Interrogatories Based on Welder Info Recently Received & Request for Production of Documents.Certificate of Svc Encl. Related CorrespondenceML20087P506 |
Person / Time |
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Site: |
Harris ![Duke Energy icon.png](/w/images/7/75/Duke_Energy_icon.png) |
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Issue date: |
04/03/1984 |
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From: |
Eddleman W EDDLEMAN, W. |
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To: |
CAROLINA POWER & LIGHT CO. |
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References |
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82-468-01-OL, 82-468-1-OL, 82-468-OL, OL, NUDOCS 8404090109 |
Download: ML20087P506 (4) |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20140A9961986-01-22022 January 1986 Responds to Eighth Set of Interrogatories Propounded by W Eddleman Re Communication Deficiency in Harnett County,Nc. Ti Hawkins Affidavit Encl.Related Correspondence ML20138R0961985-12-22022 December 1985 Responses to Applicant 851125 Emergency Planning Interrogatories & Request for Production of Documents (Third Set).Related Correspondence ML20138R1141985-12-20020 December 1985 Response to Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20138R1061985-12-20020 December 1985 Response to General Interrogatories.Related Correspondence ML20137L9851985-11-26026 November 1985 Interrogatories to NRC & FEMA on Studies,Info & Knowledge Re Contentions on Which Discovery Now Open ML20137M0031985-11-26026 November 1985 Interrogatories to Applicant & State of Nc.Certificate of Svc Encl ML20137H6291985-11-25025 November 1985 Third Set of Interrogatories Re Emergency Planning & Request for Production of Certain Documents.Certificate of Svc Encl. Related Correspondence ML20138D2761985-10-18018 October 1985 Supplementary Response to General Interrogatories 2-3 & 12-14 Re Eddleman Contention 57-C-3 Concerning Nighttime Emergency Siren Sys at Facility.Certificate of Svc Encl. Related Correspondence ML20128P8311985-05-29029 May 1985 Correction of Answer to Applicant Discovery Requests Re Interrogatories on Contention WB-3 Concerning Drug Abuse. Certificate of Svc Encl.Related Correspondence ML20128P8001985-05-29029 May 1985 Response to NRC Interrogatories Re Contention WB-3 Concerning Drug Abuse.Related Correspondence ML20128G7151985-05-24024 May 1985 Answers to Discovery Requests Re Contention WB-3 on Drug Abuse.Applicants Have Not Reinspected safety-related Work of Known Drug Abusers ML20127M8941985-05-20020 May 1985 Answers to Conservation Council Discovery Requests Re Contention WB-3, Drug Abuse During Const. Util Employee Assistance Program Provides Aid in Drug Rehabilitation. W/Certificate of Svc.Related Correspondence ML20116L1731985-05-0101 May 1985 Interrogatories & Request for Production of Documents Re Allegations in Contention WB-3,per ASLB 850315 Memorandum & Order Ruling on Contentions Re Diesel Generators,Drug Use & Harassment.Certificate of Svc Encl.Related Correspondence ML20102C3621985-03-0101 March 1985 Responses to Interrogatories & Request for Production of Documents on Contention 41-G.C Van Vo Considered to Be Well Qualified in Experience & Educ for Job.Related Correspondence ML20107D0491985-02-19019 February 1985 Response to W Eddleman 12th Set of General Interrogatories to Applicant Re Contention 41-G.Related Correspondence ML20107D0591985-02-19019 February 1985 Response to W Eddleman Request for Production of Documents Re Contention 41-G.Certificate of Svc Encl.Related Correspondence ML20106D0951985-02-0808 February 1985 Applicant Request That W Eddleman Answer Interrogatories & Produce & Permit Insp of Documents Re Contention 41-G Concerning C Van Vo Allegations.Certificate of Svc Encl. Related Correspondence ML20102A2061985-02-0404 February 1985 General Interrogatories & Request for Production of Documents Re Employment of Cv Vo.Related Correspondence ML20102A0791985-02-0404 February 1985 Seventh Set of Interrogatories & Request for Production of Documents Re Eddleman Contentions.Related Correspondence ML20101E9021984-12-21021 December 1984 Response to W Eddleman Second Round Interrogatories on 213-A to Applicant/Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100G5971984-12-0303 December 1984 Second Round Interrogatories on 213-A to Applicants/ Emergency Response Personnel & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20100A5001984-11-30030 November 1984 Response to 841005 Discovery on Contention EPJ-3 (Volunteer Workers).Certificate of Svc Encl.Related Correspondence ML20099K4271984-11-26026 November 1984 Applicant Supplemental Responses to W Eddleman General Interrogatories to Applicant 11th Set.Certificate of Svc Encl.Related Correspondence ML20099D3771984-11-0909 November 1984 Response to Applicant 841005 Emergency Planning Interrogatories & Request for Production of Documents to Sponsors of EPJ-1,EPJ-4 & EPJ-5.Certificate of Svc Encl. Related Correspondence ML20107G1011984-10-31031 October 1984 Final Response to Conservation Council of North Carolina First Set of Interrogatories & Request for Production of Documents on Emergency Planning Contentions.Related Correspondence ML20107F3851984-10-31031 October 1984 Response to Conservation Council of North Carolina Interrogatories & Request for Production of Documents Re First Set of Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence 1999-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
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- _ ) .' 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
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