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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
[Table view] |
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igg November 11, 1983 -- - . .
13 NW 14 41:37 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h[ ;c .3 S' '
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,,
In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
APPLICANTS' SUPPLEMENTAL RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 41 AND 65 TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.
(FIRST SET)
Pursuant to the Licensing Board's " Memorandum and Order (Ruling on Discovery Disputes)" of October 6, 1983, and to the rulings issued by the Board during telephone conferences on September 22 and 23, 1983, Applicants herein provide their re-sponses to a portion of those interrogatories for which the Board granted intervenor Eddleman's Motion to Compel Discovery.
As Mr. Eddleman has been advised, responses to the remaining interrogatories (which require the receipt of information from Daniel Construction Company) will be provided at a later date.
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. RESPONSES TO GENERAL INTERROGATORIES INTERROGATORY NO. Gl(c): Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each-such answer; or (2) upon whom Applicants relied (other than their attorneys) in making such answer.
ANSWER: The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Eddleman Contention Nos. 41 and 65 and indicates the particular interrogatory answer (s) for which each such person provided information.
PERSON INTERROGATORY NO(S).
K. V. Hate' 41-1(d); 41-5(c)
G. O. White 41-1(d)
D. Timberlake 41-1(n) and (o); 41-1(q); 41-7 C. French 41-5(i) through (k); 41-6 A.-Fuller 41-3(e) and (f); 41-4(i); 41-5(a) through (f); 41-5(i) through (k)
B. Marlar 65-1(b)
- R. M. Parsons 65-2(a); 65-3(a) and (b)
All of the above individuals are employees of Carolina
' Power & Light Company at the Shearon Harris Nuclear Power Plant, Route 1, Box 101, New Hill, North Carolina 27562.
RESPONSES TO INTERROGATORIES ON CONTENTION 41 INTERROGATORY NO. 41-1(d): Identify the qualifications of those persons.who reviewed welding symbols, blueprints and specifications, i.e., explain what is meant by the term "de-greed engineers" as used in Applicants' initial answer to In-
, terrogatory No. 41-1(d). (As modified by the Board at Tr.
663.)
, - . . _,.-m . , , , - _ . ,y_ _
_,.m,,, .,...,m,, , - ,.___e- w., _ - , . , , - - _ - - , . _ - . . , - .m, .,-, , --
ANSWER: A " degreed engineer" is a person.with a baccalau-reate degree in engineering, or the equivalent degree from a foreign university.
Review of welding procedure specifications has been performed by QA Engineers who have, as a minimum, a bachelor's degree in mechanical or metallurgical / materials engineering.
Of the 34 designers currently with the Harris Plant hanger design organization, 27 are degreed engineers (19 in civil en-gineering and 8 in mechanical engineering). The design organi-zations at Ebasco and Bergen-Patterson have employed many de-signers over the life of the project and detailed records of their qualifications are not available to Applicants. However, the education and experience of these designers would be similar to those employed by Applicants.
INTERROGATORY NO. 41-1(n): State whether Applicants' welder training courses cover the reading of welding blue-prints, including symbols for size, length, position, penetra-tion, groove preparation, heat treatment, undercut allowable, type of electrode required, current setting and type (DC or AC). (As modified, Tr. 666.)
ANSWER: Yes.
l INTERROGATORY NO. 41-1(o): Have Applicants established "
l who made the defective welds identified on pipe hangers at Harris?
ANSWER: No. There are no site or code requirements that
+
require Applicants to maintain records that identify which welder or welders welded on a specific weld joint on a pipe '
hanger. Welder identification is maintained by hanger and not p,-,,, _ . - - , -
by individual weld. A hanger could have any number of weld joints on which several welders have welded, and if one or more ,
of these welds.were rejected it would not be feasible to iden-tify.the specific welder (s) that made the defective weld (s).
INTERROGATORY NO. 41-1(q): If Applicants don't know who made the defective pipe hanger welds, will they admit their QA program is inadequate in that respect?
ANSWER: No.
INTERROGATORY NO. 41-3(e): For each such rejection of -
hanger in b above-[ rejected as a result of reinspection due to
. weld defects), identify and produce a 10% sample of those field change requests, requests for permanent waiver, and field re-werk orders issued with respect to it. (As modified, Tr. 730.)
~ ANSWER: .The requested records regarding pipe hangers will be made available pursuant to Applicants' Supplemental Response to Wells Eddleman's Request for Production of Documents. The 10% sample of applicable Pipe Hanger Problem Reports, Field Change Requests, Permanent Waivers and Reworks was obtained by reviewing the Reinspection Logbook and obtaining the documents associated with the first reject and every tenth reject there-aftch. -
's' _
~,
Applicants' May 12, 1983 Response to Request for Produc-tion of Dgcuments provided the requested documentation concern-l, ing HVACiand conduit hangers.
l INTERROGATORY NO. 41-3(f): Foi e^ach hanger in e above, state what review of the field work orders, field change re-i / quest, or request for permanent waiver was done, and the date
, - - for each such field work order', field change request (FCR) or
- . permanent waiver request (PW) and the date each such was approved. If any such FCR or PW request was denied, or any field work order modified for this hanger, so state, and explain fully, for each hanger covered by this interrogatory.
7'
- f'._ _ _ _ _. -., ___. .- _ .._.- _. _ . __ _
ANSWER: See Applicants' answer dated May 12, 1983. The requested information as to the 10% sample required by th 1-censing Board can be obtained from documents produced in re-sponse to Interrogatory No. 41-3(e), above.
INTERROGATORY NO. 41-4(i): List all persons under g above '
who are no longer at Harris, giving last known address for each.
ANSWER: Not applicable. See Applicants' answer to Inter-rogatory No. 41-4(g) dated May 12, 1983.
INTERROGATORY NO. 41-5(a): State whether welders working at Harris had any instructions, prior to 9/3/80, on what to do if a weld drawing was unclear, unreadable, or in obvious error?
ANSWER: Yes.
INTERROGATORY NO. 41-5(b): If answer to (a) above is af-firmative, state the general instructions given to welders.
(As modified, Tr. 678.)
ANSWER: Prior to September 3, 1980, the various welding foremen were orally instructed by the appropriate Superinten-dents to return drawings with unclear, unreadable or incorrect weld symbols. The individual foremen were then responsible for relaying this information to the welders.
INTERROGATORY NO. 41-5(c): If answer to (a) above is other than affirmative, did QA/QC know of the non-existence of such instructions?
ANSWER: Not applicable.
INTERROGATORY NO. 41-5(d): State whether Applicants can identify every welder who worked on pipe hangers at Harris who identified an unclear or missing detail or instruction on a
, pipe hanger weld olueprint to a superior (foreman, etc.) or QA/QC person at Harris prior to 9/3/80, the date on which s/he
did it, and what action was taken with respect to such blueprint, for each such blueprint. (As modified, Tr. 729.)
ANSWER: 'The requested information cannot be obtained.
The person who initiates a Pipe Hanger Problem report or a Field Change Request in order to correct an unclear or missing weld symbol can be determined from the document itself. The name of the welder who may have originally identified the error is not recorded. Documents produced in response to Interroga-tory No. 41-5(i) below provide information as to the identity of the initiator and subsequent corrective actions.
INTERROGATORY NO. 41-5(e): If no action was taken under (d) above for any report, or if CP&L cannot document the action, so. state; otherwise, provide all documentation of actions taken on such identification of unclear or missing de -
tail or instruction on a pipe hanger weld blueprint prior to 9/3/80, for inspection and copying.
ANSWER: See answer to Interrogatory No. 41-5(d), above.
INTERROGATORY No. 41-5(f): State whether any welders at Harris made defective pipe hanger weids after going through Ap-plicants' welder training program.
ANSWER: Yes.
INTERROGATORY NO. 41-5(i): State exactly how many weld drawings have been returned to the Site Mechanical Unit under the policy of returning such when it is not possible to weld the hanger exactly as drawn due to physical limitations or drawing errors.
INTERROGATORY NO. 41-5(j): For each weld drawing which was returned due to the reasons set forth in (i) above, since 9/3/80, state exactly what was done to resolve the problem and document'all such resolution by identifying all documents which show or contribute to such resolution or approve such resolu-tion.
INTERROGATORY NO. 41-5(k): State whether any permanent waivers have been granted for any weld for which a drawing has I
been returned to the Site Mechanical Unit for the reason (s) set forth in (i) above or any of them, and for each such permanent waiver, state the basis therefor and any engineering rationale underlying it, and state who granted the waiver or approved it.
ANSWER: In accordance with the Board's ruling (Tr.
727-728), Applicants will produce a 5% sample of the applicable Field Change Requests, Pipe Hanger Problem reports and Permanent Waivers pursuant to Applicants' Response to Wells Eddleman's Request for Production of Documents.
All PHPs, FCRs and PWs for pipe hangers were researched to identify those associated with weld symbol errors or inability to make the required weld due to physical limitations. Of this group, every twentieth document has been retrieved for produc-tion to Mr. Eddleman.
For HVAC and conduit hangers, a review of all Architectural-Structural FCRs and PWs was performed to identify those concerned with welding problems. Again, of this group, every twentieth document will be made available for review by Mr. Eddleman.
INTERROGATORY NO. 41-6: Answer all questions and all parts of Interrogatories 41-3, 41-4, 41-5 above, inclusive, with respect to (a) Bergen-Patterson pipe hangers only (b) HVAC hangers only (c) Cable tray and electrical conduit hangers only.
ANSWER: Unless otherwise noted above, the response to subparts (a), (b) and (c) of this interrogatory is the same as the above answers to Interrogatories 41-3, 41-4 and 41-5.
4
t INTERROGATORY NO. 41-7: Identify all percons retrained in welding, blueprint reading . . . re pipe hangers or other supports by CP&L since 9/3/80 and when each such person was retrained, for how long, using what curriculum and materials (produce same for inspection and copying), and state what tests if any were given to each such person during or after such training to determine the effect of such training (or for any other purpose) and what the results of those tests were for that person, for each such person.
ANSWER: Welders were not retrained in welding because their ability to deposit sound welds was established during their performance qualification (per ASME B&PV Section IX re-quirements). Retraining of welders did include the following:
(1) gen 1ral review of welding symbols and (2) procedural re-quirements for structural welding (including pipe hangers).
Information which provides details of the retraining of welders will be produced in accordance with Applicants' Supplemental Response to Wells Eddleman's Request for Production of Documents. Tests were given to welders in the retraining classes to verify their understanding of weld symbols and general procedural requirements, but test results were not maintained as a part of the training records (test results were orally reviewed during training classes).
RESPONSES TO INTERROGATORIES ON CONTENTION 65 INTERROGATORY No. 65-1(b): For each pour in the contain-ment building which exhibited honeycombing or voids and for 5%
of the remaining pour packages, provide the following informa-tion: the date(s) of the pour; the supervisor (s) of the pour; the time (s) in which the pour took place; whether a concrete placement report, or equivalent, exists for such pour; and, whether a sample or samples of such pour was retained, and, if so, identify each such pour. (As modified, Memorandum and Order at 4.)
l
ANSWER: Of.the 106 concrete placements for the contain-4 ment building base mat, exterior walls and dome, only one was identified as having honeycombing or voids. (Note that Appli-cants' answer of:May 12, 1983 to Interrogatory No. 65-1(h) was i
not limited to the containment base mat, walls and ceiling, but included interior concrete pours, and thereby provided informa-tion b;vond the scope of the interrogatory.) The requested in-fo rn.a ulon for this placement is set forth in Exhibit 1 attached hereto.
Exhibit 2 hereto contains the requested information for i
the additional ~ random sample. The random sample was obtained
, by selecting-the first pour package in a file drawer and every tenth package thereafter.
The concrete samples listed in Exhibits 1 and 2 are required by the ASTM Code to be retained for 28 days, at which time compressive strength tests are performed on each sample.
As storage space permits, samples may be retained for a short period thereafter, but are then discarded. ,.
1 INTERROGATORY NO. 65-2(a): To. knowledge of Applicants, including their contractor Daniel International, is it true that (1) the' base mat poured in December 1977 at Wolf Creek has approximately 50 percent of its concrete test containers for -
the base mat pour-failing (or having failed) to meet strength
. of 5000 psi, (2) that 5000 psi is the specified strength for test' containers from this pour, (3) that the concrete used in the pour was purchased from a company that supplied Daniel with a mixLformulated intended for use in ditch linings and box culverts on highways, (4) that such concrete was used in the base mat pour at Wolf Creek, and/or (5) that such concrete is not approved for a highway surface, but only for non-safety-related mud slabs and fill concrete only.
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INTERROGATORY NO. 65-3(a): At the Wolf Creek, Callaway and Farley plants, state what major modifications to design and-structures at each were required by (a) NRC (b) Daniel (c) the
. utility after discovery of defects in concrete emplaced in the containment building. (Tr. 686.)
INTERROGATORY NO. 65-3(b): Identify all significant repairs made to concrete in the base mat, and containment walls, at Callaway, Wolf Creek and Farley after discovery of significant defects.
ANSWER: Applicants do not know. Applicants have discussed these interrogatories with their contractor Daniel, which is not a party to this proceeding. Daniel has advised CP&L that any information available to Daniel with respect to these other nuclear projects which would be responsive to the interrogatories is not within the control of CP&L as that term is construed for discovery purposes.
1
In addition, reference is made to the NRC Staff's answers to Eddleman Interrogatories 96 and 97, served on June 24, 1983 (pages'82-84). There the Staff answered questions about
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concrete placements at the Callaway, Wolf Creek and Farley facilities and identified numerous relevant documents which, it 1
appears, were made available for inspection and copying.
Thomas A. B a x t e r , P'. C .
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Carolina Power & Light Company P. O. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517-Counsel for Applicants Dated: November 11, 1983
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4 UNITED STA7d5 OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE__THE ATOMIC' SAFETY AND LICEN_S_ING BOARD-In the Matter of )
)
CAROLINA POWER & LIGHT COMPAN'l ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 QL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
AFFIDAVIT OF R_OLAND M. PARSUd County of Wake )
) as:
State of North Carolina )
i Roland M. Parsons, being duly sworn according to law, deposes and says that hc is Project General Manager - Shearon Harris Nuclear Power Plant of Carolina Power a Light Company; that the answers to Interrogatories on Contentions 41 and 65 contained in "Applicantu' Supplemental Responses to Wells Eddleman's General Interrogatories and Interrogatories on l
contentiona 41 and 65 to Applicants Carolina Power & Light
- Company, et al., (First Set) are true and correct to the l
best of his information, knowledge and belief; and that l
the sources of his information are officers, employees, agents and contractors of Carolina Power & Light company.
W +~~'
..Rdrand M. Parsons Sworn and subscribed to before me this // r4. day of November,1983.
l' Notary Public f's%_
l My Commission expiren f/J */ f4 __ __
- - . . . . - . . _ - - . , - _ _ . . . . .