ML20080E803

Interrogatories & Request for Production of Documents of City of Piladelphia to Util Re Sys Interaction.W/Certificate of Svc.Related Correspondence

ML20080E803
Person / Time
Site:	Limerick
Issue date:	02/06/1984
From:	Bush M PHILADELPHIA, PA
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8402100140
Download: ML20080E803 (12)

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RELATED CORRESPONDENN 00Cvr?E9' UNITED STATES OF AMERICA MUCLEAR REGULATORY COMMISSION .y c,

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Before the Atomic Safety and Licensing 3,dard

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In the Matter of  :

Philadelphia Electric Company  :

Docket Nos. S'0-352 (Limerick Generating Station,  : 50-353 Units 1 and 2)

INTERROGATORIES AND REQU2ST FOR PRODUCTION OF DOCUMENTS OF THE CITY OF PHILADELPHIA TO PHILADELPHIA ELECTRIC COMPANY ON SYSTEMS INTERACTION Pursuant to the Rules of Practice of the Nuclear Regulatory Commission ("NRC"), 10 C.F.R. 5 2. 7 4 0 (b ) , and the Atomic Safety anc Licensing Board's Memorandum and Order (October 28, 1983), .

the City of Philadelphia-(" City") hereby propounds the following interrogatories to Philadelphia Electric Company ("PEC0") to be answered fully in writing, under oath, in accordance with the definitions and instructions below.

Additionally, pursuant to 10 C.F.R. 62.741, the City requests ,

that PECO produce for inspection and copying (or provide copies of) those document- designated by it in its respective answers below.

Definitions and Instructions

1. For each interrogatory, please state the full name, work address, and title or position of each person providing information l for the answer to the interrogatory, i

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2. The following definitions shall apply:

a. "PECO" shall refer to the Philadelphia Electric Company or any official, officer, member, j

employee or consultant thereof.

b. " Document" shall mean any written, printed,

{ typed or other graphic matter of any kind or nature, and all mechanical and electronic i

sound recordings and transcripts thereof, in the I

possession, custody, or control of PECO, or its officials, employees, or agents; it shall also

, mean all copies or drafts of documants by whatever means made.

c. "Date" shall mean the exact day, month and year, if ascertainable, or, if not ascertainable, the best approximation (including the evene's relation-ship to other events in-the relevant centext of the interrogatoryl.

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d. "NRC" or " Commission" shall mean either the Atomic

! Energy Commission or the Nuclear Regulatory Commission, as appropriate, including its regula-l tory staff.and adjudicatory boards, as indicated by the context-of tne interrogatory.

e. "Specify", when referring to a proceeding before the Nuclear Regulatory Commission, means that the answer shall se; forth the proceeding, applicant, I

' docket number, relevant date, and any de.scriptive information appropriate to the request.

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f. ",Specify" or " identify", when referring to an fndividual, corporation, or other entity, means that the answer shall set forth the name, present or last known work address, and, if a corporation or other entity, its principal place of businass or, if an individual, his or her title or titles and epployer. Once an individual. corporation or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation or other entity to state mer.ely his, her or its name.

3. These , interrogatories request all knowledge and informa-tion in PECO's possession and/or knowledge and information in the possession of PECO officials, officers, agents, representatives, consultants, and unless privileged, attorneys.

4. In sach instance in which an interrogatory requests a statement of PECO's assertion, view or opinion, the answer shall .

also contain a full discussion of the factual basis for the assertion or opinion.

Interrogatories

31. State whether PECO intends to present any expert witnesses on the subject matter at issue in Contention I-41, as stated in Limerick Ecology Action's letter dated September 28, 1983 and admitted.by the Licensing Board in its-Memorandum and Order dated October 28, 1983 (slip op, at'1). If so, identify each expert TT 3

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witness and state (a) his professional qualifications; (b) the subj ect matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) the grounds for each opinion. Identify by court, agency or other body, each proceeding in which such individual rendered testimony on this subject.

32. State whether PECO intends to present any factual witnesses on the subject matter at issue in Contention I-41. If so, identify each such factual witness and further state (a) his professianal qualifications; (b) the subject matter on which the witness is expected to testify; (c) the substance of the facts to

, which the witness is expected to testify. Identify by court, agency, or other body, each proceeding in which such individual rendered testimony on this s ubj e c t ('s ) . ,

33. Identify by title, author, publisher and date of issuance op publication, all documents that PECO relies upon as a basis for opposition to the contention or that PECO intends to use (by way of reference or evidentiary proffer) in presenting its direct case, in cross-examining other witnesses on Contention I-41, and all documents to which PECO intends to refer in conducting cross-exami-nation of other witnesses who may testify in connecticn with any such contention.

34 To the extent that your answer to any interrogatory is based up.on one or mere documents, (a) identify each such document on which your answer is based; (bl identify the specific informa-tion in such document upon which you rely; (c) explain how the information provides a basis for your answer.

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35. To the extent that your answer is based upon any study, Et 2"

calculation, research or analysis, (a) describe the nature of the 3 a'

study, calculation, research or analysis and identify any documents @

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sis; (b) identif y the person (s) or entity (ies). who perf ormed the $

study, calculation, research or analysis; (cl describe in detail h the information which was the subject of the study, calculation, g research or analysis; (dl describe the results of such study, I

%d calculation, research or analysis; (e) explain how such study, [

t calculation, research or analysis provides a basis for your answer. $

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36. To the extent that your answer is based upon conversations,  :"

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consultations or correspondence or other communications with one or I more individuals or entities, please identify each such individual t

or entity; (b) state the educational and professional background of .

Y each such individual, including occupation and institutional affili-m ations; (c) describe the nature of each communication, including E time and context, and describe the inf.ormation received from each l

such individual or entity; (e) explain how such information provides f a basis for your answer. It

37. To the extent that PECO possesses information or documents )

l expressing facts or opinions which are relevant to the specific j interrogatories below, but which do not oppose intervenor's position i or which have not otherwise been fully provided in the answers thereto, please provide such information and documents.

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38. Define how PECO uses the following terms in relation- [

e gg ship to the Limerick Generating Station, giving the specific basis [

or reference for such definitions: (a) safety systems; (b ) non-safety systems; (c) systems interaction; (d) systems interaction _

analysis; (e) failure combinations. If you are aware that any of

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the definitions utilized by you differs from one utilized by City i or NRC, state the comparable definition and discuss the specific differences.

39. Specify each and every way or instance in which PECO has 2 h

taken into account systems interaction in its analysis of the  ;

reliability of systems to determine whether there are reasonable I assurances that the Limerick design adequately protects the public ,

from credible accidents. $

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40. Specify each and every way or instance in which PECO has i

taken into account classific. tion and qualification of systems 3 important to safety in their analyses of the reliability of systems j i

to determine whether there is reasonable assurance that the Limetick design adequately protects the public from credible incidents.

41. Specify each and every way or instance in which PECO has determined which is a proper sequence of accidents that should be considered within the design basis for Limerick.

42. Specify each and every way or instance in which PECO's determination of sequences of accidents to be included within the design basis of Limerick has taken into account systems interaction.

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43. Specify each and every way or instance in which PECO's determination of sequences of accidents to be included within the design basis of Limerick properly takes into account classification and qualification of systems important to safety.

44 Specffy each and every way or instance in which PECO adequately ~ determined whether the design basis of the plant ade-quately protects against every such sequence determined by them to be within the design basis for Limerick.

45. Specify each and every way or instance in which PECO took into account syste=s interactions in the determination of the adequacy of protection for sequences of accidents which they have included within the design basis for Limerick.

46. Specify each and every way or instance in which PECO ade-quately took into account classification and qualification of systems important to safety in the determination of the adequacy of protec-tion f,or sequences of accidents which it has included within the design basis for Limerick, i

47. Specify each and every way or instance in which PECO-i adequately applied proper systematic methodology such as the fault cree and event tree logic approach to analyze the reliability of systems to determine whether there is reasonable assurance that the  :

Limerick design adequately protects the public from credible i

accidents. ]

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48. Specify each and every way or instance in which PECO adequately applied proper systematic methodology to analyze the reliability of systems to determine whether there is reasonable -

h assurance that the Limerick design adequately protects the public from credible accidents.

49. Specify each and every way or instance in which PECO adequately identified the items for the Limerick Generating Station to which General Design Criteria 1, 2, 3, 4, 10, 13, 21, 22, 23, 24, 29, 35 and 37 apply and demonstrated compliance with these criteria. [

Recuest for oroduction of Documents Please attach to your answers to the interrogatories listed above a copy of all documents applicable to such answer or upon which you otherwise intend to rely in the presentation of your direct case or in the cross-examination of other witnesses, whether or not they support your position on the contention. Alternatively, please state that all such documents will be produced at a reason-able time and place to be agreed upon by PECO for inspection and copying.

Respectfully submitted, b.

MARTHA W. BUSE Deputy City Solicitor Counsel for City of Philadelphia "

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UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION'84 F2 -9 All :38 ATOMIC SAFETY AND LICENSING BOARD

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3 BEFORE ADMINISTRAT'"T JUDdES UU UIdIffgjC Lawrence Brenner, Chairman q Dr. Ricnard F. Cole j Dr. Peter A. Morris In the Matter of  : Docket Nos. 50-352-OL 50-353-OL PHILADELPHIA ELECTRIC COMPAhT  :

(Limerick Generating Station,  : {

Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that Interrogatories and Requests for Production of Documents of the City of Philadelphia to the Philadelphia Electric Company on Systems Interaction in the above-captioned proceeding have been served on the following persons named on the attached service list by hand delivery or'by

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causing the same to be deposited in envelopes addressed to said persons, first-class, postage prepaid, $nd deposited with the United States Postal Service at Philadelphia, Pennsylvania 19107. -

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Respectfully submitted, hw W.h MARTHA W. BUSH Deputy City Solicitor Dated: February 6, 1984

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Adm. Law Judge Lawrence Brenner Robert L. Anthony Atomic Safety & Licensing Board 103 Vernon Lane U.S. Nuclear Regulatory Commission Moyland, Pennsylvania 19065 Washington, D.C. 20555 Adm. Law Judge Richard F. Cole Phyllis Zitzer Atomic Safety & Licensing Board Limerick Ecology Action U.S. Nuclear Regulatory Commission P.O. Box 761 Washington, D.C. 20555 Pottstown, Pa. 19464 Adm. Law Judge Peter A. Morris Zori G. Ferkin Atomic Safety & Licensing Loard Assistant Counsel U.S. Nuclear Regulatory Commission Governor's Energy Council Washington, D.C. 20555 1625 North Front Street P.O. Box 8010' Harrisburg, Pa. 17125 Decketing & Service Section Frank R. Romano Of fice of the ' Secretary 61 Forest Avenue U.S. Nuclear Regulatory Commission Ambler, Pennsylvania 19002 Washington, D.C. 20555 Benjamin H..Vogler Gregory-Minor 0.E.L.D. NHB Technical Associates U.S. Nuclear Regulatory Commission 1723 Hamilton Avenue Washington, D.C.- '20555 San Jose, CA :95125 I

l Mark Wetterhahn,'Esq. . Eugene J. Bradley

[ Troy B. Conner, Jr., Esq. Philadelphia Electric Company i Nils N. Nicholas, Esq. - Associate' General Counsel l Conner and Wetterhahn 2301 Market' Street l =1747 Pennsylvania Avenue, N.W. Philadelphia, Pa. 19101

! Washington, D.C. 20006:

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i Edward G. Bauer, Jr.

Marvin I. Lewis Vice-President & General Counsel 6504 Bradford Terrace Philadelphia Electric Company Philadelphia, Pa.

2301 Market Street 19149 v

Philadelphia, Pa. 19101 l

i Mr. Vincent Boyer Senior Vice President Frederic M. Wentz County Solicitor  !

Nuclear Operations Philadelphia Electric Company County of Montgomery 2301 Market Street Courthouse Philadelphia, Pa. 19101 Norristown, Pa. 19404 I

i Mr. J.T. Robb, N2-1  !

Philadelphia Electric Company Angus Love, Esquire 2301 Market Street 101 East Main Street )

Philadelphia, Pa. 19101 Norristown, Pa. 19401 i Hon. Lawrence Coughlin House of Representatives Joseph H. White, III Congress of the United States 8 North Warner Avenue Washington, D.C. 20515 Bryn Mawr , Pa. 19010 Frank Hippart, Director, Pennsylvania Emergency Steven P. Hershey, Esq.

Management Agency, B-151- Community Legal Services, Inc.

In.asportation & Safety Building 5219 Chestnut Street Harrisburg, Pa. 17120 Philadelphia, Pa. 19139 Roger B. Reyncid, Jr., Esq.

324 Swede Street Robert L. Sugarman, Esq.

Norristown, Pa. Sugarman & Denworth 19401 Suite 510, North American Building-121 S. Broad Street Philadelphia, Pa. 19107 hm, . . ......,mi , . . .........-c- iii - - -- . a-

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4 Charles W. Elliot, Esq.

1101 Building Easton, Pa. 18042 Q

Jacqueline I. Ruttenberg Keystone Alliance 3700 Chestnut Street Philadelphia, Pa. 19104 Spence W. Perry, Esquire Associate General Counsel Federal Emergency Management Agency Room 840 500 C St:, S.W.

Washington, D.C. 20472 U.S.N.R.C. Region I 631 Park Avenue King of Prussia, Pa. 19406

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Thomas Gerusky, Director Bureau of Radiation Protection Dept. of Environmental Resources 5th Floor, Fulton Bank Bldg.

Third & Locust Streets Harrisburg, Pa. 17120 Atomic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i