ML20083A653
| ML20083A653 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/15/1983 |
| From: | Churchill B METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | JOINT PETITIONERS - TMI |
| Shared Package | |
| ML20083A637 | List: |
| References | |
| 83-491-04-OLA, 83-491-4-OLA, ISSUANCES-OLA, NUDOCS 8312200359 | |
| Download: ML20083A653 (18) | |
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. '3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
Docket No. 50-289-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 JOINT INTERVENORS This set of interrogatories and request for document pro-duction are filed by Licensee to Joint Intervenors 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 be received on a schedule to enable completion of discovery by January 31, 1984.
I.
INTERROGATORIES Pursuant to 10 C.F.R.
S 2.740b, Licensee hereby requests that intervenors Norman Aamodt and Jane Lee (" Joint Interve-nors") answer separately and fully in~ writing, and under oath or-affirmation, each of the following interrogatories.
Answers 8312200359 831215
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PDR ADDCK 05000289 O
must'be signed by the person making them and must be served within 14 days afteriservice of the interrogatories.
These interrogatories are intended to be continuing in nacure, and the answers should promptly be supplemented or
~ amended as appropriate, pursuant to 10 C.F.R.
$ 2.740(e),
.should Joint.Intervenors or any individual acting on their be-half 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 Hof the person or persona 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
- rely.
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l 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 Joint Intervenors or any individual acting on their behalf, including, but not lim-ited to, memoranda, correspondence, reports, surveys, tabu-lations, charts, books, pamphlets, photographs, maps, bulle-tins, minutes, handwritten notes, speeches, articles, transcripts, audio and video recordings and all other writings or recordings of any kind.
" Writings" and " recordings" consist of letters, words or numbers, or their equivalent, set down by handwriting, typewriting, printing, photostating, magnetic im-pulse, 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 Joint Intervenors.
A document shall be deemed to be within the " control" of Joint Intervenors or any individual acting on their behalf if they have ownership, possession or custody of the document or copy thereof, or have 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 Joint Intervenors, Norman Aamodt, Jane Lee or any person authorized to act on their behalf.
"SER" means the Staff's Safety Evaluation Report on Steam Generator Tube Repair and Return to Operation, NUREG-1019, and Supplement 1 thereto. **
A.
General Interrogatories 1.
(a)
For each interrogatory answer, and each subpart thereto, identify each person who participated in the prepara-tion of 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 each 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:
(a)
The educational and professional qualifications (including a complete list of publications) of each such person; (b)
The precise subject matter 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(2) 1(2)-1.
What forms of " benign sulfur" do you allege remain on the steam generator tubes?
1(2)-2.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory 1(2)-1.
1(2)-3.
Explain in detail how each fact stated in your answer to Interrogatory 1(2)-2 supports the allegations stated in your answer to Interrogatory 1(2)-1.
1(2)-4.
What " active forms" of sulfur do you allege can be generated from the benign sulfur forms identified in your answer to Interrogatory 1(2)-1?
1(2)-5.
State in detail each and every fact upon which you base the allegations in your answer to Interrogatory 1(2)-4.
1(2)-6.
Explain in detail how each fact stated in your answer to Interrogatory 1(2)-5 supports the allegations stated
.in your answer to Interrogatory 1(2)-4.
1(2)-7.
Explain in detail the mechanism (s) whereby the active forms of sulfur identified in Interrogatory 1(2)-4 would j
likely be generated from the benign forms of sulfur identified in Interrogatory 1(2)-1.
1(2)-8.
State in detail each and every fact upon which you base the allegations in your answer to Interrogatory 1(2)-7.
1(2)-9.
Explain in detail how each fact stated in your
. answer to Interrogatory 1(2)-8 supports the allegations stated
. in your answer to Interrogatory 1(2)-7.
L 1(2)-10.
Do you allege that the active forms of sulfur generated'in the manner described in your answer to Interroga-tory.1(2)-7 would be sufficient to reinitiate corrosion of the steam generator tubes?
1(2)-11.
If your answer to Interrogatory 1(2)-10 is other than an unqualified "no",
explain in detail the mechanism (s) whereby the corrosion would likely reinitiate, including the rate and quantity ~of active sulfur generation necessary to prompt such reinitiation.
1(2)-12.
State in detail each and every fact upon which c
you base the allegations in your answer to Interrogatory 1(2)-11.
1(2)-13. " Explain in detail how each fact stated in your
answer to Interrogatory 1(2)-12 supports the allegations stated
-in your answer.to Interrogatory 1(2)-11.
1(2)-14.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1(2)-1 through 1(2)-13, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
1(2)-15.
De you claim that the level of sulfur compound determined by post-cleaning testing to be in solution in the steam generator tubes is greater than that stated by Licensee, namely.0.1 ppm sulfate?
4 6.,
1(2)-16.
If the answer to Interrogatory 1(2)-15 is other than an unqualified "no",
state in detail each and every fact upon which you base-this allegation.
1(2)-17.
Explain in detail how each fact stated in your answer to Interrogatory 1(2)-16 supports the allegation stated in your answer to Interrogatory 1(2)-15.
1(2)-18.
Do you believe an inventory of 0.1 ppm sulfate
~
in solution has a significant corrosive effect?
1(2)-19.
If your answer to Interrogatory 1(2)-18 is other than an unqualified "no",
state in detail each and every fact upon which you base your allegation.
1(2)-20.
Explain how each fact stated in your answer to Interrogatory 1(2)-19 supports the allegation stated in~your answer to Interrogatory 1(2)-18.
1(2)-21.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1(2)-15 through 1(2)-20 above, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
1(2)-22.
Do you claim that the administrative controls adopted by Licensee are inadequate to prevent a build-up of sulfur to corrosive levels in the steam generator tubes?
1(2)-23.
'If the answer to Interrogatory 1(2)-22 is other than an unqualified "no",
state in detail each and every fact upon which you base this allegation, specifying the particular administrative control to which each alleged inadequacy relates.
l 1(2)-24.
Explain in detail how each fact stated in your answer to Interrogatory 1(2)-23 supports the allegation stated
~
in your answer to-Interrogatory 1(2)-22.
1(2)-25.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories
~
1(2)-22 through 1(2)-24 above, and correlate each such document as specifically as possible (page and paragraph number) with
.each such fact.
1(2)-26.
Identify each person you propose to call as a witness in support of Contention 1(2).
1(2)-27.
Identify all documents, including relevant page citations, which you intend to offer as exhibits during<this
- proceeding to support Contention 1(2).
1(2)-28.
- 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(2).
C.
-Interrogatories on Contention 1(3) 1(3)-1.
Define the term " morphological changes".
1(3)-2.
Identify in detail the types of " morphological changes" which you' claim are present "in the inner tube sur-face, remote from the expanded joints," which "could reasonably b'e presumed to be the precursors of.IGSCC."
1(3)-3.
For'each type of morphological change identified
-in your answer to Interrogatory 1(3)-2, state in detail each and every fact upon which you base your allegations that 8-f
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(a) such morphological change is present in the steam generator tubes, (b) and the particular morphological change could reasonably be presumed to be a precursor of IGSCC.
1(3)-4.
Explain in detail how each fact stated in your answer to Interrogatory 1(3)-3 supports each allegation in your answer to Interrogatory 1(3)-2.
1(3)-5.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1(3)-1 through 1(3)-4 above, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
1(3)-6.
Identify each person you propose to call as a witness to support Contention 1(3).
1(3)-7.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 1(3).
~
1(3)-8.
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(3).
D.
Interrogatories on Contention 1(51 1(5)-1.
Identify each and every " potential stress cracking agent other than active forms of sulfur" which you claim could have caused or significantly contributed to the IGSCC which occurred in the TMI-1 steam generators. -
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1(5)-2.
For each potential stress cracking agent identi-fied in your answer to Interrogatory 1(5)-1, state in detail each and every fact upon which you base your allegation that the particular agent could have caused or significantly con-tributed to the IGSCC which occurred.
1(5)-3.' Explain in detail how each fact stated in your answer to Interrogatory 1(5)-2 supports the allegations stated in your answer to Interrogatory 1(5)-1.
1(5)-4.
For each potential stress cracking agent identi-fied in your answer to Interrogatory 1(5)-1, state with specif-icity the quantity of each such agent which you claim could cause or significantly contribute to corrosion of the steam generators.
1(5)-5.
State in detail each and every fact upon which you base the allegations stated in your answer to Interrogatory 1(5)-4.
1(5)-6.
Explain in detail how each fact stated in your answer to Interrogatory 1(5)-5 supports the allegations stated in your answer to Interrogatory 1(5)-4.
1(5)-7.
Identify each and every document which you claim cupports each fact set forth in your answers to Interrogatories 1(5)-1 through 1(5)-6 above, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
1(5)-8.
Do you claim that any of the potential stress cracking agents identified in your answer to Interrogatory l L
1(5)-1 were in fact present, at the time of the corrosion here in issue, in the quantities which you claim (in your a..swer to Interrogatory 1(5)-4) are sufficient to cause or significantly contribute to the corrosion?
1(5)-9.
If your answer to Interrogatory 1(5)-8 is other than an unqualified '"no," identify each and every potential stress cracking agent which you claim was present, at the time of the corrosion here in issue, in sufficient quantities in the steam generators to cause or significantly contribute to the corrosion which occurred.
1(5)-10.
For each potential stress cracking agent identi-fled in your answer to Interrogatory 1(5)-9, state in detail each and every fact upon which you base your allegation that the given agent was present in sufficient quantities to cause or significantly contribute to the corrosion.
1(5)-11.
Explain in detail how each fact stated in your answer to Interrogatory 1(5)-10 supports your allegation that the particular agent was present in sufficient quantities to cause or significantly contribute to corrosion.
1(5)-12.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1(5)-8 through 1(5)-11 above, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
1(5)-13.
Define the term " synergistic effects" as used in Contention 1(5). -
~
t 1(5)-14.
Identify each and every synergistic effect which you allege was not, but should have been, considered and explain the cause of and chemical agents involved in each such effect.
1(5)-15.
State in detail each.and every fact upon which you base the allegations. stated in your answer to Interrogatory 1(5)-14.
1(5)-16.
Explain.in detai( how each fact identified ~in your answer to. Interrogatory 1(5)-15 supports the allegations in your answer to Interrogatory 1(5)-14.
4 1(5)-17.
Do you allege that any of the synergistic effects identified in your answer to Interrogatory 1(5)-14
' caused or significantly contributed to the corrosion of the steam' generator tubes?
~1(5)-18.
For each synergistic effect with respect to which your answer to Interrogatory 1(5)-17 is other than an un-qualified "no",
identify the synergistic effect, its cause and agents involved, and state in-detail the factual bases for l
j-those allegations.
1(5)-19.
Explain in detail how each fact stated in your i'
answer to Interrogatory 1(5)-18 supports your allegation that the particular synergistic effect caused or significantly con-tributed to the-corrosion of the steam generators.
1(5)-20.
For each synergistic effect identified in your answer to Interrogatory 1(5)-18, identify the magnitude of the synergistic effect between the agents involved. - '
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. _ _ -..,. _.. -. _ _ _. ~. - _,
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y 1(5)-21.
State in detail each and every fact upon which I
you_ base the allegation stated in your answer to Interrogatory 1(5)-20.
1(5)-22.
Explain in detail how each and every fact stated in your answer to Interrogatory 1(5)-21 supports the allegation stated in your answer to Interrogatory 1(5)-20.
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'1(5)-23.
Identify each and every document which you claim i
~
supports each fact set forth in your answers to Interrogatories 1(5)-13 through 1(5)-22, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
j 1(5)-24.
With respect-to each synergistic effect identi-fied in your answer to Interrogatory 1(5)-18, do you claim that the necessary cause and agents involved in the effect are now
.present (i.e.,.after the clean up of the steam generator tubes), in sufficient quantities that the synergistic effect could cause or-significantly contribute to reinitiation of the l
corrosion?
1(5)-25.
If your answer to Interrogatory 1(5)-24 is other than an unqualified "no",
(a)
Identify each synergistic effect for which this 1
la so, and state its cause and agents. involved; (b)
State in detail each and every fact upon which you basa the allegations in your answer to subparagraph (a);
and
- _ _... _. _., _ _...... _. ~
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(c)
Explain how each fact stated in your answer to subparagraph (b) supports the allegations in your answer to subparagraph-(a).
1(5)-26.
Do you claim that the administrative controls Licensee plans to-initiate to guard against the introduction of contaminating agents do not provide reasonable assurance against any synergistic effect which would be of sufficient magnitude to reinitiate the corrosion in the steam generator tubes?
1(5)-27.
If your answer to Interrogatory 1(5)-25 is other than an unqualified "no,"
(a)
Identify each synergistic effect for which this is so, and state its cause and the agents involved; (b)
State in detail each and every fact upon which you base the agent each and every fact upon which you base your allegations in your answer to subparagraph (a); and (c)
Explain in detail how each fact stated in your answer to subparagraph (b) supports the allegations in your answer to subparagraph (a).
1(5)-28.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories 1(5)-24 through 1(5)-26 above, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
1(5)-29.
Identify each person you propose to call as a witness to support Contention 1(5).
l
d' 1(5)-30.
Identify all documents, including all relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 1(5).
1(5)-31.
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(5).
II.
REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R.
$ 2.741, Licensee hereby requests that-Joint Intervenors respond in writing to the following re-quest for production of documents and produce the original or best copy of each requested document at the office of the un-dersigned, Shaw, Pittman,'Potts & Trowbridge, 1800 M Street, N.W.,
Washington, D.C. 20036 or at another place mutually con-venient to the parties.
" Document (s)" means all writings and records of every type in'the possession, control or custody of Joint Intervenors or any individual acting on their behalf, including, but not lim-ited to, memoranda, correspondence, reports, surveys, tabu-lations, charts, books, pamphlets, photographs, maps, bulle-tins, minutes, handwritten notes, speeches, articles,
' transcripts, audio and video recordings and all other writings or recordings of any kind.
" Writings" and " recordings" consist of letters, words or numbers, or their equivalent, set down by handwriting, typewriting, printing, 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 Joint Intervenors.
A document shall be deemed to be within the " control" of Joint Intervenors or any individual acting on their behalf if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the document or copy thereof, from any person or public or private entity having physical possession thereof.
Licensee requests that Joint Intervenors produce each and every document identified or described in the answers to the interrogatories in Section I above.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE s
d BY:
(<
Ge' urge F.
Trowbridge, 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 -
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'83 DEC 19 A10:53 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION LFF IfJ: CF 5Lu.-t ir
['ch Before the Atomic Safety and Licensing a
In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Tnree Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Interrogatories and Request for Production of Documents to Intervenor TMIA" and " Licensee's First Set of Interroga-tories and Request for Production of Documents to Joint Intervenors" were served this 15th day of December, 1983, by deposit in the U.S. mail, first class, postage prepaid to those on the attached Service List.
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Bruce W7 Churchill, P.C.
Dated:
December 15, 1983 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
)
ASLBP 83-491-04-OLA (Three Mile Island Nuclear
)
(Steam Generator Repair)
Station, Unit No. 1)
)
SERVICE LIST Sheldon J. Wolfe Atomic Safety and Licensing Administrative Judge Board Panel Chairman, Atomic Safety and U.S. Nuclear Regulatory Commission Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Docketing and Service Section (3)
Washington, D.C.
20555 Office of the Secretary U.S. Nuclear Regulatory Commission Dr. David L. Hetrick Washington, D.C.
20555 Administrative Judge Atomic Safety and Licensing Board Joanne Doroshow, Esq.
Professor of Nuclear Engineering Louise Bradford University of Arizona Three Mile Island Alert, Inc.
Tucson, Arizona 85271 315 Peffer Street Harrisburg, Pennsylvania 17102 Dr. James C. Lamb, III Administrative Judge Jane Lee Atomic Safety and Licensing Board 183 Valley Road 313 Woodhaven Road Etters, Pennsylvania 17319 Chapel Hill, North Carolina 27514 Norman Aamodt Richard J.
Rawson, Esq.
R. D.
5, Box 428 Mary E. Wagner, Esq.
Coatesville, Pennsylvania 19320 Office of Executive Legal Director U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.
20555
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