ML20113H967

Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20113H967
Person / Time
Site:	Hope Creek
Issue date:	01/18/1985
From:	Remis S, Shapiro R, Thurber J NEW JERSEY, STATE OF
To:	Public Service Enterprise Group
Shared Package
ML20113H929	List: ML20113H927 ML20113H944 ML20113H967
References
OL, NUDOCS 8501250383
Download: ML20113H967 (27)

Text

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WTEL LogRESDONN

. v.CCD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION,],

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.n.g Before the Atomic Safety and Licensing Board -

In the Matter of )

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Public Service Electric and ) Docket No. 50-354  :

Gas Company, et g. )

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'(Hope Creek Generating )

Station) ) .

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INTERVENOR'S RXHm! SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO APPLICANTS 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 Special Praharing Conference Order (December 21, 1983) and Order of December 24, 1984, the Public Advocate of the State of New Jersey (" Inter-venor" or "Public Advocate") hereby propou'nds the following interrogatories l to Public Service Electric and Gas Company, f.t M. (" Applicants") to be answered fully in writing, under oath, in accordance with the definitions and instructions below. -

AddiHan=11y, pursuant to 10 C.F.R. 62.741, the Public Advocate requests that Applicants produce for inspection and copying (or provide copies of) .

those documents designated by applicants in their respective answers below

.' and those requested by Intervenor in his request for production of documents.

These interrogatories and request for production of documents are in four parts as follows: I , Pipe Crscks Interrogatories; II - Pipe Cracks Request for Documents; III - Management Competence Interrogatories; and IV - Management ,

Competence Request for Documents. ergi % 3 $ 0 0 ,

e Definitions and Instructions

1. For each interrogatory, please state the full name, business address, and title or position of each person providing infonnation for the answer to the interrogatory.

2. The following definitions shall apply:

a. "Intervenor" shall refer to the Public Advocate of the State of New Jersey,

b. " Document" or " writing" 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 applicants, or its officials, employees, or agents; it shall also mean all copies or drafts of docu-ments by whatsoever means made.

c. "Date" shall mean the exact day, month, and year, if ascertainable, or, if not ascertainable, the best approxi-

. mation (including the event's relationship to other events in the relevant context of the interrogato:7).

'd . "NRC" or " Commission" shall mean either the Atende Energy Commission or the Nuclear Regulatory Commission, as appropriate, including its regulatory staff and adjudicat'ory

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boards, as indicated b'y the context of the interrogatory.

e. "Specify", " identify", " list", and " describe", when referring  !

to an action, decision, step, document, meeting or visit,  ;

means that the answer shall set forth all. relevant dates and

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1 the names and titles of all individuals involved. 1 r  !

. 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 business address, .

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and, if a corporation or other entity, its principle place of  ;

business or, if. an individual, his or her title or titles and i

employer. Once an individual, corporation, or other entity has been 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. l

g. " Basis" shall mean any document (as defined in 2(b) above),

analysis, study, reference, or source upon which intervenor l relies for any assertion in the contentions or which will be

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referred to or used in cross-examination of Applicants' witnesses.

. h. " Applicants," "P.S.E.&G. ," "You" or "Your" shall refer to l Public Service Electric & Gas Company, et d., applicants in this proceeding, or any official, employee, contractor, sub-contractor or consultant thereof. .

3. These interrogatories request all knowledge and information in j applicants' possession and/or knowledge and information in the possession of applicants' agents, representatives, consultants, and, unless privDeged, attorneys. .

4. In your answer, repeat each interrogatory set forth herein and then i set forth an answer thereto separately and fully. As to any interrogatory.

- section or subsection of said interrogatory that you refuse to answer or

!* which is objected to for any reasons, separately state the grounds for

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any such refusal. Where a complete answer to a parti:ular interrogatory, section or subsection of said interrogatory is not possible, such interrogatory, section or subsection of said interrogatory should be answered to the extent .

possible and a statement made indicating the reason for the partial answer.

5. Identify any documents used as the basis for the answer to each interrogatory.

6. If the answer to any interrogatory is based upon a calculation, describe (a) the calculation, (b) identify any documents setting forth such calculation, (c) identify the person who performed each calculation, (d) whhn it was performed, (e) each parameter used in such calculation, each value assigned to the parameters, and the source of your data, (f) the results of each calculation, and (g) how each calculation provides a basis for the answers.

7. If the answer to any interrogatory is based upon conversations, consultations, correspondence or any other type of communications with one or more individuals (a) identify each such individual by name.and address, (b) state the , educational and professional background of each such indivi-dual, (c) describe the information received from such individual and its relation to your direct answer, (d) identify each writing or record related to each such conversation, consultation, correspondence or other communi-cation with such individual.

8. In accordance with 10 C.F.R. 52.740(e) and the Licensing Board's Order of December 21, 1983, these interrogatories are continuing in nature and require prompt supplemental answers should applicants obtain or identify supplemental information or documents. ,

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.I. Pipe Cracks-Interrogatories

,. 1. List each meeting any of your employees or the employees of any of your contractors or subcontractors has attended that related to Intergranular Stress Corrosion Cracking (IGSCC). For each such meeting, identify (a) the date of the meeting; (b) the individuals in attendance; (c) the purpose of the meeting; and

' (d) all documents prepared for the meeting or created as a result.

2. Identify and describe all operating conditions that you considered in designing the neans and techniques to mitigate IGSCC in the recirculation piping at Hope Creek.

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3. . Describe the chemical and physical parameters in the primary

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system at Hope Creek that'are designed to achieve control of IGSCC.

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4. Describe the use of water chemistry control or any plans for such use as acountermeasure or means to mitigate intergranular stress corrosion cracking at other boiling water reactors both in the United States and the remainder of the world, including for each facility:

a. Facility name;

b. Location;

c. When constructed;

d. Comparison of recirculation system piping configuration and material to that at Hope Creek;

e. Critical water chemistry parameters which were sought to be controlled;

f. Whether the use was experimental;

g. Description of means and levels of chemical addition and measurement, including accuracy of instrumentation and levels of critical water chemistry and physical parameters actually measured;

h. Date when such use of water chemistry control began;

i. Length of time utilized to date and planned length of use or experiment;

j. Any reported operating problems with system;

k. Any reported detrimental effects on the facility or its -

operation;..

1. Conclusions-whether preliminary or.not, regarding evaluation

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of the water chemistry control and basis therefor;

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m. Means utilized to determine impact on IGSCC:

n. Describe all nondestructive and destructive testing conducted since use of water chemistry control began and any results of such testing;

o. Identify and describe any reports or documents discussing use or projected use in that facility.

5. If you are aware of any boiling water reactors that have decided not to utilize water chemistry control as a means to counter

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or mitigate IGSCC, identify the facility and describe the reasons why such decision was made. Identify any documents associated with or discussing such decision.

6. L'ist and identify all recirculation piping at Hope Creek by heat number. For each such piece of recirculation piping, also state its length.

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7. Identify all recirculation piping at Hope Creek in which there have been linear indications.

8. Identify and describe all nonformance reports (NCRs) inv61ving recirculation piping at Hope Creek. Describe all corrective measures taken as a result of each such NRC.

9. Identify each instance in which the x-rays or other testing of welds on recirculation piping at Hope Creek revealed a deficiency.

For each such instance, describe all corrective measures taken, and identify all related documents.

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, 10. Identify each occasion in which Quality Control Inspection Reports (QCIRs) involving recirculation piping have been back-dated or " rebuilt." Identify all personnel alleged to have been involved in such practices.

11. List the qualifications and experience of each of the following personnel involved with recirculation piping at Hope Creek:

a. James MacIntire

b. Robert Legg

c. Michael Sullivan

d. William Lamb

e. David Janson

12. Identify and describe all steps ybu have taken to minimize '

poor outer surface finish and excessive weld crown contour so as to reduce the effectiveness of ultrasonic testing (UT) examination on recirculation piping at Hope Creek.

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13. -Identify and describe all steps you have taken in planning for UT examinations of recirculation piping at Hope Creek to minimize operator exposure to radiation. Identify and describe all documents pertaining to your consideration of health physics as it relates to IGSCC at Hope Creek.

14. State whether you assert that the requirements contained in NUREG-0313 and 0313 rev. 1 are sufficient to prevent IGSCC at Hope Creek. Explain the basis for your conclusion.

15. State whether you have considered using SWRI's FLAWSORT or any other computer program to interpret UT waveforms at Hope Creek. If so, state the result of this ccasideration.

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16. State whether you have considered using the Synthetic Aperture Focusing Technique (SAET) devalW under NRC sponsorship at the University of Michigan or any other system to perfonn imaging in Ur inspections at Hope Creek. If so, state the results of this m=idantion.

17. Describe the =4*- # pat +imlate rMihvity nonitoring system for leak detection of Hope Creek.

18. State whether you will utiliva an air cooler condensate flow rr_te nonitoring system for leak detection at Hope Creek. If so, da M ha this system.

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19. State whether you will utiliva an airknrne gam activity nonitoring system for leak detection at Hope Creek. If so, MM this systan.

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20. State whether indicators and =1== for leak detection will be provided in the main vcniL.v1 rocza at Hope Creek. If not, a y1=in why the decision was made not to place than in the main control roczn, as suggested by the American National S Institute (ANI ), and identify where such indi-cators and alarms will be located.

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21. State whether high *meature pia 9^ alar tric acceleraneters will be utilized for leak detection at Hope Creek. If so, describe the system to be so utilized.

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State whether you have deramired to participate in the Pooled Inventory

) W (PIM) progran presently being i T e==+M l by G.E. If so, 4 W _ba all plans and s ucx=iures for utilivi g this ps- @ =u in the event that Hope Creek ss304 piping hal to be replaced after Opw.at. ion due to IGSOC.

23. State whether you are a partir'ipant in the BWR Owners Group Renedy Develop-ment Center estah14 =hd at charintte, North Carolina.- If so, describe all plans, guvadures, methods and tools that have been or .are being deva 1W at this fUlity that may be utili'M in~the event timt Hope Creek SS304

. piping had to be replanarl after cpecai. ion due' to IGSOC.

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a II. Pipe Cracks Request for Documents 24.

Provide copies of all documents relating to your answer (s) to the interrogatories listed above or upon which you otherwise intend to rely in the presentation of your direct case or in the exmination of other witnesser III. Managenent Ccametence Ir*amatories 25.

na_W M in detail each anticipated and actual effect of PSE & G's decision in July of 1981 to " provide more centra 14mi management and control for the operation, maintenance and servicing of its nuclear plants at Art 4f4mial Island," as referred to in Interrogatory 40 of Applicant's Second Set of In&--

_-ptories. WM each alternatia that was considered in reaching this daci=4on and explain why each was rejected. Identify all per =.1 involved in this decision.

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26. Describe in detail each anticipated and actual effect of PSE&G's decision, resulting from its in-depth analysis of the position of Vice President-Nuclear initiated in September of 1983, to create two additional management positions -- Assistant Vice President-Nuclear Operations and Support and Assistant Vice President-Nuclear Operations -- as referred to in Interrogatory 42 of Applicants' Second Set of Interrogatories. Identify and describe all other actions and options that were considered as part of this in-depth analysis and explain why each was either adopted or rejected. Identify all personnel involved in this decision.

27. Describe in detail each anticipated and actual effect of PSE&G's decision that the General Managers of Quality Assurance and Nuclear Safety Review will continue to report directly to the Vice President-Nuclear, as referred to in Interrogatory 43 of Applicants' Second Set of Interrogatories. Describe each alterna-tive ~ considered in reaching .this decision and explain why and how i each was rejected. Identify all personnel involved in this deci-sion.

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28. Describe in detail each anticipated and actual effect of PSE&G's decision to employ a " senior management team" approach

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. in its Nuclear Departments as referred to in Interrogatory 44 of Applicants' Second Set of Interrogatories. Describe all nuclear plant operator utilities that employ or have employed this approach and describe their experience with it. Describe each alternative approach considered and explain how and why it was rejected. Describe the reasons why this approach was chosen for the Nuclear Department.

29. Describe in detail each anticipated and actual effect~

'of PSE&G's decision in July of 1983 to establish the Hope Creek Transition Management Steering Committee, as referred to in Interrogatory 48 of Applicants' Second Set of Interrogatories.

Describe the rearms why this decision was nade. Describe each alternative considered and explain how and why it was rejected.

Identify each nuclear plants that has employed a simil'ar committee for its transition management and describe their experience with such committees.

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30. List and identify each occasion since January 1, 1982 on which PSE&G has used on-the-spot changes for procedures where the, intent of the procedure is thereby changed. For each such occasion, state whether prior SORC review was required.

31. List and identify all steps you have taken or presently intend to take in response to the NRC's observation in its 1984 Salem SALP that "[s] tation procedures, in general, do not reference commitments, license conditions, technical specifications, etc.

Therefore, procedure changes require a thorough review .to determine if deletions will result in any violations or deviations from commitments."

32. , List and identify each instance in which the Hope Creek station procedures will not reference " commitments, license condi-tions, technical specifications, etc." as referred to by the NRC in its 19,84 Salem SALP. -

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. 33. List and identify all steps you have taken or presently intend to take in the future in response to the NRC's conclusion in the 1984 Salem SALP that "[a]ggressive management attention is

'necessary to correct the longstanding degradation of fire barriers l and the complacent attitude which accompanies it."

34. List and identify all steps you have taken or presently intend to take in the future in response to the NRC's observation in the 1984 Salem SALP that "PSE&G has not fully implemented a sound safety oriented operating attitude."

35. List and identify all steps you have taken or presently intend to take in the future in response to the NRC's observation in the 1984 Salem SALP that "[t]he licensee has not demonstreated a firm commitment to ensure that deadlines are met and the desired results achieved." -

36. List and identify all steps you have taken or presently

- intend to take in the future in response to the NRC's observation in the 1984 Salem SALP that "[i]t would appear that questions posed by the NRC are sometime the sole stimuli for the licensee to seek further information*and to perform more in-depth caused analyses of events, possibly indicative of a weak process of self-evaulation."

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37. Identify and describe all steps taken by PSE&G in re-sponse to the observation by the NOC in its minutes dated July 31, 1984, that " portions of management do not appear to the NOC to be fully informed or sufficiently responsive to the tough choices required to achieve a premier position in plant safety."

38. For each of the years 1982, 1983, and 1984, provide the follosing statistics:

(a) the number of interviews conducted to recruit and hire new personnel for the Nuclear Department; (b) the number of offers extended by PSE&G to hire new personnel for the Nuclear Department; and

, (c) the offer acceptance rate for offers extended by the Nuclear Department.

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39. Identify and describe all of the work required for each .

.. item of the Action Plan after each such item has been " closed out."

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40. State whether you have determined to implement the NOC's 1

recommendation contained in its minutes dated July 31, 1984, that

" Nuclear Safety Assurance be a separate line function headed by a senior manager who reports directly to the Vice President -

Nucle ar. " If so, identify when this change was or will be imple-mented. If not, state why not.

41. State whether you.have agreed to implement the NOC's recommendation contained in its July 31, 1984, minutes that

" Quality Assurance . . . be placed under a manager who . . .

reports [directly) to the Vice President - Nuclear." If so, identify when this change was or will be implemented. If not, state why not.

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42. -State whether you agree with the NOC's statement in its minutes dated October 22, 1984, that "the primary need is for a

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safety. review group reporting at a higher level (than Vice

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President - Nuclear) and consisting mainly of outside members."

If not, explain why not.

43. State whether you have determined to implement the NOC's

" proposed arrangement" as identified in its minutes dated October 22, 1984, of a Nuclear Safety Advisory Board reporting to the Vice President'- Nuclear; a Nuclear Safety Assurance Group re-porting to the Senior Vice President, and the NOC composed of outside members reporting to senior management and/or the PSE&G Board of Directorc. If so, identify when this arrangement was or will be implemented. If not, state why not.

44. State whether you have determined to implement the NOC's recommendation contained in its minutes' dated October 22, 1984, .that " upper management involvement and. drive .[in post trip

. reviews] be more visible in encouraging the identification of root causer, and the implementation of corrective action . . . . If so, identify and describe all steps that you have taken or pre-sently intend to take in the future to implement this recommendation.

If not,. state why not. ,

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45. In the June 4, 1984 Hope Creek Self Assessment Completion

'- Report, you " recognized that expertise in operational Quality Assurance matters may not be sufficient within the Engineering and Construction Quality Assurance organization at the preset time to adequately support the development, review and approval of the various Hope Creek Operations programs." Identify and describe all stepn you have taken and presently intend to take in the future to rectify this deficiency.

46. Identify. all instructors at the PSE&G Nuclear Training Center who have been on staff for a period of one year or more and

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who have not yet been certified.

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47. Identify each of the PSEEG Nuclear Training Center course or programs that hhve not received INPO accreditation.

48. Identify the dates the following Technical Supervisory Skills Programs '(TSSP) .were bnplemented: .

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a. TSSP-2 for all Hope Creek Senior Station Supervisors

b. TSSP-3 for all Hope Creek Senior Station Supervisors

c. TSSP-4 for all non-station, professional and technical

-support personnel J

49. Identify the percentage of all Hope Creek personnel requiring cold license certification that have not yet received such certification.

50. State whether you have developed an " integrated modular

[ fundamentals] training program" that is applicable for all disciplines, listed as a goal for 1984 in your Nuclear Training Center 1983 Annual Report.

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51. -Identify each individual from the Nuclear Department who kas n'ominated to participate in each cf the PSE&G sponsored Executive Development Programs in 1983 and 1984. . For .each individual, identify.each Executive Development Program he or she actually participated in and the dates of the Program.

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. 52. State whether the PSE&G management programs, practices and training described in your " Overview of PSE&G Technical Qualifications and Management Capability in Support of the Operation of Hope Creek Generating Station," dated July 1984 (Management Over-view Report) represent an on-going commitment by Applicants or simply describe current practices and standards. If they do not represent an on-going commitment, explain why not, and describe each way in which you presently foresee deviating from the practices and standards described therein. Also explain your objection to accepting these practices and standards as an on-going commitment. If these practices and standards do represent an on going commitment, explain your objection -- as voiced to the NRC staff -- to their inclusion in the FSAR or even a reference to the Management Overview Report in the-SER.

IV. Management Competence Request for Documents

53. Provide copies of the March 1, 8, 14 and 15, 1983 submittals discussing overall [PSE&G]'., management capability and performance" as referred to in the letter dated March 18, 1983 from R.A.Uderiz to R.W. Starostecki of the NRC l

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54. Provide copies of all letters, memoranda and other documents

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j relating to PSE&G's requ'st e that "a neighboring utility . . .

consider exchanging members on each other's review board" as referred i' to . in the letter referenced :b1 Document Request 46.

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55. Provide copies of all writing containing "[s]uggestions and recommendations from our NSSS vendor, based _upon their obser-vations and experience." as referred to in the letter referenced in Document Request 46.

56. Provide copies of all documents authored by or directed to kisling, Incorporated related to purchased order 905464 or the consulting services furnished thereby.

57. Provide copies of all documents authored by or directed to Operations Analysis Corporation related to purchase order 932759

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on the consu1 ting services furnished thereby.

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JOSEPH H. RODRIGUEZ Public Advocate of the State of New Jersey BY: .

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' RICHARD E. SHAPIRO BY: -

SUSAN C. REMIS 4

BY: A - - --

J HN'P. THURBER 9

DATED: January 18, 1985 a

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UNITED STATES OF AMERICA .,_

NUCLEAR REGULATORY COMMISSION 03 e 43 AiO:10 Before the Atomic Safety and Licensing Board m n.. . ..

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PUBLIC SERVICE ELECTRIC  :

AND GAS COMPANY

Docket No. 50-354-OL (Hope Creek Generating Station)

CERTIFICATE OF SERVICE I hereby certify that copies of"Intervenor's Fourth Set of . Inter-rogatories And Request For Production Of Documents To Applicants" and" Notice of Depositions" dated January 18, 1985, in the above-captioned matter have been served upon the following by deposit in the United States mail on this' 18th day of January,1985:

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• Marshall E. Miller, Esq. Atomic Safety and Licensing Chairman Appeal Panel

Atomic Safety and Licensing U. S. Nuclear Regulatory Board Panel Commission U. S. Nuclear Regulatory ~ Washington, DC ~ 20555

Commission East-West West Building Docketing and Service West Tower, Room 408 Section 4350 E.ast-West Highway Office of the Secretary Bethesda, Maryland 20814 U. S. Nuclear Regulatory

Commission j . *Dr. Peter A. Morris Washington, DC 20555 1 Atomic Safety and Licensing

l Board Panel ** Lee Scott .Dewey, Esq.

l U. S. Nuclear Regulatory Office of the Executive .

Commission Legal Director l East-West West Building U. S. Nuclear Regulatory West Tower, Room 408 Commission

. 4350 East-West Highway Washington, DC 20555 Bethesda, Maryland 20814

• ZAP Mail -

• • Express Mail

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• Dr. David R. Schink Atomic Safety and Licensing Board

, U. S. Nuclear Regulatory Commission East-West West Building West Tower, Room 408 4350 East-West Highway -

Bethesda, Maryland 20814

• • Dr. David R. Schink TexasA & M University Oceanography & Meteorology Building Room 716 College Station, Texas 77840

• Richard Fryling, Jr. , Esq.

Associate General Counsel Public Service Electric & Gas Company P. O. Box 570 (T5E)

Newark, NJ 07101

• Troy Conner, Jr. , Esq.

Conner & Wetterhahn 1747 Pennsylvania Ave. , N.W.

Suite 1050 Washington, DC 20006 Peter Hess, Esq.

Dept. of National Resources and Environmental Control Legal Office 89 Kings Highway Dover, DE 19901 Mr. Ken Koschek -

Planning Group -

. Department of Environmental Protection State of New Jersey .

CN-402 Trenton, NJ 08625

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flJa Edla/n RICliARD E. SHAPIRO ^

January 18, 1983

• ZAP Mall i

• • Express Mail

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