ML20086K063
| ML20086K063 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/24/1984 |
| From: | Churchill B METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | AAMODTS |
| Shared Package | |
| ML20086K059 | List: |
| References | |
| 83-491-04-OLA, 83-491-4-OLA, ISSUANCES-OLA, NUDOCS 8401260207 | |
| Download: ML20086K063 (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 SECOND SET OF INTERROGATORIES TO JOINT INTERVENORS This second set-of interrogatories is filed by Licensee to Joint Intervenors Norman Aamodt and Jane Lee to supplement the
. interrogatories and production request served by Licensee on i
December 15, 1983, and responded to by Joint Intervenors on January 16, 1984.
Licensee requests that Joint Intervenors j
answer separately and fully in writing and under oath or affir-l mation, each of the following interrogatories.
Answers must be signed by the person making them and must be served within 14 f
days after service of the interrogatories.
l I.
SCOPE OF THE INTERROGATORIES These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or l
amended-as appropriate, pursuant to 10 C.F.R. 5 2.740(e),
8401260207 840124 PDR ADOCK 05000289 G
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should Joint Intervenors or any individual acting on their
-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, name and address of publisher, 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 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 bulletins,.-
4 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, mechani-cal 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.
II.
INTERROGATORIES A.
General Interrogatories II-1(a)
For each interrogatory answer, and each subpart i
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. - - - -. -
.a (b)
Identify all such information which was provided i
by each such person and the specific interrogatory in which such information is contained.
II-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 expe:ted to testify; (c)
The substance of the facts and opinions as to which e,ach 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.
1 B.
Interrogatories on Contention 1(2)
R II-1(2)-1.
Do you allege that the sulfur present in.the r
i steel from which the tubes were made was the source of sulfur which caused the IGSCC (a)
. of the TMI-l OTSG; and/or
. (b) poses a significant risk of IGSCC in the future?
II-1(2)-2.
If your answer to either part of Interrogatory II-1(2)-1 is other than an unqualified "no":
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2 (a) explain the mechanism by which the IGSCC occurred and/or is likely to reoccur; and (b) identify the reactor operating conditions, including temperatures and chemical environments, under which the IGSCC occurred and/or is likely to reoccur.
II-1(2)-3.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(2)-1 and II-1(2)-2, and explain in detail how each such fact supports your allegations.
II-1(2)-4.
Do you allege that the sulfur present in the steel as fabricated is in an active or aggresive form capable of causing corrosion?
II-1(2)-5.
Explain, in terms of the expected or potential thermal and chemical environment of the tubes, the mechanism by which active forms of sulfur are likely to be generated from the sulfur present in the steel as fabricated.
II-1(2)-6.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(2)-5, and explain in detail how each such fact supports your allegations.
II-1(2)-7.
Explain each and every similarity which you allege exists between the conditions under which Blanchet et al. found intergranular cracking of Inconel-600 or Inconel X 750 and the conditions attendant to operation of the TMI-l OTSG.
II-1(2)-8.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(2)-7, and explain in detail how each such fact supports your allegations.
II-1(2)-9.
Identify each and every operating condition which you allege causes.ne " system oxygenation" which alleged-ly could prompt " spontaneous intergranular degradation."
II-1(2)-10.
Explain the mechanism (s) by which
" spontaneous intergranular degradation could occur spontane-ously from the action with sulfur within this alloy matrix" during the operating conditions and resultant system oxy-genation identified in your answer to Interrogatory II-1(2)-9.
II-1(2)-11.
State in detail each and every fact upon which you base your allegations in your answers to Interrogatories II-1(2)-9 and II-1(2)-10, and explain in detail how each such fact supports your allegations.
II-1(2)-12.
Explain the mechanism (s) by which IGSCC can occur " spontaneously if tube composition varies excessively".
II-1(2)-13.
Specify (a) the elements of the tube composi-tion wh' ch must "vtry excessively" in order for IGSCC to reinitiate spontaneously; and (b) with respect to each element so identified, the outer bounds of the extent of variation which is necessary for IGSCC to reinitiate spontaneously.
II-1(2)-14.
State in detail ecch and every fact upon which you base your allegations in your answers to Interrogatories II-1(2)-12 and II-1(2)-13, and explain in detail how each such fact supports your allegations. 1-
O II-1(2)-15.
Identify each transient which you allege could activate the sulfur remaining in the system, and explain in detail for each such transient the mechanism by which this activation is likely to occur.
II-1(2)-16.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(2)-15, and. explain in detail how each such fact supports your allegations.
II-1(2)-17.
Precisely what tube composition is
" appropriate" to " magnify" the effect of active forms of sulfur to such an extent that an inventory of 0.1 ppm sulfate in solution would have a significant corrosive effect?
II-1(2)-18.
State in detail each and every fact upon which you base the allegations in your answer to Interrogatory II-1(2)-17, and explain in detail how each such fact supports your allegations.
II-1(2)-19.
In light of the actual environmental conditions attendant to reactor operation, what synergists and/or synergistic effects are likely to cause IGSCC in the TMI-l OTSG?
II-1(2)-20.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(2)-19, and explain in detail how each such fact supports your allegation.
II-1(2)-21.
Identify each and every document which you claim supports each fact set forth in your answers to O
Interrogatories II-1(2)-1 through II-1(2)-20, and correlate each such document as specifically as possible (page and para-graph number) with each such fact.
II-1(2)-22.
Do you allege that a " suitable reducing agent is present (or will be present) in the TMI-1 OTSG that could generate active forms of sulfur from the 0.1 ppm sulfate and thereby create a significant corrosive effect"?
II-1(2)-23.
If your answer to Interrogatory II-1(2)-22 is other than an unqualified "no",
state in detail each and every fact upon which you base this allegation, and explain how each such fact supports the allegation.
II-1(2)-24.
Do you allege that the mere " presence" of sulfur or any other potentially corrosive contaminant at any concentration, however small, raises significant safety concerns which undermine the integrity of the repaired tubes under the environmental conditions attendant to operation?
II-1(2)-25.
If your answer to Interrogatory 1(2)-24 is other than an unqualified "no" with respect to any potentially corrosive contaminant, identify the contaminant, state in de-tail each and every fact upon which you base ycur allegations, and explain in detail how each such fact supports the allega-tions.
l II-1(2)-26.
If your answer to Interrogatory II-1(2)-24 is other than an unqualified "yes" with respect to any potentially corrosive contaminant, specify-in detail the concentration of the contaminant which you allege poses a significant risk of IGSCC.
I i
C II-1(2)-27.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(2)-26, and explain in detail how each such fact supports the allegations.
II-1(2)-28.
Identify each technical specification you allege may be " inappropriate" and specify in detail the manner in which each such technical specification may be "inappropri-ate".
II-1(2)-29.
State in detail each and every fact upon whichtyou base the allegations in your answer to Interrogatory II-1(2)-28, and explain in detail how each such fact supports your allegaticns.
II-1(2)-30.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories II-1(2)-22 through II-1(2)-29, and correlate each such document as specifically as possible (page and para-graph number) with each such fact.
II-1(2)-31.
Identify each person you propose to call as a witness in support of Contention 1(2).
II-1(2)-32.
Identify all documents, including relevant page citations, which you intend to offer as exhibits during I
this proceeding to support Contention 1(2).
II-1(2)-33.
Identify all documents, including all rele-vant page citations, which you intend to use during your cross examination of witnesses presented by Licensee or the NRC Staff on Contention 1(2)..
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~ Interrogatories on Contention 1(3)
II-1(3)-1.
In terms of the conditions attendant to operation of the OTSG, explain the mechanism by which you allege _that. islands of IGA.can propagate into IGSCC.
II-1(3)-2.
State in detail each and every fact upon which you base the allegations stated in your answer to Interrogatory
' II-1(3)-1, and explain in detail how each such fact supports your allegation.
II-1(3)-3.
Do you allege that an inventory of the 0.1 ppm sulfate in solution will or could cause existing islands of IGA to propagate into IGSCC?
4 II-1(3)-4.
If the answer to Interrogatory II-1(3)-3 is other than an unqual'ified "no",
state in detail each and every fact upon which you base this allegation, and explain in detail how each such fact, supports your allegations.
II-1(3)-5.
Do you allege that any of the other potential corrosive contaminants, synergists or synergistic effects iden-tified in your answers to Interrogatories II-1(2)-1 and II-1(2)-29 above will or could cause existing islands of IGA to propagate into IGSCC?
'II-1(3)-6.
If the answer to Interrogatory II-1(3)-5 is other than an unqualified "no",
identify each potential corrodant, synergist or synergistic effect which could cause existing islands of IGA to propagate into IGSCC and with respect to each, specify:......
A (a) the concentration of.the chemical which must be present to cause islands of IGA to propagate into IGSCC; and (b) whether you allege that the chemical is present in the TMI-1 OTSG at that concentration.
'II-1(3)-7.
State in detail each and every fact upon which you base your allegations in your response to Interrogatory II-1(3)-6, and explain in detail how each such fact supports your allegations.
II-1(3)-8.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories II-1(3)-1 through II-1(3)-7 above, and corre-late each such document as specifically as possible (page and paragraph number) with each such fact.
II-1(3)-9.
Identify each person you propose to call as a witness in support of Contention 1(3).
II-1(3)-10..
Identify all documents, including relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 1(3).
II-1(3)-11.
Identify all documents, including all rele-
'vant page citations, which you intend to use during your cross examination of witnesses presented by Licensee or the NRC Staff 2
on Contention 1(3).
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D.
Interrogatories on Contention 1(S)
II-1(5)-1.
Identify each and every " active form of carbon" which you allege could have caused or significantly contributed to the IGSCC which occurred in the TMI-l OTSG.
II-1(5)-2.
State in datail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(5)-1, and explain in detail how each such fact supports your allegations.
II-1(5)-3.
Define what you mean by " low valance carbon ions", and explain its relationship to the " carbonaceous
. material" discussed in the Third Party Review May 16, 1983 f
supplement at p. 3.
II-1(5)-4.
Do you allege that low valance carbon ions, or other " carbonaceous material" as defined in your answer to In-terrogatory II-1(5)-2, are present in the TMI-1 OTSG?
II-1(5)-5.
If your answer to Interrogatory II-1(5)-4 is other than an unqualified "no",
specify with precision the lo-cation and quantity of low valence carbon ions or other carbonaceous material present in the TMI-1 OTSG.
II-1(5)-6.
State in detail each and every fact upon which you base the allegations stated in your answer to Interrogatory II-1(5)-5, and explain in detail how each such fact supports the allegations.
II-1(5)-7.
Identify each and every synergist and/or synergistic effect which you allege could act in concert with the low valance carbon ions or other carbonaceous material allegedly present in the TMI-1 OTSG to cause IGSCC..
e II-1(5)-8.
State'in detail each and every fact upon which you base the allegations stated in your answer to Interrogatory II-1(5)-7, and explain in detail how each such fact supports your allegations.
II-1(5)-9.
With respect to each synergist and/or synergistic effect identified in your answer to Interrogatory II-1(5)-7, specify and explain:
(a) the concentration of the low valance carbon ions (or other carbonaceous material) and the synergist which must be present to cause or significantly contribute to IGSCC; (b) the operating conditions necessary for propaga-tion of IGSCC due to the corabined effect of the low valence carbon ions (or other carbonaceous material) and the synergist and/or. synergistic effect; and (c) the mechanism whereby IGSCC is propagated as a result of the combined effect of the low valence carbon ions (or other carbonaceous material) and the synergist and/or synergistic effect.
II-1(5)-10.
State in detail each and every fact upon which you base your allegations in your answer to Interrogatory II-1(5)-9, and explain in detail how each such fact supports your allegations.
II-1(5)-11.
Identify each and every " oxidation and reduc-tion processes" which you allege would in fact, not merely in theory, be subject to the effect of a synergist under the envi-ronmental conditions attendant to reactor operation of the TMI-l OTSG.
2 II-1(5)-12.
For each reactor oxidation and reduction processes identified in your answer to Interrogatory II-1(5)-11,
.(a)
Identify each and every-synergist which is like-ly to have an effect on the oxidation or reduction processes, and/er the synergistic effect which is likely to occur during reactor operation; (b)
Identify the source and quantity of the synergist or synergistic effect; and (c)
Explain the mechanism by which IGSCC is likely to result from the presence of the synergist and/or synergistic effect.
II-1(5)-13.
State in detail each and every fact upon which you base the allegations in your answer to Interrogatory II-1(5)-12 above, and explain in detail how each such fact supports your allegations.
II-1(5)-17.
Describe the expert qualifications of Dr. R.
H. Hansen.
II-1(5)-18.
Explain in detail the " extensive work in the l
development of synergistic antioxidant systems at Bell Tele-phone Laboratories" and how that work supports Contention 1(5).
II-1(5)-19.
Did the work described in your answer to In-terrogatory II-1(5)-18 demonstrate that any of the substances 1
there present, which are also present in the TMI-1 OTSG, have synergistic effects?
If ycur answer is other than an unquali-fied "no",
specify, i
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(a) the identity of eacn such substance; (b) the extent of the synergistic effect; (c) whether, as a result of the synergistic effects discerned, the substance was found to cause or significantly contribute to IGSCC, or a comparable corrosive phenomenon, at the concentrations identified; and (d) the concentration of the substances involved in the synergistic effect.
II-1(5)-20.
State in detail each and every fact upon which you base the allegations stated in your answer to Interrogatories II-1(5)-18 and II-1(5)-19, and explain in de-tail how each and every fact supports your allegations.
II-1(5)-21.
Identify and provide qualifications, mono-graphs, and all other documents authored by Dr.
Hansen with respect to the work described in your answer to Interrogatories II-1(5)-18 through II-1(5)-20.
II-1(5)-22.
Identify each person you propose to call as a witness in support of Contention 1(5).
II-1(5)-23.
Identify all documents, including relevant page citations, which you intend to offer as exhibits during this proceeding to support Contention 1(5).
II-1(5)-24.
Identify all documents, including all rele-vant page citations, which you intend to use during your cross examination of witnesses presented by Licensee or the NRC Staff on Contention 1(5).
Dated:
January 24, 1984.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE F
BY:
GETrfge W 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 i
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o 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 Second Set of Interrogatories to Joint Intervenors" and " Licensee's Motion for Leave to File Second Set of Interrogatories Out of Time" were served this 24th day of January, 1984, by deposit in the U.S.
mail, first class, postage prepaid to those on the atta-ched Service List.
r
'k.
Bruce ~W.
Churchill, P.C.
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v' e-i 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 d
Sheldon J. Wolfe Atomic Safety and Licensing Administrative Judge Board Panel Chairman, Atomic Safety and U.S. Nuclear Regulatory Commission Licensing Board W a s h i n g t o n, 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 Ilt. 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 i
Washington, D.C.
20555 s
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