tube;.
(b) Explain in detail what your allege the radiological health and safety consequences of such a rupture to be; and i
(c) Describe mechanistically the manner in which such health and safety consequences will occur.
1.a-11.
Identify each and every document which you claim t
I supports each fact set forth in your answers to Interrogatories 1.a-8 through 1.a-10, and correlate each such document as l
i specifically as possible (page and paragraph number) with each such fact.
1.a-12.
Do you allege that " restart" would result in stresses sufficient to cause a rupture of the repaired portion of a steam generator tube?
- 1. a'- 13.
If your answer'to Int,errogatory 1.a-12 is other t'cr.n an unqualified "no,"
state in detail each and every fact
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upon which you base such allegation, and explain in detail how each such fact supports the allegation.
1.a-14.
Do you allege that "a turbine trip at maximum power" would result in stresses sufficient to cause a rupture of the repaired portion of a steam generator tube?
1.a-15.
If your answer to Interrogatory 1.a-14 is other than an unqualified "no",
state in detail each and every fact upon which you base such allegation, and explain in detail how each such fact supports the allegation.
1.a-16.
Do you allege that a " thermal shock from an inad-vertent actuation of emergency feedwater at high power" would Tesult in' stresses sufficient to cause a rupture of the repaired portion of a steam generator tube?
1.a-17.
If your answer to Interrogatory 1.a-16 is other than an unqualificd "no",
state in detail each and every fact
.upon which you base such allegation, and explain in detail how each such fact supports the allegation.
1.a-18.
Do you allege that a " rapid cooldown" following a LOCA will result in stresses sufficient to cause a rupture of the repaired portion of a steam generator tube? -
1.a-19.
If your answer to Interrogatory 1.a-18 is other than an unqualified "no",
state in detail each and every fact upon which you base such allegation, and explain in detail how each such fact supports the allegation.
1.a-20.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1.a-12 through 1.a-19 above, and correlate each such document as specifically as'possible (page and paragraph number) with each such fact.
1.a-21.
Identify each person you propose to call as a witness in support of Contention 1.a.
1.a-22.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 1.a.
1.a-23.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee or the NRC Staff on Contention.1.a.
C.
Interrogatories on Contention 1.b 1.b-1.
General Design Criterion 14, 10 C.F.R. Part 50, App. A, (GDC 14) reads as follows:
Criterion 14 - Reactor Coolant Pressure Boundary.
The reactor coolant pressure boundary shall be designed, fabricated, erected and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture..-
- Do you allege that, as a result of the kinetic expansion repair-process, the porticn of the reactor coolant pressure boundary represented by the repaired portions of the steam generator-tubes fails to meet GDC 14?
1.b-2.
If your answer to Interrogatory 1.b-1 is other than an. unqualified "no",
state in detail each and every fact upon which you base your allegation.that, as a result of the kinetic expansion repair process, the portion of the' reactor
-coolant pressure boundary represented by the repaired portions
'of the steam' generator tubes fails to meet GDC 14.
1.b-3.
Explain in detail how each fact stated in your answer to Interrogatory 1.b-2 supports your allegation.
I 1.b-4.
Identify-each and every document which you claim supports each fact' set forth in your answers to Interrogatories 1.b-1 through 1.b-3, and correlate each such document as spe-F cifically-as possible (page and paragraph number) with each such fact.
1.b-5.
State in detail.each and every fact upon which
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1 you base your allegation that, as a result of the kinetic ex-j pansion repair process, a simultaneous tube rupture in both l
1 steam generators.is not "an incredible event," and explain in detail how each such fact supports the allegation.
l 1.b-6.
Identify each and every document which you claim l
supports each fact se facth in your answer to Interrogatory 1.b-5,1and correlate each such document as specifically as l~
- possible (page and paragraph number) with each such fact.
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1.b-7.
State in detail each'and every fact upon which you base your allegation that, as a result of the kinetic ex-pansion repair process,.a simultaneous tube rupture in both steam generators "could lead to a sequence of events not encom-passed by emergency procedures," and explain in detail how each such fact supports your allegation.
1.b-8.
Identify each and every document which you claim supports each fact set forth in your answer to Interrogatory 1.b-7, and correlate each such document as specifically as pos-sible (page and paragraph number) with each such fact.
1.b-9.
State in' detail each and every fact upon which you base your allegation that, as a result of the kinetic ex-pansion repair process, a simultaneous tube rupture in both steam generators, occurring in conjunction with a LOCA, could
- create essentially uncoolable conditions, and explain in detail how each such fact supports your allegation.
1.b-10.
Identify each and every document which you claim supports each fact set forth in your answer to Interrogatory 1.b-9, and correlate each such document as specifically as pos-sible (page and paragraph number) with each such fact.
l 1.b-11.
Identify each person you propose to call as a witness in support of Contention 1.b.
1.b-12.
Identify all documents, including all relevant I
page citations, which you intend to offer as exhibits during this proceeding to support Contention 1.b. 4 i
1.b-13.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee or the NRC Staff cn Contention 1.b.
D.
Interrogatories on Contention 1.c 1.c-1.
Do you allege that any of the types of plugs
'used in the TMI-1 steam generators are inadequate to perform their intended purposes?
1.c-2.
If the answer to the preceding interrogatory is other than an unqualified "no":
(a)
Identify each such type of plug and the alleged inadequacies associated with it; (b)
State in-detail each and every fact upon which you base your allegation that each such type of plug is inade-quate; and (c)
Explain in detail how each fact stated in your answer to Interrogatory 1.c-2(b) supports your allegation that each such type of plug is inadequate.
1.c-3.
Do you allege that the kinetic expansion repair process adversely impacted the ability of ar.y of the type of plugs to perform their intended purposes?
1.c-4.
If the answer to the preceding interrogatory is other than an unqualified "no":
(a)
Identify each touch type of plug;..
v.
'(b)
State in detail each and every fact upon which you base your allegation that the kinetic expansion repair process adversely _ impacted the ability of each such type of plug to perform its_ intended purposes; and (c)
Explain in detail how each fact stated in your answer to Interrogatory 1.c-4(b) supports your allegation that the kinetic expansion repair. process adversely impacted the ability of each such type of plug to perform its intended purposes.
1.c-5.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1.c-1 through 1.c-4, and correlate each such document as spe-cifically as possible (page and paragraph number) with each such fact.
1.c-6.
Do you allege that, as a result of the kinetic expansion repair process, plugged tubes will interfere with the plant's ability to respond to transients and accidents?
1.c-7.
If your answer to Interrogatory 1.c-6 is other than an unqualified "no":
(a)
Identify each. transient or accident for which you allege that, as a result of the kinetic expansion repair process, plugged tubes wil. interfere with the plant's ability to respond to such transient or accident; (b)
For each such transient or accident set out in your answer to Interrogatory 1.c-7(a), state each and every fact upon which you base your allegation that, as a result of A
the kinetic expansion repair process, plugged tubes will interfere with the plant's ability to respond to such transient or accident; (c)
Explain in detail how each fact stated in your answer to Interrobatory 1.c-7(b) supports your allegation that, as a result of the-kinetic expansion repair process, plugged tubes will interfere with the plant's ability to respond to each such transient or accident.
1.c-8.
Other than the allegations stated in Interroga-tory 1.c-6,and your answer thereto, do you allege that, as a result of the kinetic expansion repair process, plugged tubes will cause the plant to fail to meet any applicable licensing criteria or requirements?
1.c-9.
Are there any safety deficiencies, associated with plugging the steam generator tubes, other than those contained in your answers to Interrogatories 1.c-1 through 1.c-8,'which you intend to be encompassed within Contention 1.c?
1.c-10.
If your answer to Interrogatory 1.c-9 is other than an unqualified "no":
(a)
Identify and describe in detail each such plug-ging safety deficiency which you allege to be as a result of the kinetic expansion repair process; (b)
For each plugging safety deficiency alleged in
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your answer to Interrogatories 1.c-10(a), state each and every fact upon which you base such allegation; and (c)
Explain in detail how each fact stated in your answer to Interrogatory 1.c-10(b) supports each such allegation of a plugging safety deficiency, and explain in detail how each such alleged plugging safety deficiency is caused by the kinet-ic expansion repair process.
1.c-11.
Identify each and every document which you claim supports each fact set forth in your answers.to Interrogatories 1.c-6 through 1.c-10, and correlate each such document as spe-cifically as possible (page and paragraph number) with each such fact.
1.c-12.
Identify each person you propose to call as a witness in support of Contention 1.c.
1.c-13.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 1.c.
1.c-14.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee or the-NRC Staff on Contention 1.c.
E'.
-Interrogatories on Contention 1.d 1.d-1.
State in detail each and every fact upon which you base your allegation that neither the " Report of Third Party Review of Three Mile Island, Unit 1 Steam Generator Repair" ("TPR") nor tr.e Staff's Safety Evaluation Report
("SER") are credible documents in their evaluation of "the 5
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kinetic expansion repair technique, including leak tightness-4
-and load carrying capabilities."
i lid-2.
Identify each and every document which you. claim
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supports'each.factLset'forth in.your answer to Interrogatories s
.1.d-1.above, and. correlate each such. document as specifically n
2.
as.possible (page.and paragraph: number) with each such fact.
1.d-3.
Specifically identify and explain each of the i
'nherent inconsistencies" to which you refer in Con-l
" reports' i
tention 1.d.
1.d-4.
-State in detail'each and every fact upon which 3
you base your allegation that each of the " reports' inherent inconsistencies" identified in your response to Interrogatory l
1.d-3 undermines or is inconsistent with the evaluation in the
-TPR and SER of "the-kinetic expansion repair technique, including leak tightness and load carrying capabilities."
1.d-5.
Identify each and every document which you claim supports each fact' set forth in your answer to Interrogatories
=1.d-4 above, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
J 1.d-6.
Explain what you mean by " axial symetric stress analysis" as it pertains to analyses in the TPR and SER.
1.d-7.
Identify and describe the cracks in the TMI Unit i
1-steam generator tubes to which you believe " axial symetric
. stress analysis" is not applicable.
1.d-8.
Where are the cracks identified and described in m
Lyour response to-Interrogatory 1.d-7 located?
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1.d-9.
What do you believe to be the cause of the cracks identified and described in your answer to Interrogatory 1.d-7?
1.d-10.
Explain why " axial symetric stress analysis" is not applicable to the cracks identified and described in your answer to Interrogatory 1.d-7.
1.d-11.
Identify each and every document which you claim supports each fact set out in your answers to Interrogatories 1.d-6 through 1.d-10 above, and correlate sach document as spe-cifically as possible (page and paragrapn number) with each such fact.
1.d-12.
Identify each " basic assumption and conclusion" in the TPR and the SER which you allege " rest [s] improperly on axial symetric stress analysis which would not be applicable to all cracks."
1.d-13.
For each basic assumption and conclusion identi-fied in your. response to Interrogatory 1.d-12, state in detail each and every fact upon which you base your allegation that such basic assumption or conclusion " rests improperly on axial symetric stress analysis which would not be applicable to all cracks."
1.d-14.
For each " basic assumption and conclusion" iden-tified'in your response to Interrogatory 1.d-12, state in de-tail each and every fact upon which you base your allegation
.that each.such assumption or conclusion undermines or is incon-sistent with the evaluations in the TPR and SER of "the kinetic
.4 expansion repair technique, including leak tightness and load carrying capabilities."
1.d-15.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1.d-12 through 1.d-14~
above and correlate each document as specifically as.possible (page and paragraph number) with each such fact.
1.d-16.
Explain the difference between " toughness" and
" hardness" in terms of significance to the analysis of " crack resistance."
1.d-17.
State in detail each and every fact upon which you base your allegation that " hardness" has no relation to crack resistance.
1.d-18.
Specifically identify each instance in the TPR and SER where it is stated, suggested, or inferred that
" hardness" was or was not used to analyze crack resistance.
1.d-19.
Specifically identify each instance in the TPR and SER where'it is stated or suggested that " toughness" was or was not used to analyze crack resistance.
1.d-20.
Identify each and every document which you claim supports each fact set out in your answers to Interrogatories 1.d-22 through 1.d-25 above, and correlate each document as specifically as possible (page and paragraph number) with each such fact.
1.d-21.
Specifically identify each instance in the TPR and SER where you allege that crack resistance was improperly 1
i analyzed on the basis of hardness, rather than toughness, and state _in detail each and every fact upon which you base your allegation that crack resistance should have been analyzed on the basis of " toughness" rather than " hardness".
1.d-22.
State in detail each and every fact upon which you base your allegation that the alleged " failure to analyze crack resistance on the basis of toughness as opposed to hardness" undermines or is inconsistent with the evaluations in the TPR and SER of "the kinetic expansion repair technique, including leak tightness and load carrying capabilities."
1.d-23.
Identify each and every document which you claim supports each fact set out in your answers to Interrogatories 1.d-21'and 1.d-22 above, and correlate each document as specif-ically as possible (page and paragraph number) with each such fact.
1.d-24.
With respect to the phrase " failure to differen-tiate in their analysis between the effects of thermal stress on small versus large cracks" as used in Contention 1.d:
(a)
Define what you mean by "small cracks";
(b)
Define what you mean by "large cracks".; and (c)
Identify each and every specific " analysis" to which you refer.
1.d-25.
In terms of each and every " analysis" identified in your answer to Interrogatory 1-24(c).d, explain in detail the significance of a failure to differentiate between the effects of thermal stress on small versus large cracks.
1.d-26.
Specifically identify each instance in the TPR and SER.where it is stated, suggested, or inferred that there
-was a " failure to differentiate in [an] anslysis between the effects of thermal stress on small versus large cracks."
1.d-27.
State in detail each and every fact upon which you base your. allegation that there was a failure in the TPR and SER to " differentiate in their analysis'between the effects of thermal str'ess on small versus large cracks."
1.d-28.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1.d-24 through 1.d-27, and correlate each document as specifi-cally as possible (page and paragraph number) with each such fact.
1.d-29.
State in detail each and every fact upon which' you base your allegation that each " failure to differentiate in their_ analysis between the effects of thermal stress on small versus large cracks" identified in your answer to Interrogatory 1.d-26 undermines or is inconsistent with the evaluations in the TPR and SER of "the kinetic expansion repair technique, including leak tightness and load carrying capabilities."
1.d-30.
Identify each and every document which you claim supports each fact set forth in your answer to Interrogatory 1.d-29, and correlate each document as specifically as possible (age and paragraph number) with each such fact.
1.d-31.
Identify each person you propose to call as a witness in-support of Contention 1.d.
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1.d-32.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 1.d.
1.d-33.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee or the NRC staff on Contention 1.d.
'F.
Interrogatories on Contention 2.a 2.a-1.
State in detail each and every fact upon which you base your allegation that the " causative agent" has not been properly identified.
2.a-2.
Explain in detail how each fact stated in your answer to Interrogatory 2.a-1 supports your allegation that the
" causative agent" has not been properly identified.
2.a-3.
State in detail each and every fact upon which you base your allegation that the " source of initiation" has not been properly-identified.
2.a-4.
Explain in detail how each fact stated in your answer to Interrogatory 2.a-3 supports your allegation that the
" source of initiation" has not been properly identified.
2.a-5.
State in detail each and every fact upon which you base your allegation that the " conditions under which initiation of the IGSCC originally occurred" have not been properly identified.
1 2.a-6.
Explain in detail how each fact stated in your answer.to Interrogatory 2.a-5 supports your allegation that the
" conditions under which initiation originally occurred" have not been properly identified.
2.a-7.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogtories 2.a-1 through 2.a-6, and correlate each such document as spe-l cifically as possible (page and paragraph number) with each such fact.
i 2.a-8.
Identify in detail each and every deficiency relating to the identification of "the causative agent or the source of initiation or the conditions under which initiation originally occurred" which you allege to be in the analyses performed by Licensee, the NRC Staff, and the various Licensee and Staff consultants.
2.a-9.
For each deficiency alleged in your answer to In-terrogatory 2.a-8, state in detail each and every fact upon which you base each such allegation.
2.a.10.
Explain in d'etail how each fact stated in your answer to Interrogatory 1.a-9 supports each allegaton of defi-ciency stated in your answer to Interrogatory 2.a-8.
2.a-11.
Explain in detail how each of the alleged deficiencies alleged in your answer to Interrogatory 2.a-8 un-dermines the conclusions reached by Licensee and the NRC Staff that 1) the causative agent has been removed from the system; 2) the clean up process was reliable; 3) the procedures meant to eliminate the corrosive environment in fact did so; and 4) the Licensee's and Staff's stress analyses were reliable as to when the corrosion could reoccur.
2.a-12.
For each allegation stated in your answer to In-terrogatory 2.a-11, state in detail each and every fact upon which you base each such allegation.
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2.a-13.
Explain in detail how each fact stated in your answer to Interrogatory 2.a-12 supports each allegation stated in your answer to Interrogatory 2.a-11.
2.a-14.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.a-8 through 2.a-13, and correlate each such document as spe-cifically as possible (page and paragraph number) with each such fact.
2.a-15.
Do you allege that the "causati's agent or source of initiation or the conditions under which initiation origi-nally occurred" differs from those identified by Licensee, the NRC Staff and their respective consultants?
2.a-16.
If the answer to Interrogatory 2.a-15 is other than.an unqualified "no",
identify each and every " causative agent or source of initiation or the conditions under which initiation originally occurred" which you claim caused or significally contributed to the corrosion.
2.a-17.
For each " causative agent or source of initiation L
or the conditions under which initiation originally occurred",
identified in your answer to Interrogatory 2.a-16, state in i
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detail each and every fact upon which you base your claim that the specified factor caused or significantly contributed to the corrosion.
2.a-18.
-Explain in detail how each fact stated in your answer to Interrogatory 2.a-17 supports each allegation stated in your answer to Interrogatory 2.a-16.
2.a-19.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogstories 2.a-15 through 2.a-18, and correlate each such document as spe-cifically as possible (page and paragraph number) with each such fact.
2.a-20.
With respect to contaminants other than sulfur (in its various forms and compounds) identified in your answer to Interrogatory 2.1-16:
(a)
Identify with specificity the quantity of each such contaminant which you claim could cause or significantly contribute to the corrosion; (b)
State in detail each and every fact upon which you rely for the allegation in subparagraph (a) above; and (c)
Explain in. detail how each fact stated in your answer to subparagraph (b) above supports the allegation in subparagraph (a).
2.a-21.
With respect to each contaminant identified in your answer to Interrogatory 2.a-20, do you claim that the quantity stated in your answer to Interrogatory 2.a-20(a) above was in fact present in the TMI-1 steam' generator tubes?
}
2.a-22.
If the answer to Interrogatory 2.a-22 is other than an unqualified "no",
state in detail with respect to each contaminant each and every fact upon which you base your alle-gation.
2.a-23.
Explain in detail how each fact stated in your answer to Interrogatory 2.a-22 supports each allegation stated in your answer to Interrogatory 2.a-21.
r 2.a-24.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.a-20 through 2.a-23, and correlate each such document as spe-cifically as possible (page and paragraph number) with each such fact.
2.a-25.
Identify each person you propose to call as a witness in support of Contention 2.a.
2.a-26.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 2.a.
2.a-27.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee or the NRC staff on-Contention 2.a.
G.
Interrogatories on Contention 2.b.1 2.b.1-1.
-Explain how and why the concerns raised by Mr.
Dillon with respect to the clean up of the sulfur in the TMI-1 ~
steam generators have any continuing relevancy to the,
~
contention that the corrosion which damaged the steam generators might reinitiate, now that the clean up has been completed.
.2.b.1-2.
State.in detail each and every fact upon which you base each allegation set forth in your answer to Interroga-tory 2.b.1-1.
2.b.1-3.
Explain how each fact stated in your answer to Interrogatory 2.b.1-2 supports each allegation stated in your ariswer to Interrogatory 2.b.1-1.
2.b.1-4.
Do you. allege that.the clean up, as actually im-plemented, had any adverse effects on the TMI-1 steam genera-tors?
2.b.1-5.
If-your answer to Interrogatory 2.b.1-2 is other than an unqualified "no",
identify each and every adverse effect which you claim resulted from the clean up.
2.b.1-6.
State in detail each and every fact upon which you base each allegation of an adverse effect in your answer to Interrogatory 2.b.1-5.
2.b.1-7.
Explain how each fact stated in your answer to Interrogatory 2.b.1-6 supports each allegation stated in your answer to Interrogatory 2.b.1-5.
2.b.1-8.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.b.1-1 through 2.b.1-7, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.,
2.b.1-9.
Do you allege that the analysis and tests of the effect-of the clean up performed by Licensee was deficient in any respect?
2.b.1-10.
If your answers to Interrogatory 2.b.1-9 is other than an unqualified "no",
identify in detail each and every alleged deficiency in Licensee's tests and or analysis relating to the effect of the clean up on the steam generators.
~
2.b.1-11.
For each deficiency alleged in your answer to Interrogatory 2.b.1-10, state in detail.each and every fact upon-which you base each such allegation.
2.b.1-12.
Explain in detail how each fact stated in your answer to Interrogatory 2.b.1-11 supports each alleged defi-ciency stated in your answer to Interrogatory 2.b.1-10.
2.b.1-13.
-Explain in detail how each of the deficiencies alleged in your answer to Interrogatory 2.b.1-10 supports each claim set forth in-your answer to Interrogatory 2.b.1-5.
2.b.1-14.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.b.1-9 through 2.b.1-13, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
2.b.1-15.
Identify each person you propose to call as a witness in support of Contention 2.b.1.
2.b.1-16.
Identify all documents, including all relevant page citations thereto, which you intend to offer as exhibits during this proceeding to support Contention 2.b.1..
2.b.1-17.
Identify.all docunents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee or the NRC Staff on Contention 2.b.1.
H.
Interrogatories on Contention 2.b.2 2. b'. 2 - 1.
Do you aslege that the sulfur contamination re-maining after the cleaning process poses a risk of reinitiation of IGSCC?
2.b.2-2.
If your answer to Interrogatory 2.b.2-1 is other than an unqualified "no",
explain in detail the mechanism by which you allege the corrosion is likely to reoccur, including the rate and quantity of sulfur contamination.
2.b.2-3.
State in detail each and every fact upon which you base your allegation that a risk of reinitiation exists, and upon which you base yodr explanation of the mechanism by which the corrosion is likely to reoccur.
2.b.2-4.
. Explain in detail how each fact stated in your answers to Interrogatories 2.b.2-2 and 2.b.2-3 supports the al-legation stated in your answer to Interrogatory 2.b.2-1.
2.b.2-5.
Do you claim that the level of sulfur compound determined by post-cleaning testing to be in solution in the TMI-1 steam generator tubes is greater than that stated by Li-censee, namely 0.1 ppm.sulface?
2.b.2-6.
If your answer to Interrogatory 2.b.2-5 is other than an unqualified "no",
state in detail each and every fact upon which you base this allegation..
Q-
2.b.2-7.
Explain.in, detail how each fact stated in your answer to Interrogatory 2.b.2-6 supports the allegation stated in your answer to Interrogatory 2.b.2-5.
2.b.2-8.
Do you allege that an inventory of 0.1 ppm sulfate in solution would have a significant corrosive effect on the steam generator tubes?
2.b.2-9.
If your answer to Interrogatory 2.b.2-10 is other than an unqualified "no",
state in detail each and every fact upon which you base this allegation.
2.b.2-10.
Explain in detail how each fact stated in your answer to Interrogatory 2.b.2-9 supports the allegation stated in your answer to Interrogatory 2.b.2-8.
2.b.2-11.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.b.2-1 through 2.b.2-10, and correlate each such document as specifically as possible (page and paragraph number) with each such fact, i
l 2.b.2-12.
Do you allege that the administrative controls-imposed by Licensee are inadequate to prevent buildup of corro-sive sulfur concentrations?
2.b.2-13.
If your answer to-Interrogatory 2.b.2-12 is other than an unqualified "no",
identify each and every admin-
[
istrative-control which you allege is inadequate and state in detail each and every fact upon which you base those allega-tions.
~-~
2.b.2-14.
Explain in detail how each fact stated in your answer to Interrogatory 2.b.2-13 supports the allegation stated
-in your answer to Interrogatory 2.b.2-12.
2.b.2-15.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.b.2-12 through 2.b.2-14 above, and correlate each such document as specifically as possible (page and para-graph number) with each such fact.
2.b.2-16.
Identify'each person you propose to call as a witness in support of Contention 2.b.2.
2.b.2-17.
Identify all documents, and relevant page cita-tions, which you intend to offer as exhibits during this pro-ceeding to support Contention 2.b.2.
2.b.2-18.
Identify all documents, including all relevant page citations, which you intend to use during your cross-examination of witnesses presented by Licensee or the NRC Staff en Contention 2.b.2.
I.
Interrogatories on Contention 2.c 2.c-1.
State in detail each and every fact upon which you base your allegation that neither the " Report of Third Party Review of Three Mile Island, Unit 1 Steam Generator Repair"
("TPR") nor the staff's Safety Evaluation Report ("SER") are credible documents in their evaluation of "the causative agent."
i-l l-
2.c-2.
State in detail each and every fact upon which you base your allegation that neither the TPR nor the SER are cred-ible documents in their evaluation of " clean up",
and explain how each such fact supports that allegation.
2.c-3.
State in detail each and every fact upon which you
- base ypur allegation that neither the TPR nor the SER are cred-ible documents in their evaluation of " procedures to prevent contaminant reintroduction", and explain how each such fact supports that allegation.
2.c-4.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.c-1 through 2.c-3, and correlate each such document as spe-cifically as possible (page and paragraph number) with each such fact.
2.c-5.
Specifically identify and explain each of the "re-ports' inherent inconsistancies" to which you refer in Conten-tion 2.c.
2.c-6.
State in detail each and every fact upon which you base your allegation that each of the " reports' inherent inconsistencies" identified in your response to Interrogatory 2.c-5 undermines or is inconsistent with the evaluation in the TPR and SER of "the causative agent."
2.c-7.
State in detail each and every fact upon which you base your allegation that each of the " reports' inherent inconsistencies" identified in your response to Interrogatory 2.c-5 undermines or is inconsistent with the evaluation in the TPR and SER of " clean up." '
2.c-8.
State in~ detail each and every fact upon which you base your allegation that each of the " reports' inherent inconsistencies"-identified in your response to Interrogatory 2'c-5 undermines or is inconsistent with the evaluation in the TPR and SER.of " procedures to prevent contaminant
. reintroduction."
2.c-9.
Identify each and-every document which you claim supports each_ fact set forth in your answers to Interrogatories
'2.c-5 through 2.c-8, and correlate each such document as spe-cifically as possible (page and paragraph. number) with each such fact.
'2.c-10.
Explain what-you mean by " axial symetric stress analysis" as it pertains to the analyses in the TPR and SER.
2.c-11.
Identify and describe the cracks in the TMI Unit 1 steam generator tubes to which you believe " axial symetric stress analysis" is not applicable.
2.c-12.
Where are the cracks identified and described in your response to Interrogatory 2.c-11 located?
2.c-13.
What do you believe to be'the cause of the cracks identified and described in your answer to Interrogatory 2.c-11?
2.c-14.
Explain.why " axial symetric stress analysis" is not applicable to the cracks identified and' described in your answer to Interrogatory 2.c-11.
2.c-15.
Identify each and every document.which you claim supports each fact set out in your answers to Interrogatories i,
+
-:,r r-sv e..
--w-
-r,
2.c-10 through'2.c-14 abo.ve, and correlate each. document as specifically as possible (page and paragraph number) with each such fact.
2.c-16.
Identify each " basic assumption and conclusion" in the TPR and the SER which you allege " rest [s] improperly on axial symetric stress analysis which would not be applicable to all cracks."
2.c-17.'
For each basic assumption and conclusion identi-fled in your response to Interrogatory 2.c-16, state in detail each and every fact upon which you base your allegation that such basic assumption or conclusion " rest [s] improperly on axial symetric stress analysis which would not be applicable to all cracks."
2.c-18.
For each " basic assumption and conclusion" iden-tified in your response to Interrogatory 2.c-16, state in de-tail each and every fact upon which you base your allegation that each such assumption or conclusion undermines or is incon-sistent with the evaluations in the.TPR and SER of "the caus-ative agent."
2.c-19.
For each " basic assumption and conclusion" iden-tified in your response to Interrogatory 2.c-16, state in de-tail each and every fact upon which you base your allegation that each such assumption or conclusion undermines or is incon-sistent with the evaluations in the TPR and SER of " clean up."
2.c-20.
For each " basic assumption and conclusion" iden-tified-in.your response to Interrogatory 2.c-16, state in
> [
detail each and every fact upon which you base your allegation that each such assumption or conclusion undermines or is incon-sistent with the evaluations in the TPR and SER of " procedures to prevent contaminant introduction."
2.c-21.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.c-16 through 2.c-20, and correlate each document as specifi-cally as possible (page and paragraph number) with each such fact.
2.c-22.
Explain the difference between " toughness." and
" hardness" in terms of significance to the analysim of " crack resistance."
2.c-23.
State in detail each and every fact upon which you base your allegation that " hardness" has no relation to crack resistance.
2.c-24.
Specifically identify each instance in the TPR and SER where it is stated, suggested, or inferred that
" hardness" was or was not used to analyze crack resistance.
2.c-25.
Specifically identify each instance in the TPR and SER where it is stated or suggested that " toughness" was or was not used to analyze crack resistance.
2.c-26.
Identify each and every document which you claim supports each fact set out in your answers to Interrogatories 2.c-22 through 2.c-25 above, and correlate each document as specifically as possible (page and paragraph number) with each such fact.
2.c-27.
Specifically identify each instance in the TPR and SER where you allege that crack resistance was improperly analyzed on '.he basis of hardness, rather than toughness, and
. state in detail each and every fact upon which you base your allegation that crack resistance should have been analyzed on the basis of " toughness" rather than " hardness"..
2.c-28.
State in detail each and every fact upon which you base your allegation that the alleged " failure'to analyze crack resistance on the basis of toughness as opposed to hardness" undermines or is' inconsistent with the evaluations in the TPR and SER of "the causative agent".
2.c-29.
State in detail each and every fact upon which you base your allegation that the alleged " failure to analyze crack resistance on the bcsis of toughness as opposed to hardness" undermines or is inconsistent with the evaluations in the TPR and SER of " clean up".
2.c-30.
State in detail each and every fact upon which you base your allegation that the alleged " failure to analyze crack resistance on the basis.of toughness as opposed to hardness" undermines or is inconsistent with the evaluations in the TPR and SER.of " procedures to prevent contaminant introduc-tion".
2.c-31.
Identify each and every document which you claim supports each fact set out in your answers to Interrogatories 2.c-27 through 2.c-30 above, and correlate each document as specifically as possible (page and paragraph number) with each such fact. \\
=
2.c-32.
With respect to the phrase " failure to differen-tiate in their analysis between the effects of thermal stress on small versus large cracks" as used in Contention 2.c:
(a)
Define what you mean by "small cracks";
(b)
Define what you mean by "large cracks"; and (c)
Identify each and every specific " analysis" to which you refer.
2.c-33.
In terms of each and every " analysis" identified in your answer to Interrogatory 2.c-32(c), explain in detail the s.ignificance of a fa'ilure to differentiate between the effects of thermal stress on.small versus large cracks.
2.c-34.
Specifically identify each instance in the TPR and SER where it is stated, suggested, or inferred that there was a " failure to differentiate in [an) analysis between the effects of thermal stress on small versus large cracks."
2.c-35.
State in detail each and every fact upon which you base your allegation that there was a failure in the TPR and SER to " differentiate in their analysis between the effects of thermal stress on small versus large cracks."
2.c-36.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.c-32 through 2.c-35, and correlate each document as specifi-cally as p6ssible (page and paragraph number) with each such fact.
2.c-37.
State in detail each and every fact upon which you base your alleastion that each " failure to differentiate in _..
their analysis between the effects of thermal stress on small versus large cracks" identified in your answer to Interrogatory 2.c-34 undermines or is inconsistent with the evaluations in the TPR and SER of "the causative agent."
2.c-38.
State in detail each and every fact upon which you base your allegation that each " failure to differentiate in their analysis between the efforts of thermal stress on small versus large cracks" identified in your answer to Interrogatory 2.c-34 undermines or is inconsistent with the evaluations in the TPR and SER of " clean up."
2.c-39.
State in detail each and every fact upon which you base your allegation that each " failure to differentiate in their analysis between the effects of thermal stress on small versus large cracks" identified in your answer to Interrogatory 2.c-34 undermines or is inconsistent with the evaluations in the TPR and SER of " procedures to prevent contaminant reintroduction."
2.c-40 Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 2.c-37 through 2.c-39, and correlate each document.as specifi-cally as possible (page and paragraph number) with each such fact.
2.c-41.
Identify each person you propose to call as a witness in support of Contention 2.c.
2.c-42.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 2.c..
2.c-43.
Identify all documents, including all relevant page citations, which you intend to use during your cross-4 examination of witnesses presented by Licensee or the NRC Staff
- on Contention 2.c.
j II.
REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R. 5 2.741, Licensee hereby requests that TMIA respond in writing to the following request for pro-duction of documents and produce the original or best copy of each requested document at the office of the undersigned, Shaw, Pittman,.Potts & Trowbridge, 1800 M Street, N.W.,
Washington, D.C. 20036 or at.another place mutually convenient to the I
parties.
" Document (s)" means all writings and records of every type in the' possession, control or custody of TMIA or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets,' photographs, maps, bulletins, minutes,. handwritten notes, speeches, articles, transcripts, audio and video record-
'ings and all other writings or recordings of any kind.
" Writ-ings" and " recordings" consist of letters, words or numbers, or i
their-equivalent, set down by handwriting, typewriting, print-ing, photostating, magnetic impulse, mechanical or electrical recording, or other form of data compilation.
" Document (s)"
shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of TMIA.
e A document shall be deemed to be within the " control" of TMIA or any individual acting on its behalf if it has ownership, possession or custody of the document or copy thereof, or has the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
Licensee requests that TMIA produce each and every document identified or described in the answers to the interrogatories in Section I above.
Respectfully submitted, SHAW, PITTMAN, POT S & TROWBRIDGE
.[
y BY:
U Gbarge F Niowbridge, P'.C.
Bruce W. Churchill, P.C.
Diane E. Burkley Counsel for. Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 DATED:
December 15, 1983 d