ML20083H262
| ML20083H262 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/10/1984 |
| From: | Rader R CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | LIMERICK ECOLOGY ACTION, INC. |
| References | |
| NUDOCS 8401130122 | |
| Download: ML20083H262 (13) | |
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'84 JMi12 A10:23 UNITED STATES OF AMERICA NUCLEA REGULATORY COMMISgN_
Before the Atomic Safety and Licensing)m 4ec.
rei Boaid In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
APPLICANT'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR LIMERICK ECOLOGY ACTION ON CONTENTION I-42 Pursuant to the Rules of Practice of the Nuclear Regulatory Commission ( "NRC ), 10 C.F.R. 52.740(b), and the Atomic Safety and Licensing Board's Memorandum and Order (October 28, 1983), Philadelphia Electric Company ("Appli-cant")
hereby propounds the following interrogatories to Limerick Ecolt,9y Action
(" LEA")
to be answered fully in writing, under oath, in accordance with the definitions and instructions below.
Additionally, pursuant to 10 C.F.R.
S2.741, Applicant requests that intervenors produce for inspection and copying (or provide copies of) those documents designated by intervenors in their respective answers below.
Definitions and Instructions 1.
For each interrogatory, please state the full name, work address, and title or position of each person providing information for the answer to the interrogatory.
2.
The following definitions shall apply:
8401130122 840110
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e 4 a.
"Intervenor" shall refer to LEA or any
- officer, member, employee or consultant thereof.
b.
" Document" shall mean any written, printed, typed or other graphic matter of any kind or
- nature, and all mechanical and electronic sound recordings or transcripts thereof, in the possession,
- custody, or control of intervenor, or its officials, employees, or agents; it shall also mean all copies or drafts of documents by whatsoever means made, c.
"Date" shall mean the exact day, month and year, if ascertainable, or, if not ascertain-able, the best approximation (including the event's relationship to other events in the relevant context of the interrogatory).
d.
"NRC" or " Commission" shall mean either the Atomic Energy Commission or the Nuclear Regulatory Commission, as appropriate, including its regulatory staf f and adjudica-tory boards, as indicated by the context of the interrogatory.
e.
"Specify",
when referring to a proceeding before the Nuclear Regulatory Commission, means that the answer shall set forth the proceeding, applicant, docket
- number,
. t relevant
- date, and any other descriptive information appropriate to the request.
f.
"Specify" or " identify", when referring to an individual, corporation, or other
- entity, means that the answer shall set forth the
- name, present or last known work address, and, if a corporation or other entity, its principle place of business or, if an indi-
- vidual, his or her title or titles and employer.
Once an individual corporation or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation or other entity to state merely his, her or its name.
3.
These interrogatories request all knowledge and information in intervenor's possession and/or knowledge and information in the possession of intervenor's
- agents, representatives, consultants, and unless privileged, attor-neys.
4.
In each instance in which an interrogatory requests a statement of intervenor's assertion, contention, view or opinion, the answer shall also contain a full discussion of the factual b& sis for the assertion or opinion.
Interrogatories 1.
State whether intervenor intends to present any expert witnesses on the subject matter at issue in
.. ' fj Contention 1-42, as stated in your letter dated July 11, 1983 and admitted by the Licensing Board in its Memorandum and Order dated October 28, 1983 (slip op. at 2).
If so, identify each expert witness and state (a) his professional qualifications; (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) the grounds for each opinion.
Identify by court, agency or other body, each proceeding in which such individual ren-dered testimony on this subject.
2.
State whether intervenor intends to present any factual witnesses on the subject matter at issue in Con-tention I-42.
If so, identify each such factual witness and further state (a) his professional qualifications; (b) the subject matter on which the witness is expected to testify; (c) the substance of the facts to which the witness is expected ~ to testify.
Identify by court, agency, or other
- body, each proceeding in which such individual rendered testimony on this subject (s).
3.
Identify by title, author, publisher and date of issuance or publication, all documents that you rely upon as a basis for your contentions or that you intend to use (by way of reference or evidentiary proffer) in presenting your direct case or.in cross-examining other witnesses on Con-tention I-42 and all documents to which you intend to refer in conducting cross-examination of other witnesses who may testify in connection with any such contention.
e B 4.
To the extent that your answer to any interrogatory is based upon one or.more documents, (a) identify each such document on which your answer is based; (b) identify the specific information in such document upon which you rely; (c) explain how the information provides a basis for your answer.
5.
To the extent that your answer is based upon any study, calculation, research or analysis, (a) describe the nature of the study, calculation, research or analysis and identify any documents which discuss or describe the study,
-calculation, research or analysis; (b) identify the per-son (s) or entity (ies) who performed the study, calculation, research or analysis; (c) describe in detail the information which was the subject of the study, calculation, research or analysis; (d) describe the results of such study, calcu-lation, research or analysis; (e) explain how such study, calculation, research or analysis provides a basis for your
- answer.
6.
To the extent that your answer is based upon conversations, consultations or correspondence or other communications with one or more individuals or entities, please identify each such individual or entity; (b) state the educational and professional background of each such individual, including occupation and institutional affil-iations; (c) describe the nature of each communication, including time and context, and describe the information
m.
...b received from each such individual or entity; (e) explain how such information provides a basis for your answer.
7.
To the extent that intervenor possesses information or documents expressing facts or opinions which are relevant to the specific interrogatories below, but which do not support intervenor's position or which have not otherwise been fully provided in the answers thereto, please provide such information and documents.
8.
Specify eacn system, component or part of the Limerick Generating Station which intervenor asserts is "important to safety" within the meaning of 10 C.F.R.
S50.49(b) which has not been included in Appendix B of the Environmental Qualification Report ("EQR") for Limerick.
As to each such component or part, (a) describe in detail the component or parts and their exact location at the Limerick Generating Station; (b) identify the manufacturer, if known; (c) identify whether the component or part is asserted to be within the category "important to safety" because of its inclusion within 10 C.F.R.
S50.49b (1) (2) or (3), describing in detail the reason for classification in one or more of these categories; (d) describe in detail the alleged "impor-tant to safety" function which the component or part will perform; (e) state the basis which the intervenor used in concluding that another
- system, component or
- part, or combination thereof, which is being qualified or which is not within a harsh enviranrent cannot perform the function instead of the. subject part or component; (f) state the
6,
basis, if any, upon which intervenor asserts that environ-mental qualification of such component or part will not or could not be performed prior to fuel loading for Limerick Unit 1 or 2, as appropriate; (d) the exact event or events for.which intervenor asserts that the equipment must be
. qualified, the time or times after the initiation of the most critical event during which the part or component is asserted to be necessary to operate, and the exact environ-mental conditions which the component or part would experi-ence.
9.
Identify any-and all components or parts listed in Appendix B of the EQR which intervenor asserts will not be environmentally qualified by the time of fuel loading for each unit, giving the basis for such conclusion and stating when intervenor believes such part or equiptent will be qualified, giving the basis for such conclusion or estimate.
10.
With regard to each of the following parts, compo-nents, or systems which intervenor alleges should be includ-ed in the equipment qualification program, (1) feedwater control; (2) emergency lighting and communications systems; i
(3) plant process computer system; (4) computer software:
(a) identify the exact systems, part or component involved, with reference to the description contained ~in the FSAR or P&I.D.'s, if possible; (b) identify the location or lo-cations.of the systems, parts or components at the Limerick L
Generating Station; (c) identify the conditions, e.g.
LOCA L
or HELL; which intervenor asserts require that these systems l
s 5 be qualified; (d) identify the operations that such equip-ment would have to perfona for such conditions and the time frame in which these actions are required; (e) identify the harsh environment that such equipment, part or component would experience; (f) state intervencr's understanding of systems, equipment, parts or components which can perform functions equivalent to those identified above and which are either being qualified or are not located in a harsh en-vironment and state why this other system, equipment, part or component is not sufficient to perform the intended function.
11.
As to each
" human interaction problem" which intervenor asserts should be addressed by Applicant in its Environmental Qualification Report for Limerick; (a) specify what is meant by the term " human interaction problem";
(b) identify the exact location of such component or part; (c) specify each component or part which intervenor alleges should be the subject of such a " human interaction review";
(d) identify the manufacturer of the part or component, if known; (e) specify the "important to safety" function which requires analysis of h'Iman interaction with regard to the particular part or component; (f) state the specific basis in NRC regulations or regulatory guidance for performing such a review as to the particular human interaction and part or component; (g) state the elements of the human interaction review, including goals, methodology, experi-mental work, studies, data analysis techniques and basis for I
) ~.
t evaluating the results which intervenor asserts is neces-sary.
12.
As to each component or part for which intervenor asserts that an Equipment Qualification Review Record
("EQRA") has not been provided in Applicant's Environmental Qualification Report for Limerick, (a) specify each part or component allegedly omitted; (b) identify the exact location of such component or part; (c) identify the manufacturer, if known; (d) state the basis upon which intervenor relies to assert that such part or component should have been included in an EQRR.
13.
As to each part or component for which intervenor asserts that the EQRR specifies a qualified life of less than 40 years, (a) specify the part or component; (b) identify.the manufacturer, if known; (c) the correctiva action which intervenor asserts should be taken by Applicant to correct the alleged deficiency, the basis upon which the means for identification of such items by Applicant as discussed on page 8.2 of the Environmental Qualification Report is insufficient to meet NRC requirements.
14.
State intervenor's basis for the assertion that the key switch in the control room for the standby liquid control system is in a harsh environment and thus subject to qualification pursuant to NRC requirements.
15.
State what electrical equipment in the PASS system intervenor asserts must be qualified; specify how failure in such electrical equipment could mislead the operator.
- )
_ l ')
s 16.
Identify each and every way which the document, Philadelphia Electric Company Q*5 Component Classification Program Rules fails to provide a methodology for assuring that equipment, parts or components f allir.g in the defini-tion of 10 C.F.R.
S50. 49 (b) are not properly identified.
The response to this interrogatory may contain proprietary material; if so, it should be sent only to Applicant's
. counsel in Washington, D.C.
Request for Production of Documents Please attach to you answers to the interrogatories listed above a copy of all documents applicable to such answer or upon which you otherwise intend to rely in the presentation of your direct case or in the cross-examination of other witnesses, whether or not they support your con-tentions.
Alternatively, please state that all such docu-ments will be produced at a reasonable time and place to be agreed upon by the Applicant for inspection and copying.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
Robert M. Rader Counsel for Philadelphia Electric Company January 10, 1984
.)
T UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
~
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's First Set of Interrogatories and Request for Production of Documents to Intervenor Limerick Ecology Action on Contention I-42" dated January 10, 1984 in the captioned matter, have been
. served upon the following by deposit in the United States mail this 10th day of' January, 1984:
Judge Lawrence Brenner (2)
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear-Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Docketing and Service Section Judge Richard F. Cole Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Ann P.
Hodgdon, Esq.
Counsel for NRC Staff Judge Peter A. Morris Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Hand Delivery Federal Express
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Atomic Safety and Licensing Steven P. Hershey, Esq.
Board Panel Community Legal U.S. Nuclear Regulatory Services, Inc.
Commission Law Center West North Washington, D.C.
20555 5219 Chestnut Street Philadelphia, PA 19139 Philadelphia Electric Company ATTN:
Edward G. Bauer, Jr.
Angus Love, Esq. 101 East Vice President &
Main Street Norristown, PA General Counsel 19401 2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue Mr.. Frank R.
Romano Ardmore, PA 19003
-61 Forest Avenue Ambler, Pennsylvania 19002 Robert J. Sugarman, Esq.
Sugarman & Denworth Suite Mr. Robert L. Anthony 510 North American Building Friends of the Earth of 121 South Broad Street the Delaware Valley Philadelphia, PA 19107 106 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Director, Pen'.tsf vania i
Emergency Management Agency Mr. Marvin I. Lewis Basement, Transportation 6504 Bradford Terrace and Safety Building Philadelphia, PA 19149 Harrisburg, PA 17120 Phyllis Zitzer, Esq.
Martha W.
Bush, Esq.
Limerick Ecology Action Kathryn S. Lewis, Esq.
P.O. Box 761 City of Philadelphia 762 Queen Street Municipal Services Bldg.
Pottstown, PA 19464 15th and JFK Blvd.
Philadelphia, PA 19107 Charles W.
Elliott, Esq.
Brose and Postwistilo Spence W.
Perry, Esq.
1101 Building lith &
Associate General Counsel Northampton Streets Federal Emergency Easton, PA 18042 Management Agency 500 C Street, S.W., Rm. 840 Zori G. Ferkin, Esq.
Washington, DC 20472 Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director Governor's Energy Council Bureau of Radiation
'1625 N. Front Street Protection Harrisburg, PA 17102 Department of Environmental Resources 5th Floor, Fulton Bank Bldg.
Third and Locust Streets Harrisburg, PA 17120 Hand Delivery Foderal Express
?
i-Jay M.-Gutierrez, Esq.
U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King'of Prussia,.PA 19406 James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA' 19464 he k'
Robert M.
Rader Hand Delivery Federal Express
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