ML20080A625

Answer to Applicant Second Set of Interrogatories & Request for Production of Documents on Contention VI-1.Related Correspondence

ML20080A625
Person / Time
Site:	Limerick
Issue date:	02/01/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20080A619	List: ML20080A617 ML20080A625
References
NUDOCS 8402060168
Download: ML20080A625 (5)

Text

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$~ AIR and WATER Pollution Patrol BROAD AXE, PA. February 1%Bc3 A10:25 y U. S.

Nuclear Regulatory Washington, D.C. 20555 Commission,__.._

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um i5 Before The Atomic Safety and Licensing Board

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PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (LIMERICK GENERATING STATION and 50-353 UNITS 1 and 2)

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Vii- AWPP's (Romano) Answers To Applicant's Second Set

== Of Interrogatories And Request For Production Of Documents To Intervenor On Contention VI-l Interrogatories n :x.

(1) State whether intervenor intends to present any expert

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m =a witnesses on the subject matter at issue on Contention VI-1, as

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}[si[ restated by the Licensing Board in its Memo'randum and Order dated

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October 28, 1983 (slip op. at 5 ).

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Z Answer: Not yet known.

N (2) State whether intervenor intends to present any factual

?.25 witnessesia)If so professional qualifications; (b) Subject matter; (c),

Substance of the facts e which witness is expected to testify.

Answer: Frank R. Romano; (a) consulting chemist; (b) careless workmanship; (c) Careless workmanship involving safetysrelated welding.

(3) Identify by title, author, publisher and date of issuance mg ~ ~ '

of publicantion, all documents that you rely upon as a basis for your

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contentions or that you intend to use (by way of reference or eviden-

[ tiary proffer) in presenting your direct case or in cross-examining other witnesses on Contention VI-l and all documents to which you intend to refer in cross-examination of other witnesses who may testify.

Answer: All inspection reports and logs and Finding Reports

==y. 8402060168 840201 requesteo of Applicant. gPDR ADOCK 05000352

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AIR and WATER Pollution Patrol BROAD AXE, PA.

(2)

S AWPP's (Romano) Answere to Applicant's 2nd Set of Interrogatories On Contention VI-1 centinued: .

(4) To the extent that your answer is based on one or more documents,(a) identify such document; (b) identify specific linfor-mation; (c) explain how information provides basis for answer.

Answer: (a) As stated in #3; (b) as in #3 IE Reports; (c) infractions discribed.

(5) To the extent that you answer is based upon any study, calculation, research or analysis, (a) describe its nature; (b) iden-tify person (s) or entity (ie$ who p'erformed it; (c) describe its' information; (d) describe the results; (e) explain how it provides .

basis for answer.

Answer: (a) Study of all IE Notices'of welding infractions, as an example, 76-06 '(Broomstick Aff air) See 76-0E-Ql; (b) you have this information; (c) falsification of work record; (d) re-inspect-ion resulted is discovery of fraud; ('e ) admission of inacurate state-ments. Also 1/24, 25/84 Phila. Inquirer revelations re Zimmer.

y (6) To the extent that you answer is based upon conversations, consultations or correspondence or other communications with one or more individual or entities please identify, (b) state educational and professional bad: ground (c) describe nature of communication; (e) explain how such information provides basis for answer.

Answer: See (5).

(7) To the extent that intervenor possesses information or doc-uments expressing facts or opinions which are relevant to Contention VI-1, but which do not support intervenor's position or which have

AIR an'd WATER Fkillu~ tion Patrol BRdili: AXE, PA

-(3)

AWPP's (Romano) Answers tofApplicant's 2nd Set of (interrogatories On Contention VI-l continued:

not otherwise been fully provided in the answers t'hernto, please pro-vide such information and documents..

Answer: None at this time.

(8) Specify each*-system, component or part of the Limerick Generating Station as to which intervenor asserts-that Applicant has failed to control performance of welding and inspection in accordance with quality control and quality assurance procedures and requirements (aside from that reported in NRC Inspection Report 50-353/76/06/01).

Answer: IE Reports as follows: 74-04-06; 75-03-04-05; FR N-079; N-063- 76-06; 77-02-06-10, 11,12; 78-03,4,7,8-12; 79-09-11; 80-G2, oG- -

18,19,20; 352-80-19-21;-81-01-04-05-08; 82 CPPR-106; 82-01,02,03-82-16 (CPPR-106-107); 83-05,07,08,11,16.

1 (Included in answer is unresolved infractions detailed in all above IE reports or FR reports.) '

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l (a) Identify system, component or part involved in such failure.

b.ove t l Answer: As describe [fgn the numerous IE Reports and logs through-l out safety related component system. Specific questions have been asked l of Applicant but no.t answered... ,

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AIR and WATER Pollution Patrol EROAD AXE PA.

(4)

) AWPP's (Romano) Answers to Applicant's 2nd Set of Interrogatories On Contention VI-l continued: .

(b) Specify procedure which Applicant failed to utilize or requirement Applicant failed to meet.

Answer: See I.E. reports, AWS Code, Qualification tests, Qual-ity assurance records.

(c) Describe the exact defect or deficinecy which resulted.

Answer: See welding logs and IE infraction reports.

(d)

State the nondestructive tests conducted on the weld in question.

Answer: Information not supplied in docuntents available.

(e) Identify the individual or individuals involved in the faulty welding or inspection.

Answer: Not all known, since not all deficient welds known, as example in unknown deficient welds re 76-06-01.

(f)

Identify the manner in which the defect or deficiency was ,

discovered.

Answer: Inspections, and by personnel known or anonymous.

(g) Identify the individual or individuals who discovered such defect or deficiency.

Answer: Inspectors, as per IE reports.

(h) Identify when and under what circumstances intervenor learned of such defect or deficiency.

Answer: Looking at IE reports after submission.

(i)

Identify the documentation related to the defect or de-ficiency and its correction known to intervenor.

AIR and WATER Pollution Patrol BROAD AXE, PA.

(5)

Q AWPP's (Romano) Answers to Applicant's 2nd Set of Interrogatories on Contention VI-l continued:

Answer: Defect not known to be corrected (as per 76-06-01) not fully described by Applicant.

(j) Specify whether such defect or deficiency has been dis-positioned or corrected.

Answer: Many not dispositioned...nor corrected, re 76-06-01.

(k) If the defect has not been dispositioned or corrected, whether such action is planned or scheduled.

Answer: See Boyer affadavit re inaccessible welds.

(1) Specify the manner in which the defect or deficiency has been dispositioned or corrected.

Answer: See k above.

(m) Specify the reasons why intervenor believes the correctipn or disposition of the deficiency or defect fails to meet all app}i-cable requirements of the Philadelphia Electric Company, its contrac-tors or the Nuclear Regulatory Commission.

Answer: Because as shown by 76-06-01 inspectors have been shown to O.K. work without inspecting it.Further, there are numerous examples when all requirements have not been met, it is dispositioned "use as is" for convenience only. Further, see Inquiter-Zimmer revelations.

Respectfully submitted gL We R POLLUTION PATROL

'F(ahk R .'R'OdIa~no , Chairman 61 Forest Ave.

Ambler, Pa. 19002

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