ML20087P506

Interrogatories Based on Welder Info Recently Received & Request for Production of Documents.Certificate of Svc Encl. Related Correspondence

ML20087P506
Person / Time
Site:	Harris
Issue date:	04/03/1984
From:	Eddleman W EDDLEMAN, W.
To:	CAROLINA POWER & LIGHT CO.
References
82-468-01-OL, 82-468-1-OL, 82-468-OL, OL, NUDOCS 8404090109
Download: ML20087P506 (4)

Text

' d'7b* .

~

Itl4tl

• _ ) .' c,3 bO (k I DOCKETED UNITED STATES OF AMERICA USNRc April 3, 19814 NUCLEAR REGULATORY COMMISSION N FR -6 P3 3 F,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD *,0CE M GAOF .itcar a SEPe Glenn O. Bright **

Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of CAB 0 LINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Unita 1 ani 2) ) ASLBP Mo. 82-1468-01

) OL Wells Eddleman's Interrogatories Based on Welder Info recently received (not based on talks w/ welders)

Attorney Baxter for Anolicants has a typo (or nistake) in a recent letter re the date of this. The 3d was anrroved. In a separate Motion, I argue for extension of time re information I may receive from the welders Applicants have finally identified aftern nearly a year's discovery dispute.

11-X-1(a) 4 For each Welder in Appendix 3, please state (1) the type of welding exnerience(s), e.g. , shop welder, pine welder, construction welder, each has had, for how many years (ii) each enployer with whom that welder had experience (iii) whether Danniel, CP&L or anyone elen checked with .. (aa) any (hb) ,each (ce) a previous encloyer re that welder's exnerience, snecifying who contacted which previous enployer, naming each nrevious ennloyer and which person, entity ofr organization was involved in naking the contact re experience. (iv) the weldning techniques (oxyacetylene, stick or arc, FiIG, TIG, etc)'each such welder had exnerience in

-(v) all welding positions each such welder qualified in w/each nrevious employer (if known) (vi) any problens the welder had 8404090109 e40403

. PDR 0

ADOCK 05000400 PDR

_g. .

with nny previout emnloyor or on any pr3vious job, which you are aware of, includins discipline or discharge for bad or defective welding or for any other cause (specify ) (e.g. drug use, absenteeism, alcoholism, theft, conflict w/ supervisor or other enployee(s ), etc )

(vii) all job training or other welding training received while with previous employer (s) (viii) all nerformance evaluations, transcripte or reports fron welder training, etc for present and past encloyment, identifying all documents in your or Daniel's nossession containing such information (ix) all disciolinary action taken against each such employee at Harric (x) reason for each (aa) discharge- give date

-(bb) layoff (give date) (cc) other ternination of work, e.g. voluntary quitting of job -- give reason and date. Please state all reason (s) you know and identify all documents concerning each discharge, ,

layoff, or other separation from work at Harris, for each such p erson.

(xi) identification of all documents concerning the encloyee 's work record at Harris including discinline, job nerformance evaluations, any grievances filed by or against the welder, and any evaluation of performance in welding pipe hangers. (xii) wnich of xthese welders received retraining in nine hanger welding or in we1xding or in blue-nrint reading (specify which) while at Harris, giving in detail the description, curriculun or outline of the training received, and stating any evaluation of that welder's performance in that training,

.and identifying all docunents concerning retraining or twairfng in the above-listed matters for each such welder (xiii) all training such welder had nreviously received in blueprint reading nrior to work at Harris, and all docunents' i'dontification for documents concerning such training-(xiv) all training in blueprint reading received after beginning work at Harris, including the date(s), curriculun and reason (s) for this training and all documents related to it or to t he welder's particination in it, narticularly any evaluations of said welder's performance in such training. (xv) any records on defective nine hanger L

wolds made by each such welder tan and the identification of any docunents known to you which link each such welder with defective pipe hun 6ers (xvi) identification of all documents concerning each such welder's assignnent (aa) to (bb) away fron,' pipe hanger welding at Harris (xvii) any notes or docunents whaxtsoevor concerning this

, welder's pipe hanger welding nerformance, which you possess, niease identify all such documents not already identified in veanonse to identification of, and identificat'on of all documents re the above (xviii)jany renorts of defective nine hangers made by such welder at any time (xix) any docunents re instruction in or faniliarization with QA/QC procedure which were given to such welder or mused in instructing or informing such welder; identify all such documents for each such welder (xx) any documents re any statenehts made or infornation given by (aa) C?&L (bb) Daniel (cc) anyone else known to you, to this welder, re (dd) defective nine hanger welding at Harris (es) blueprint reading nroblens in nine hanger welding at Harris (ff) renorting, or not renorting, viointions of NRC regulations re welding or pipe hangers (gg) reporting, or not renorting, violations of QA or QC or other anplicable procedures re Harris nipe hangers or any such hanger (s) (hh) renorting, or not renorting, defective weldsms on Harris pine hangers or any such hanger (jj) nrocedure for venairing defective pipe hangers or defective welds thereon (kk) procedure to follow when bluenrint symbols for a pipe hanger are not clear to the welder (11) procedure for weldinF nipe hangers at Harris (mn) speed or piecework requirements for welding pipe hangers at Harris (nn) pay rates or incentives re welding pipe hangers at Harris (oo) other information, procedures or plans, formal or informal, identifyin_g each x such, which relate to nine hangers at Harris or inspection thereof, i

41-X-1(b) For each welder in Appendix A, please nrovide or

! provide conies of as unuch of the above-requested information or i documents showing it, as is readily available. Please identify all  !

_4 documente contain'ng such information.

(c)Please specifically identify all reasons for each (1) termination (ii) discharge (iii) layoff (iv) other leaving of a pipe hanger welding job at Harris, for each welder listed in Anpendix A.

(d) Please specify all deonnunico.tions CF&L or Daniel has made with any welder identified in Appendix A, c oncerning (1) contention 41 (ii) the Harris OL nroceeding (iii) the velease of her/his name to Wells Eddlenan (iv) rights or resnonsibilities to report defects to NRC ( Av) connunication by the welder with Wells Eddleman and/or anyone 1 working for or with hin (vi) communication with nuclear intervenors or anti-nuclear activists (vii$ revealing or not revealing information concerning pine hanger welde and/or defects therein at Harris. Please identify all documents which concern any of the above natters or which contain information re any comnuni-cation inquired about above.

(e) R For each welder listed in Appendix A, please a state that welder's last known home telephone number.

(f) Please suecify the instruction (s), if any, re (i) uine hanger welding procedures (ii) blueprint reading for pipe hanger work (iii) blueprint reading generally (iv) defective welds (v) renorting of defects at Harris to QA/QC (vi) reporting of defects at Har=is to in NRC (vii) connunicating re defects at Harris in nine hangers to anyone other than CP&L, Danici or NRC personnel (viii) not telling info about problens at Harris, esp. re nine hangers, which (aa) any (bb) all (cc) any snecific known welder or welders listed in Annendix A has received since beginring work at Harric, at any time, to your knowledge. Please identify the source of each such instruction (s) and identify all documents concerning eadh, including all notices put on display at Harris, and all internal iconmunications or docunents for communication to welders and/or other ennloyees, re each such natter.

5-(g) Please state which, if any, welders listed in Anpendix A have been disciplined for (1)-drug or alcohol problens (ii) making defective pipe hangers (iii) making udefective pine hanger welds at Harris. Please also identify all welders counseled or helped in any way re any of (1) thru (iii) above, specifying which and when.

Please identify all x documents concerning each inexident or instance of (as) discioline (bb) counseling (cc) help, and/or the nature of such discipline, counseling or help, for each welder.

(h) Please state which of these welders identified in Annendix A (i) is now welding (ii) is now available to weld, pipe hangers at Harris.

(j) Please identify all new hires in Craft 66 pinefitters etc to date,

_ (under the provisions of the Board's oral protective order of March 8 '8h I will hold these names in the same confidence, i.e. as subject to that ordsr) who are not listed in A>pendix A. Please state which of then have welded pipe hangers or are to weld on then. Please answer all s

of the above interrogatories where possible, for eachz nuch welder.

(k) Please state what, if any, QA or QC experience (snecify what experience, when, with what organization (s)), any welder identified in Appendix A or in renconse to the aboe.., has had, to your knowledge, and identify all docunents you nessess concerning such experience or the training in QA or QC such welder has received.

PRODUCTION OF DOCUMENTS Please nake all documents identi!!ed in resronse to the above available to Wells Eddlenan for insnection and/or conying at a mutually agreeable time a and pie ce. Please identify those you believe may contain confidential informstion under the Board's orotective order of March 8,1984

/

A+4/v Wells Eddleman

UNITED STATES OF AMERICA NUCLEkR REGULATORY COMMISSION In the matter of CAROLIKA POWER k LIGHT CO. Et al. ) Docket 50-1400 Shearon Harris Nuclear Power Plant. Units 1 and 2 ) 0.L.

CERTIFICATEOF SERVICE WEE 41 welder info interrogatories; I hereby certify that copies of W.E. Motion #n= whenN c_* Ti z ;

wee. Partial 9esponse and Contentions re Emergence Plan (nrrn<te) i HAVE been served this 3 day of April 198J,bydepositin the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with ,

an asterisk, for whom service was accomplished by i JudEes Jates Kelley, Glenn Bright and James Carpenter (1 e gy each) l Atomic Safety and Licensing Board i US Nuclear Megulatory Commission l Washington DC 20555 George F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge R uthanne G. Miller 1800 M St. NW ASLB Panel l Washington, DC 20036 USNRC Washington DC 2055 5 1

Office of the Executive Legal Director Phyllis Lotchin, Ph.D.

Attn Dockets 50-400/401 0.L. 105 '.ridle Run

, USNRC Cheael Hill NC 2751h

! Washington DC 20555 Dan Read Docketing and Service Section (3x) CEA!E /FLP Attn Docke ts 50-h00/h01 0.L. Raleigh,7707 NC Waveross Office of the Secretary h7606 a 20555

. nda W. Wie neton DC Governor's Waste Mgt. Bd.

513. Albemarle B1dg J hn Runkle '

325 N. salisbu n St.

Granville Rd I"'@8 1 Chapel Hill Me 2751b. Bradley W. Jones Robert Gruber USNRC Region II

'Travi s Payne Exec. Director 101 Marietta St.

Edelstein & Payne Public Staff Atlanta GA 30303 Blex 12601 Box 991 Raleigh NC 27605 Raleigh NC 27602 Richard Wilson, M.D. Certified by w 729 Hunter St.

Apex NC 27502

. -, . . _ _ _ . .