ML20086K045
| ML20086K045 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/24/1984 |
| From: | Churchill B METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| 83-491-04-OLA, 83-491-4-OLA, ISSUANCES-OLA, NUDOCS 8401260190 | |
| Download: ML20086K045 (8) | |
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DOCKETED January 24, '4b$~4 UNITED STATES OF AMERI M NUCLEAR REGULATORY COMMISSION CFFICE 0; SECh* 4 GCCKLUh3 4 SW Before the Atomic Safety and Licensfn"hUboard 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
)
S ta tion, Unit No. 1)
)
LICENSEE'S THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR TMIA This third set of interrogatories and regest for produc-tion of documents supplements Licensee's First and Second Set of Interrogatories and Request for Production of Documents served on TMIA on December 15, 1983, and January 12, 1984, respectively.
In accordance with 10 C.F.R.
S 2.740b, Licensee requests that TMIA answer each interrogatory set forth below separately and fully in writing, and under oath or affirmation.
Answers must be signed by the person making them and must 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.
S 2.740(e),
8401260190 840124 PDR ADOCK 05000289 G
PDR h
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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 identification of a document'is requested, briefly describe the-document (e.g., book, letter, memorandum, transcript, report, handwritten notes, test date, 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 rely.-
As used in the interrogatories and request for production of documents set forth below, the following definitions shall apply:
l
" Document (s)" means all writings and records of every type in the possession, control or custody of TMIA or any l
individual acting on its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, mats, bulletins, minutes, handwritten notes, speeches, articles, transcripts, audio and video recordings and all other writings or recordings
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2,-
of any kind.
" Whitings" and " recordings" ' consist o f letters, words ornnumbers, or their equivalent, set down by handwriting, typewriting, printing, photostating,7 magnetic impulse,
~
. mechanical:or electrical recording, or other form of. data compilation.
" Document ( s) " shall also mean copies of documents evenLthough.the originals thereof'are not in the possession, custody, or control 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,'from any person or public or private entity having physical possession thereof.
"You" _ or "your(s) " means TMIA, its members or any person auth' orized to act on its behalf.
1.
"SER" means the NRC Staff's Safety Evaluation' Report on p
Steam Generator Tube Repair and Return to Operation, NUREG-1019, and Supplement 1 thereto.
I.
SUPPLEMENTAL INTERROGATORIES A.
General Interrogatories l.
(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 p
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.
-3'-
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.d.
III-1.d-1.
What is the nature of your relationship with Dr. George C. Sih?
III-1.d.2.
When did TMIA discuss " axial symmetric stress ar.alysis" with Dr. Sih?
III-1.d.3.
State in detail what Dr. Sih told you that supports your contention that axial symmetric stress analysis would not be applicable to cracks.
III-1.d.4.
Explaid in detail how Dr. Sih's conclusions undermine or are inconsistent with the evaluations in the TPR and SER of "the kinetic expansion repair technique, including leak tightness and load carrying capabilities." -
III-1.d.5.
. Identify each and every document which Dr.
Sih claims support his conclusions regarding axial symmetric stress analysis, including any notes and letters that Dr.
Sih may have provided.
III-1.d-6.
When did you have conversations with Dr. Sih pertaining to the effects of thermal stress on small versus
.large cracks?
III-1.d-7.
State-in detail Dr. Sih's theory on the effects of thermal stress on small versus large cracks.
III-1.d-8.
How doe's Dr. Sih define "small cracks"?
III-1.d-9.
How does Dr. Sih define "large cracks"?
III-1.d-10. Explain in detail how Dr. Sih's conclusions regarding the effects of thermal stress on small versus large cracks undermine or are inconsistent with the. evaluations in the SER and TPR of "the kinetic expansion repair technique, including leak tightness and load carrying capabilities."
III-1.d-ll. Identify each and every document that Dr.
Sih claims support his conclusions regarding the effects of thermal stress on small versus large cracks, including any notes and letters that Dr. Sih may have provided.
III-1.d-12. State in detail the content of any otber communications with Dr. Sih pertaining to the issues raised in Contention 1.d.
III-1.d-13.. Explain in detail how the communications listed in your response to Interrogatory III 1.d-12 support Contention 1.d.
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.III-1.d-14.' Identify each and every document, including letters and notes,-relied upon or supplied inr Dr. Sih in
- relation to the communications listed in your response to
~ Interrogatory III-1.d-12.
II.
REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R. S 2.741, Licensee herby requests that,TMIA respond in writing to_the following. request for
_ production of documents and produce the original or best copy of each requested document at the office of the ' under-signed, Shaw, Pittman, Potts & Trowbridge, 1800 M Street, N.W.,
- Washington, D.C.
20036 or at' another place mutually convenient
- to the parties.
Licensee requests that TMIA produce each and every document, identified or described in the answers to the Interrogatories in section I above, unless those documents were prepared by Licensee or the NRC Staff with-respect to the TMI-l steam' generator repairs.
Respectfully submitted, i
l SHAW, PITTMAN, POTTS & TROWBRIDGE Mu.U.hudM[xQ BY:
George F.
Trowbridge, P.C.
Bruce W.
Churchill, P.C.
Diane E.
Burkley Wilbert Washington II Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated: January 24, 1984 L
~ 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)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Third Set of Interrogatories and Request for Production of Documents to Intervenor TMIA" were served this 24th day of January, 1984, by deposit in the U.S. mail, first class, postage prepaid to those on the attached-Service List.
b%u U. O%vJib /L..:
Bruce W.
Churchill, P.C.
. Dated:
January 24, 1984 l-1 I
e 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 26514 I
Norman Aamodt Richard J.
Rawson, Esq.
R.
D.
5, Box 428 Mary E. Wagner, Esq.
Coatesville, Pennsylvania 19320 Office of Executive Legal Director i
U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 Atomic Safety and Licensing Appeal l
Board Panel U.S. Nuclear Regulatory Commission Washington,.
D.C.
20555 i!'
i t
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