ML20083J408
| ML20083J408 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/06/1983 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-OL, NUDOCS 8401100140 | |
| Download: ML20083J408 (5) | |
Text
l January 6, 1984 DOCHETED NC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- g4 g _9 g gg Before the Atomic Safety and Licensing Board CFFICE Of SECRETA.
00CKETING A SEPvt.t.
BRANC$1 In the Matter of
)
)
CLEVELAND ELECTRIC ILLUMINATING
)
Docket Nos.
50-440 COMPANY, e_t al.
)
50-441
)
(OL)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
OCRE 'fElfrH SET OF INIERBOGMDRIBS 'Io t@O 9mEP Intervenor Chio Citizens for Responsible Energy ("OCRE") hereby files its tenth set of interrogatories to the Staff, pursuant to 10 CFR 2,720(h)
(2)_lii) and to the Licensing Board's December 23, 1983 Memorandum and Order (New Contention on Diesel Generators). In accordance with 10 CFR 2.720(h)
(2)(ii), OCRS is subnitting these interrogatories to the presiding officer and also moves the presiding officer to require the Staff to answer them.
OCRE hopes that the Staff will voluntarily answer these interrogatories,,
thereby avoiding unnecessary delay and needless burdening of the Licensing Board.
In order to require the NBC Staff to answer interrogatories under 10 CPR 2.720(h) (2) (ii), a tefold test must be met: first, that the answers to the interrogatories are necessary to a proper decision in the proceeding, and, second, that the mswers to the interrogatories are not reasonably obtainable fran any other source.
Since the Staff has done much work concerning the reliability of Transamerica Delaval diesel generators, and since the Staff's documents (e.g., Information Notice 83-5.8) served both as basis and good cause fer the contention, it is entirely reasonable and proper to consider answers
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< \\)AL> J 8401100140 830106 J
l PDR ADOCK 05000440 t
8 PDR to interrogatories requesting clarification of or further information on the Staff's conclusions and investigations to be necessary to a proper decision in this proceeding. OCRE would also affirm the Board's remarks in its December 23, 1982 Memorandum and Order (Concerning Discovery frcm the Staff on Hydrogen Issue) concerning the meaning of "necessary" and would suggest that the answers to these interrogatories are~just as necessary as are the Staff's answers to interrogatories on hydrogen control.
These interrogatories must be answered by specific persons on the NRC Staff. Although information from the Public Document Rocm may provide scne background information relevant to Issue #16, this type of information cannot substitute for answers, made under oath or affirmation, to specific interrogatories concerning this issue in this proceeding.
OCRE thersfore believes that a positive showing has been made on both factors of 10 CPR 2.720(h) (2) (ii); the Staff must respond to these interrogatories.
INTERROGATORIES: Issue #16 Statertent of Purpo'se: The following interrogatories are designed to ascertain thebasisfortheStaff'sconbernoverthereliabilityofTransamerica Delaval diesel generators ("TDI DGs") and to discover the NRC's plans for resolving this problem for PNPP.
10-1.
Identify all persons Staff intends to call as witnesses on Issue #16 Indic:.te which persons are Staff members, and which are consultant personnel. Provide the professional qualifications of all persons so named. Produce all testimony or drafts of testimony each such person will present, or, if not available, sumarize the areas each person's testimony will cover. Provide the bases of all facts and opinions to be advanced in testimony.
10-2.
Identify each person or organi::ation whose expertise will be utilized by Staff in its response to Issue #16 cr on the larger issue of
'IDI DG reliability. Provide the professional qualifications of each person or organization identified. Explain the services to be rendered by each consulting organization named.
10-3.
List all cxets kncun by Staff to exist pertaining to the reliability of TDI DGs, Indicate which documents are available in the Public Document Rocm, and produce those documents not availabie in the PDR.
10-4.
Produ m a concise list of all failures or deficiencies concerning
'IDI DGs twed at ccmnercial nuclear facilities (including foreign users), and indicate the causes of these failures or deficiencies, if kncwn.
10-5.
Has the Staff monitored TDI DGs used in applications other than commercial nuclear facilities? If so, produce a concise list of failures or deficiendies encountered (with causes, if kncun) in other applications.
10-6.
Produce a concise list of viol.ations or citations of TDI relating to quality assurance in its design or manufacture of DGs, include date of violation, criterion of Appendix B to 10 GR 50 violated, cause of violation, severity level, whether civil penalties were
~
imposed,gand corrective action taken.
10-7.
Provide t$he total rurtber of violations at 'IDI and all other DG vendors monitored by the.NRC.
10-8.
Does the Staff consider the number and severity of TDI violations to be significant, in comparison to other DG vendors? Why or why, not?
10-9.
hhat standards does the Staff have for defining and assuring the
" reliability" of DGs? To what extent is judgernent involved in
defimng and detennining " reliability"?
10-10. What weight does the Staff 'give to the standards and rehur.uidations of the Diesel Engine Manufacturers Association (e.g., " Standard Practices for Iow and Mediun Speed Stationary Diesel and Gas Engines" 6th edition, 1972) in determining whether DGs are reliable and
' designed and built to appropriate quality standards?
'10-11.
What is the Staff's action plan for TDI DGs, as mentioned in BN-83-160A?
10-12. Concerning Inspection Report 99900334/83-01, p.14, where it is stated that TDI's management would take exception to all violations identified during that inspection:
(.a) Is this a canon action or attitude among vendors nonitored by the NRC?
(b). Does the NBC consider such an attitude indicative of management's comu.tment (.or lack thereof) to product quality? Why or why not?
10-13. What is the nature of the investigation being conducted by the NRC Office of Investigations regarding TDI?
10-14. List all allegations, received by the NBC concerning TDI; include date of the allegation, whether the allegation was investigated, and 1
if investigated, whether it was substantiated.
10-15. Identify eacit and every person on or : serving as a consultant to the the Staff who disagrees with any ansmr to the above interrogatories or with any Staff position regarding DG reliability in general and that of TDI DGs in particular.
Respectfully subnitted, Tf Susan L. Hiatt OCRE Representative 8275 Munson Rd.
Mentor, OH 44060 (216) 255-3158 i
i.
J I
li
' l' i
1 CERTIFICATE OF SERVICE.
l.
.l This is to certi'fy that copies of the foregoing were served by deposit in the U.S. Mail, first class, postage prepaid, this 4; ^L day of Qo van t /
, 19 84 to those on the service list b,elow./
,/
uA Susan L.
Hiatt SERVICE. LIST Peter B..Bloch, Chairman Terry Lodge, Esq.
Atomic Safety & Licensing Board 618 N. Michigan St.
U.'S, Nuclear Regulatory Comm.
8"it Washington,'D.C.
20555 gledo OH 43624 Dr. Jerry'R.;Kline Atomic Safety.& Licensing Board.
U.S. Nuclear. Regulatory Commission i
Washington,'D.C.
20555 Mr..Glenn O.
Bright Atomic Safety &. Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Colleen P. Woodhead, Esq.
Office of'the' Executive Legal Director U.S. Nuclear Regulatory Commission Washington,.D.C.
20555
,u' Jay.Silberg, Esq.
Shaw, Pittman; Potts, & Trowbridge 1800 M Street, NW
. Washington, D.C.
20036 Docketing'& Service Branch
.Offi'ce of'the Secretary U.S..Naclear Regulatory. Commission Washington, D.C.
20555 Atomic'. Safety.&. Licensing Appeal Board Panel U.S. Nuclear. Regulatory Commission Washington, D.C.
20555 i