ML20080E857

Responds to Applicant First Set of Interrogatories Re Contention I-42.Certificate of Svc Encl.Related Correspondence

ML20080E857
Person / Time
Site:	Limerick
Issue date:	02/06/1984
From:	Zitzer P LIMERICK ECOLOGY ACTION, INC.
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8402100178
Download: ML20080E857 (9)

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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION m BEFORE THE ATOMIC SAFETY AND LICENSING BOARD : - "

'C.......a* SEi SRANCH h.7 In the Matter of .

m PHILADELPHIA ELECTRIC COMPANY  :

' Docket Nos. 50-352 E I"'

50-353 (Limerick Generating Station,  :

Units 1 and 2)  :

ft LEA'S ANSWERS TO APPLICANT'S FIRST SET OF INTER- b ROGATORIES RELATING TO CONTENTION I-42. -

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Limerick Ecology Action hereby responds to Applicant's -

Jan. 10, 1984 First Set of Interrogatories and Request for Pro- 7. . .

duction of Documents on Contention I-42., pursuant to the NRC ((

Rules of Practice and Procedures, 10 CFR 2. 74 0 (b) and the Board's [.I Order of Oct. 28, 1983. Please note that LEA was informed by Ni Applicant's counsel that LEA was not expected to respond to a

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similar (but shorter) " Initial Interrogatory" Request dated e.;

Jan. 9, 1984, due to the fact that Applicant's First Set of  :: -

Interrogatories covers the same material (per conversation with  !

Mark Wetterhahn, 2/3/84). All answers have been prepared by Phyllis -

itzer, President of LEA, a full-time voluntecr.

INTERROGATORIES M

E'r 1). State whether or not LEA intends to present any expert witnesses on Contention I-42.

ANSWER: At the present time, LEA has no plans to present. expert Ir testimony on I-42. A

2. State whether or not LEA intends to present any facutal witnesses Y on the subject matter at issue in. Contention I-42.

ANSWER: At the present time, LEA has no plans to present any factual {

witnesses on the subject matter at issue in Contention I-42. ..,

3. Identify by titic, author publisher, and date'or issue, all docu-N 7-ments that LEA relies unon as a basis ~for Contention I-42, or that LEA intends to use in presenting its' direct case or in cross- 5 examining'other witnesses on Contention I-42, and identify g 8402100178 840206 i' 1 PDR ADOCK 05000352 "

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all documents to which LEA intends to refer to in conducting cross.. examination of other witnesses who may testify in connec-tion with any such contention.

ANSWER: LEA is relying upon the documents listed as the " Basis" for {

this contention as discussed in its filings on Respecification I of Contention I-42, dated 7/11/83, 8/9/83, and any subsequent '

_ material provided to LEA by the Applicant.

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4. To the extent that your answer to any interrogatory is based upon one or more documents, (a) identify each such document on which your answer is based; (b) identify the specific information in such document upon which you rely; (c) explain how the information provides a basis for your answer.

ANSWER: See discussion under " Basis" section of LEA's filings on I-42, dated 7/11/83 and 8/9/ST as referemced above, Applicant's responses to City Interrogatories dated 2/3/84 may provide additional information.

5. To the extent that your answer is based upon any study, calculation, research or analysis, (a) describe the nature of the study, calculation, research or analysis and identify any documents which discuss or describe the study, calculation, research or analysis; (b) identify the per- .

son (s) or entity (ies) who performed the study, calculation, research or analysis; (c) describe in detail the information which was the subject of the study, calculation, research or analysis; (d) describe the results of such study, calcu-lation, research or analysis; (e) explain how such study, calculation, research or analysis provides a basis for your answer.

ANSWER: Not applicable.

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1 answer is based upon

6. To the extent that your 1 correspondence or other conversations, consultations or communications with one or more individuals or entities, (b) state please identify each such individual or entity; the educational and professional background of each su h 3

individual, including occupation and institutional affil-iations; (c) describe the nature of each communication, including time and context, and describe the information (e) explain received from each such individual or entity; how such information provides a bacis for your answer.

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ANSWER: Not applicable.

7. To the extent that intervenor possesses information or documents expressing facts or opinions which are relevant to the specific interrogatories below, but which do not support intervenor's position or which have not otherwise been fully provided in the answers thereto, please provide such information and documente.

ANSWER: Not applicabic.

Specify each system, component or part or tne

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asserts is Limerick Generating Station which intervenor meaning of 10 C.F.R.

safety" within the "important to which has not been included' in Appendix B of the 550.49(b) As Environmental Qualification Report ("EQR") for Limerick.

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to ecch such component or part, (a) describe in detail the component or parts and their exact location at the Limerick Generating Station; (b) identify the manufacturer, if known; I (c) identify whether the component or part is asserted to be l 1

3 within the category "important to safety" because of its inclusion within 10 C.F.R. S50.49b (1) (2) or (3), describing in detail the reason for classification in one or more of these categories; (d) describe in detail the alleged "impor-tant to safety" function which the component or part will perform; (e) state the basis which the intervenor used in concluding that another system, component or part, or combination thereof, which is being qualified or which is not within a harsh environment cannot perform the function instead of the subject part or component; (f) state the basis, if any, upon which intervenor asserts that environ-mental qualification of such component or part will not or could not be performed prior to fuel loading for Limerick Unit 1 or 2, as appropriate; (d) the exact event or events for which intervenor asserts that the equipment must - be qualified, the time or times after the initiation of the most critical event during which the part or component is asserted to be necessary to operate, and the exact environ-mental conditions which the component or part would experi-ence.

ANSWER: Intervenors position is that PECO has not complied with the new expended EQ rule, nor even attempted to conduct a thorough review of both safety-related and non-safety-related equipment to determine which equipment falls into category (b) (2) of the EQ Rule (10 CFR 50.49), since either might contain non safety related components, the failure of which could prevent the satisfactory accomplishment of safety functions.

LEA is unabic to provide a more detailed response until it receives answers to City Interrogatories on I-42 dated 2/3/84.

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"""" Identify any and all components or parts listed in

- m Appendix B of the EQR which intervenor asserts will not be environmentally qualified by

.jjj the time of fuel loading for

... 2.9 each unit, giving the basis M for such conclusion and stating 35t when intervenor believes such part or equipment will be y

...a qualified, giving the basis for such conclusion or estimate ,

ANSWER: LEA is Ap'plicant*s receiving unable to respond to this Interrogatory without on I-42, dated 2/3/84 answers It is to City Interrogatories also possible that LEA will not be able to provide a throuogh question until it has had an opportunityanswer to to this cross-exa-mine PECO's witnesses on this contention.

. 10. With regard to each of the following parts, compo-nents, or systems which intervenor alleges should be includ -

ed in the equipment qualification program, (1) feedwater control; (2) emergency lighting and communications systems; (3) plant process computer system; (4) computer scftware:

(a) identify the exact systems, part or component involved, with reference to the description P&I.D.'s, contained in the FSAR or if possible; (b) identify the location or lo-cations of the systems, parts or components at the Limerick Generating Station; (c) identify the conditions, e.g. LOCA .

or HELB; which intervenor asserts require that these systems be qualified; (d) identify the operations that such equip-ment would have to perform for such conditions and the time frame in which these actions are required; (e) identify the harsh environment that such equipment, part or component would experience; (f) state intervenor's understanding of systems, equipment, parts or components which can perform

' functions equivalent to those identified above and which are either being qualified or are not located in a harsh en-

12. ,

As to each component or part for which intervenor ,

asserts that an' Equipment Qualification Review Record

("EQRR") has not been provided in Applicant's Environmental Qualification Report for Limerick, (a) specify each part or a component allegedly omitted; (b) identify the exact location of such component or part; (c) identify the manufacturer, if known; (d) state the basis upon which intervenor relies to assert that such part or component should have been included in en EQRR.

ANSWER: LEA cannot respond until it is provided with answers to City Interrogatories on I-42, dated 2/3/84. Further-more. LEA's concerns relate to the scope of search made by the Applicant to determine (b) ( 2) "important- ,

to safety" equipment. LEA believes that it is the Appli-cant's responsibility to make a showing that its EQ pro-gram meets the new requirements of the 1/31/83 new EQ Rule.

13. As to each part or component for which intervenor asserts that the EQRR specifies a qualified life of less than 40 years, (a) specify the part or component; (b) identify the manu.facturer, if known; (c) the corrective action which intervenor asserts should be.taken by Applicant to correct the alleged deficiency, the basis upon which the' means for identification of such items by Applicant as .

discussed on page 8.2 of the Environmental Qualification Report is insufficient to meet NRC requirements.

ANSWER: LEA's position is that no action is identified to correct noted deficiencies where life of qualified equipment does not equal the 40 year plant life. 1 (See EQRRs, pp. 8,32-35) LEA intends to cross-exa-mine Applicant's witnesses to determine whether or not NRC requirements have been satisfied. l

14. State intervenor's basis for the assertion that the key switch in the control room for the standby liquid control system is in a harsh environment and thus subject to _.

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COMMElf7S SUBMITTED ONLY TO APPLICANT'S COUNSEL f

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LEA has relied soley upon documentr. nrovided by the Applicant. [

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I hereby affirm that the above answers are true and correct to the g best of my knowledge. 5

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CERTIFICATE OF SERVICE

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'M FD -9 AM :06 5 I hereby certify that LEA's E Responses to Applicant's _First {

Set of Interrogatories relating to Contention I-42 havf,been- g g served upon the following by first class mail, p o s t a g p#"p sgjg ' '

on Feb. 6, 1984. {

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Lawrence Brenner, Chairman (2)

Ann P. Hodgdon, Esq. k Administrative Judge Office of the Executive Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission ET il Commission Washington, DC 20555

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Washington, DC 20555 Benjamin Vogler, Esq. a Dr. Richard F. Cole 6 Administrative Judge Office of the Executive Legal Director e U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory kashington, DC 20555 E Commission ,=

Washington, DC 20555 Troy B. Conner, Jr., Esq.

[7 Dr. Peter A. Morris Conner and Wetterhahn 2:

1747 Pennsylvania Ave., NW 5 Administrative Judge Washington, DC 20006 U.S. Nuclear Regulatory- l@

Commission Philadelphia Electric Company Washington, DC 20555 Attn: Edward G. Bauer, Jr.

is Docketing and Service Section VP and General Counsel y 2301 Market St. =

Office of the Secretary Phila., PA 19101 U.S. Nuclear Regulatory 5 Commission Thomas Gerusky, Director M Washington, DC 20555 Bureau of Radiation Protection, DER Ti EL 5th fl, Fulton Bank Bldg. E Atomic Safety and Third and Locust Sts.

Licensing Board Panel Harrisburg, PA 17120 E U.S. Nuclear Regulatory g Commission Spence W. Perry, Esq. y Washington, DC 20555 gg Associate General Counsel =

Atomic Safety and FEMA Room 840 -

b EE Licensing Appeal Panel 500 C St., SW EE U.S. Nuclear Rerulatory Washington,.DC 20472 Commission =.

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Washington, DC 20555 Zori Ferkin, Esq. Ms Governor's Energy Council GE P.O. Box 8010 1625 Front St. {}=

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mm Harrisburg, PA 17105 E, j?:?

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Jay M. Gutierrez, Esq. Robert Sugarman, Esq.

U.S. Nuclear Regulatory Commission Sugarman and Denworth Region 1 Suite 510 l 631 Park Ave. North American Building l King of Prussia, PA 19406 121 S. Broad St.

Phila., PA 19107 Director, PEMA Basement, Transportation David Wersan, Esq.

and Safety Building Assistant Consumer Advocate Harrisburg, PA 17120 Office of the Consumer Advocate 1425 Strawberry Square Angus Love, Esq./Myggggy Aid)

C Harrisburg, PA 17120 107 East Main St Norristown, PA 19401 Gregory C. Minor Robert Anthony MHB Technical Associates 103 Vernon Lane 1723 Hamilton Ave.

Moyla'n, PA 19065 San Jose, CA. 95125 Martha W. Bush, Esq.

Kathryn S. Lewis, Esq.

Solicitor's Office City of Philadelphia Municipal Services Building Phila., PA 19107 -

Steven Hershey, Esq.

community Legal Services 5219 Chestnut St.

Phila., PA 19139 Marvin I. Lewis 6504 Bradford Terrace Phila., PA 19149 Frank Romano 61 Forest Ave.

Ambler, PA 19002 Joseph H. White,III 15 Ardmore Ave.

Ardmore, PA 19003 February 6. 19A4 9485 W PHYLLIS {1TZER V m, 7 _ _ , ,,.. _ .