ML20010B281
| ML20010B281 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/10/1981 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE, UNION ELECTRIC CO. |
| To: | JOINT INTERVENORS - CALLAWAY |
| References | |
| ISSUANCES-OL, NUDOCS 8108140318 | |
| Download: ML20010B281 (41) | |
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IMM ColutwoADENCE August 10, 1981 p
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION t
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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UNION ELECTRIC COMPANY
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Docket No. STN 50-48' y po,,
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APPLICANT'S INTERROGATORIES AND REQUESTS FOR DOCUMENT PRODUCTION (SET NO.2) 4 TO JOINT INTERVENORS ON THEIR CONTENTION NO. 1 s /*,zT\\ &
v Applicant UNION ELECTRIC COMPANY hereby requests that each of the Joint Intervenors COALITION FOR THE ENVIRONMENT, ST.
LOUIS REGION; MISSOURIANS FOR SAFE ENERGY; and the CRAWDAD ALLIANCE, pursuant to 10 CFR SS2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce and permit inspection 4
and copying of the original or best copy of all documents identified in the responses to interrogatories below, and that subsequent to filing answers to these interrogatories and pro-ducing documents therein identified, Joint Interven6rs file supplemental responses and produce additional documents as required by 10 CFR S2.740(e).
As set forth in the Special Pre-Hearing Conference Order of April 21, 1981, responses to these discovery requests are due no later than September 10, W>
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B108140318 810810 DR ADOCK 05000483 PDR
. 1981; objections to interrogatories or the production of docu-ments are to be served within fourteen (14) or thirty (30) days, respectively, of the date of service of these requests.
It will be acceptable if the Joint Intervenors choose to file a joint response to these requests provided the.t such responses include all information and all documents in the possession, custody or control of any of the Joint Intervenors.
Where iden'tification of a document is requested, briefly describe the document (e.g., book, letter, memorandum, report) and state the following information as applicable for the par-ticular document:
name, title, number, author, date of publi-cation and publisher, addressee, date written or approved, and the name and address of the person (s) having possession of the docu-ment.
As used in these discovery requests the term " document (s)"
includes publications of any format, letters, memoranda, notes, I
reports, analyses, test results or data, recordings, transcrip-tions and printed, typed or written materials of every-kind in the possession, custody or control or within the knowledge of any of the Joint Intervenors or their counsel.
Joint Intervenors' Contention No. lA (Embedded Plates) l 1A-18.
Does Kay Drey have first-hand knowledge of the factual basis for any of the allegations in your Contention i
No. lA?
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,, 1A-19.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person known to you to have first-hand knowledge of the facts alleged in your Contention No. lA.
lA-20.
Did Kay Drey provide any information and/or documents used in your responses to Interrogatory Nos. lA-1 through.n-17?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogatory and identify the information and/or documents provided by Kay Drey used in the response to such interrogatory.
lA-22.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person who provided infor.nction and/or documents used in your responses to Interrogatory Nos. lA-1 through 1A-17, and indicate for each such person the interrogatories for which he or she provided such information and/or documents.
lA-23.
Did Kay Drey prepare any of the Joint Intervenors' responses to Interrogatory Nos. lA-1 through 1A-17?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogatory response.
4-1A-25.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person who prepared any of the Joint Intervenors' responses to Interrogatory Nos. lA-1 through 1A-17, and indicate for each such person the interrogatory responses which he or she prepared.
lA-26 (a).
State the factual basis for the allegation in your response to Interrogatory No. lA-6(a) that Union Electric did not act upon the suggestion of the NRC to identify the location of the 480 plates.
(b)
Identify all documents you rely upon to support this allegation.
(c)
Stata the name, prescat or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job t>tle, specialty, professional qualifications, etc. ) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
lA-27(a)
State the factual basis for the allegation in your Contention No. lA and in your response to Interrogatory No.
lA-ll(a) that the four (4) exceptions listed in such response were " improperly determined" to be allowable.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualificacions, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of euch person you intend to call as a witness to support this allegation.
lA-28(a)
State the factual basis for the allegation in your response to Interrogatory No. lA-12 (a) that "[alpparently there was no inspection or testing of those [ embedded plates]
already installed prior to [the issuance of the stop work order]."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you
. to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
lA-29(a)
Explain fully and state the factual basis for the allegation in your response to Interrogatory No. lA-12 (a) that "[f]ive load tests should have been performed in order to apprcximate the actual stress that these embeds must eventually bear."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(u)
State the name of each person you intend to call i
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. as a witness to support this allegation.
lA-30(a)
Explain fully and state the factual basis for the allegation in your response to Interrogatory No. lA-12(a) that "if some of the machine-welded plates were not loaded, no valid oasis existed for their evaluation."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you l
to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by empicyer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
State fully the factual basis for the allegation in your response to Interrogatory No. lA-12(a) that "[olnly six out of 255 machine welded plates installed prior to June 9,
1977 were inspected."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you
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to have first-hand knowledge of the factual-basis for this allegation.
If you object to providing such information for
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any such person,. identify such person generically (i.e.,
by employer or description of employer, job title, specialty, l
professional qualifications, etc.) with as much specificity i
as you find non-objectionable.
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(d)
State the name of each person you intend to call as a witness to support this allegation.
Please respond in greater detail and with greater specificity to Interrogatory 1A-12 (e) through (h), including listing individually the inspections and/or tests you contend should have been performed and the specific factual basis for i
each such contention.
j lA-33.
Please respond in greater detail and with-greater, specificity to Interrogatory No. lA-14(b) and' (c), providing j
(as previously requested and not provided) the factual basis for your allegation of a failure in the quality assurance pro-gram, the specific nature and degree of such alleged failure, and the specific documentr. which support this allegation.
Please respond in~ greater detail.and with greater specificity to Interrogatory No. lA-15(b) and (c), providing (as previously requested and not provided) the factual basis for your allegation of an effect on-the safe operation of the l
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Callaway Plant, the specific manner and degree in which such safe operation will allegedly be affected, and the specific documents which support this allegation.
Joint Interver. ors' Contention No. 1B (Concrete Cracks) 1B-12.
Does Kay Drey have first-hand knowledge of the factual basis for any of the allegations in your Contention No. 1B?
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person known to you to have first-i hand knowledge of the facts alleged in your Contention No.
j 1B.
Did Kay Drey provide any information and/or documents used in your responses to Interrogatory Nos. 1B-1 through 1B-ll?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogatory and identify the information and/or documents provided by Kay Drey used in the response to such interrogatory.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person who provided information l
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and/or documents used in your respcnses to Interrogatory Nos. 1B-1 through?lB-ll, and indicate for each such person the interrogatories for which he or she provided such information and/or documents.
Did Kay Drey prepare any of the Joint Intervenors' responses to Interrogatory Nos. 1B-1 through 1B-ll?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such l
1 interrogatory response.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, eacn person who prepared any of the Joint Intervenors' responses to Interrogatory Nos. 1B-1 through 1B-ll and indicate for..each such person the interrogatory responses which he or she prepared.
What affirmative facts or other information, if any, do you have (beyond the nonresponsive reply to Interrogatory No. 1B-6 (a) ) to support your allegation that the crack in the reactor cavity moat area will affect the safe operation of the Callaway Plant, specifying, in detail, the manner and degree in which such safe operation will allegedly be affected.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and
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. present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc. ) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
State the factual basis for the allegation in your response to Interrogatory No. 1B-6 (a) that there was a
" failure to discover and inspect the crack (in the reactor cavity moat areal in a timely manner."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and i
l present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
l (d)
State the name of each person you intend to call l
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' as a witness.to support this allegation.
What affirmative facts or other information, if any, do you have-(beyond the nonresponsive reply to Interrogatory No. 1B-7 (a) ) to. support your allegation that the crack in the
" north wall" of the Control Building will affect the safe operation of the Callaway Plant, specifying, in detail, the manner and degree in which such safe operation will allegedly l
be affected.
I (b)
Identify all documents you rely upon to support thie allegation.
(c)
State the name, present or last known address,-and 7 esent or last known employer of each person known to you t
to have first-hand knowledge of the factual basis for this i
allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
State.the factual basis for the allegation in yourresponsetoInterrogakoryNo.1B-7(a) that "UE's-quality assurance personnel overlooked the crack (in the Control Building ' north wall'] and allowed the next lift to be poured on top."
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(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or.last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically _(i.e.,
by employer or description of employer, job title, specialty, a
professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
State the factual basis for the allegation in your response to Interrogatory No. 1B-8(a) that "[cloncrete was poured over the crack with'out its being reported by quality assurance personnel."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known,to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity i
as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
Joint Intervenors' Contention No. 1C (Honeycombing) 1C-13.
Does Kay Drey have first-hard knowledge of the factual basis for any of the allegations in your Contention No. 1C?
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person known to you to have first-hand knowledge of the facts alleged in your Contention No. 1C.
Did Kay Drey provide any information and/or i
documents used in your responses to Interrogatory Nos. 1C-1 through IC-12?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogatory and identify the information and/or documents provided by Kay Drey used in the response to such interrogatory.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person who provided information
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. and/or documents used in your responses to Interrogatory Nos. 1C-1 through 1C-12, and indicate for each such person the interrogatories for which he or she provided such information and/or documents.
Did Kay Drey prepare any of the Joint Intervenors' responses to Interrogatory Nos. 1C-1 through 1C-127 1C-19.
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogecory response.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person who prepared any of the Joint Intervenors' responses to Interrogatory Nos. 1C-1 through 1C-12, and indicate for each such person the interrogatory responses which he or she prepared.
l 1C-21(a)
State the factual basis for ::he allegation in your response to Interrogatory No. 1C-6(b) that "[t]he design of the base mat may have called for an overcongestion of rein-forcing steel, contrary to Criterion III of Appendix B and to General Design Criterion I of Appendix A of Part 50," specifying, in detail, the nature and degree of the alleged deviation from the requirements of the referenced Criteria.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or.last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.-
(d)
State the name of each person you intend to call as a witness to cupport this allegation.
State the factual basis for the allegation in your response to Interrogatory No.'1C-6(b) that " [t]he concrete pour was not monitored properly, contrary ~ to the monitoring instructions and procedures, contrary to Criterion X of Appendix B," specifying, in detail, the nature and degree of the alleged deviation from the requirements of the referenced Criterion.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each persan known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, l
a-professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
State the factual basis for the allegation in your response to Interrogatory No. 1C-6(b) that "[s]oniscope i
examination of a sample of.
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. may be contrary to criterion X of Appendix B," specifying, in detail, the nature and degree of the alleged deviation from the requirements of the referenced Criterion.
(b)
Identify all documents you rely upon to support this allegation.
l (c)
State the name, present or last known address, and l
present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object.to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
L (d)
State the name of each person you intend to call as a witness to support this allegation.
l 1C-24 (a)
State the factual basis for the allegation in your response to Interrogatory No. 1C-6(b) that "[r]epair work was in progress before the NCR covering the same was J
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. approved," specifying the exact nature and location of the referenced " repair work" and the number of the referenced NCR.
(b)
Identify all documen'.3 you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
What affirmative facts or other information, if any, do you have (beyond the nonresponsive reply to Interrogatory No. 1C-7 (b) ) to support your allegation that the honeycombing in the tendon access gallery will affect the safe operation of the Callaway Plant, specifying, in detail, the manner and degree in which such safe operation will allegedly be affected.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you
. to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
Do you contend that th'ere was any cold joining 1
(improper bonding) in the concrete of the reactor base mat due to the drying (setting up) of concrete in certain areas before additional concrete was poured on top?
If the answer to the preceding interrogatory is affirmative, or other than negative, provide the following information:
(a)
State the factual basis for such allegation.
(b)
Identiij all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and l
present or last known employer of each person known-to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty,
. professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
State the factual basis for the allegation in your response to Interrogatory No. 1C-9 (b) that "[flaults in the concrete of the dome could easily compromise this function (' boundary designed to contain radioactive materials'],
allowing radioactive materials to escape to the environment."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generl.cally (i.e.,
by emt,loyer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
Joint Intervenors' Contention 1D (Concrete Coverage) 1D-10.
Does Kay Drey have first-hand knowledge of the factual basis for any of the allegations in your Contention
. No. 1D?
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person known to you to have first-hand knowledge of the facts alleged in your Contention No. 1D.
Did Kay Drey provide any information and/or documents used in your responses to Interrogatory Nos. 1D-1 through 1D-9?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogatory and identify the information and/or docceents provided by Kay Drey used in the response to such interrogatory.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) rith as much specificity as you find non-objectionable, ea<n person who provided information and/or documents used in your responses to Interrogatory Nos.1D-1 through 1D-9, and indicate for each such person the interrogatories for which he or she provided such information and/or documents.
Did Kay Drey prepare any of the Joint Intervenors' responses to Interrogatory Nos. 1D-1 through 1D-9?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such
. interrogatory response.
Identify generically (i.e., by employer or l
description of employer, job title, specialty, professional I
qualifications, etc.) with as much specificity as.you find non-objectionable, each person who prepared any of the Joint l
Intervenors' responses to Interrogatory Nos. 1D-1 through 1D-9, and indicate for each such person the interrogatory responses which he or she prepared.
Does the term " requirements" used in the first
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sentence of your response to Interrogatory No. 1D-6(b) refer to the requirements set forth in Bechtel Specification No. 10466-Cll2 (Q), Revision 9 and ACI 318-71 Section 7.3.2 or does _it l
refer to the interpretation of such requirements by the NRC?
1D-19 (a)
State the factual basis for the allegation in your response to Interrogatory No. 1D-6(b) that " requirements for concrete cover were either ignored or grossly misunderstood."
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l (b)
Identify all documents you rely upon to support i
this allegction.
(c)
State the name, present or last known address, and present or last known employer of each person known,to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for i
any such person, identify such person generically (i.e.,
i by employer or description of employer, job title, specialty, i
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- professional qualifications, etc. ) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
On what date do you contend the NRC " indicated to the Applicant that the NRC's interpretation of the require-ments must prevail"?
At what point in the construction process (i.e., at what lift) do you contend that the NRC's interpretation of the concrete coverage requirement was to " prevail" as that term is used in your response to Interrogatory No. 1D-6(b)?
State the factual basis for your contentions set forth in response to Inteirogatory Nos. 1D-20 and 1D-21.
(b)
Identify all documents you rely upon to support these contentions.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for these contentions.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call
as a witness to support these contentions.
In reference to the allegation in your response to Interrogatory No. 1D-6(b) that " numerous instances of failure to meet the requirements were found," whose interpre-tation of the requirements are you referring to?
What affirmative facts or other information, if any, do you have (beyond the nonresponsive reply to Interrogatory No. 1D-7(b)) to support your allegation.that the alleged failure of concrete coverageto " adhere to requirements" will affect the safe operation of the Callaway Plant, specifying, in detail, the manner and degree in which such safe operation will allegedly be affected.
Joint Intervenors' Contention No. lE (Piping) lE-20.
Does Kay Drey have first-hand knowledge of the factual basis for any of the allegations in your Contention No. lE?
lE-21.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person known to you to have first-hand knowledge of the facts alleged in your Contention No. lE.
lE-22.
Did Kay Drey provide any information and/or 4
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documents used in your responses to Interrogatory Nos. lE-1 through lE-19?
lE-23.
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogatory and identify the information and/or documents provided by Kay Drey used in the response to such interrogatory.
lE-24.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person who provided information and/or documents used in your responses to Interrogatory Nos. lE-1 through lE-19, and indicate for each such person the interrogatories for which he or she provided such information and/or documents.
l lE-25.
Did Kay Drey prepare any of the Joint Intervenors' responces to Interrogatory Nos. lE-1 through lE-197 l
lE-26.
If the answer to the preceding interrogatory is t
affirmative or other than negative, identify each such interrogatory response.
lE-27.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualitications, etc.) with an much specificity as you find non-objectionable, each person who prepared any of the Joint
Intervenors' responses to Interrogatory Nos. lE-1 through lE-19, and indicate for each such person the interrogatory responses which he or she prepared.
lE-28.
Identify and provide documentation for any other alleged instances of whic'i you have knowledge of safety-related SA 358 piping containing " poor fusion" (surface overlap) and/or
" excess inside reinforcement" as referred to in your response to Interrogatory No. lE-6 (r).
lE-29.
The NRC Inspection and Enforcement Report No.
50-483/81-04, referenced in Joint Intervenors' responses to Interrogatories 1E-8, lE-9, 1E-ll, lE-12, and lE-13, states that, with respect to the SA 358 piping in the accumulator discharge tank, "[t]he visual inspections, measurements, and radiographic review of the pipe performed during this investi-gation indicate that the pipe piece presently meets all ASME Code requirements and is acceptable."
Do you contend that this statement is maturially inaccurate?
lE-30.
If the answer to the preceding interrogatory is affirmative, or other than negative, provide the following information:
(a)
State the factual basis for such allegation.
l (b)
Identify all documents you rely upon to support l
this allegation.
(c)
State the name, present or last known address, and l
present or last known employer of each person known to you l
i
a
. to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as.much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
Do you contend that the surface overlap condition or the excess inside reinforcement on the SA 358 piping referenced on Deficiency Report 2SD-0699-P adversely affects the structural integrity of such pipe?
lE-32.
If the answer to the preceding interrogatory is affirmative, or other than negative, provide the following information:
(a)
State the factual basis for such allegation.
(b)
Identify all documents you rely upon to support l
this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known,to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, 1
m professional qualifications, etc.) with as much specificity as you find non-objection.'b'.:.e.
(d)
State the name of each person you intend to call as a witness to support this allegation.
lE-33(a)
State the factual basis for the allegation in your response to Interrogatory No. lE-9 (a) (3) that "[e]ven though the defective area has been ground and no visible defects remain, the structural integrity of the [SA 358] pipe has not been fully investigated or established."
(b)
Identify all documents you rely upon to support this allegation.
(c)
Etate the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allagation.
lE-34 (a)
State the factual basis for the allegations in your responses to Interrogatory Nos. lE-9 (a) (3) and lE-13(b) 1 that "[t]he appearance of the inside weld indicates that the original inside weld was melted through by a pass made from
the outside," including the name, address and professional qualifications of any individual who has given an opinion to this effect.
(b)
Identify all documents you rely upon to support i
this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this alleg'a' tion.
If you object to providing such information for any such person, identify such person generically (i. e.,
by employer or description of employer, job title, specialty, nrofessional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
lE-35(a).
State the factual basis for the allegation in your responses to Interrogatory Nos. lE-9 (a) (3) and lE-13(b) that "[dlefects of a similar nature may exist in other safety-regulated SA 358 pipe and remain unidentified."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for
~
- 30 any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc. ) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call l
as a witness to support this allegation.
l lE-36(a)
State the factual basis for the allegation in your response to Interroge. tory lE-9 (a) (3) that "[ilt is not the responsibility or obligation of craft personnel to identify nonconformances or deficiencies."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for l
any such person, identify such person generically (i.e.,
l by employer or description of employer, job title, specialty, professional qualifications, etc. ) with as much specificity l
l as you find non-objectionable.
1 (d)
State the name of each person you intend to call as a witness to support this allegation.
lE-37.
Joint Intervenors, in response to Interrogatory lE-ll, reference Nonconformance Report 2SN-0496-P as the basis for their allegation that a section of SA 358 pipe in the
. accumulator discharge tank "was substantially out-of-round."
The NRC Inspection and Enforcement Report No. 50-382/81-04, which documents the investigation of this allegation, states that
"[v]isual inspections and measurements of the pipe show acceptable ovality."
Do you contend that this statement is materially inaccurate?
lE-38.
If the answer to the preceding interrogatory is affirmative, or other than negative, provide the following informations (a)
State the factual basis for such allegation.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and l
present or last known employer of each person known to you l
to have first-hand knowledge of the factual basis for this l
l allegation.
If you object to providing such information for 1
any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
lE-39(a)
What facts or other information, if any, do you have to support the allegation in your response to 1
- Interrogatory No. lE-9 (a) (1) (a) that "CLP at Callaway may exceed the 26% ' worst case' cited in the Bechtel report, or it may even equal or exceed the 60% critical defect size."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to hava first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title,. specialty, professional qualifications, etc.) with as much specificity as yoa find non-objectionable.
(d)
State the name of each person you intend to call l
as a witness to support this allegation.
State the factual basis for the allegation in l
your response to Interrogatory No. 1E-9 (a) (1) (c) that " [t]he recommendations given in the Bechtel report, page 4, seek to give a substitute assurance of integrity and quality that is not consistent with Section III and may be considered perverse to Section III."
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and l
present or last known employer of each person known to y;u l
r
- to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
i (d)
State the name of each person you intend to call as a witness to support this allegation.
lE-41.
Joint Intervenors' responses to Interrogatory Nos.
1E-8(a) and lE-9 (a) (1) assert that the evaluation performed by Bechtel of SA 312 piping in response to IE Bulletin 79-03 should have included a flattening test.
The Certified Material Test Reports of SA 312 pipe manufactured by Youngstown Welding t Engineering Co. for use at the CAllaway plant, produced by Applicant pursuant to Joint Intervenors' Document Request No. 50, indicate that all such piping met the ASME Code f
flattening test criteria.
Do you contend that it was T.ecessary for Bechtel to conduct additional flattening test:. 14 order j
to meet the ASME Code criteria?
l lE-42.
If the answer to the preceding interrogatory is affirmative, or other than negative, provide the following information:
(a)
State the factual basis for such allegation.
(b)
Identify all documents you rely upon to support
U
' this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
lE-43.
Do you contend that post-accident irradiation in the RHR system at the Callaway Plant will affect the mechanical properties (including ductility) of SA 312 piping containirs l
centerline lack of penetration?
lE-44.
If the answer to the preceding interrogatory is affirmative, or other than negative, provide the following information:
(a)
State the factual basis for such allegation.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such information for
. any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc. ) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
lE-45.
What type of radiation do you contend would be experienced in the RHR system under post-accident conditions?
lE-46.
As to your response to the preceding interrogatory, provide the following information:
(a)
State the factual basis for such contention.
(b)
Identify all documents you rely upon to support this contention.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this contention.
If you object to providing such information for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much spe,cificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this contention.
. lE-47.
Do you contend that CLP in SA 312 piping at the Callaway Plant exceeds 26 percent of wall thickness?
lE-48.
If the answer to the preceding interrogatory is affirmative, or other than negative, provide the following information:
(a)
State the factual basis for such allegation.
(b)
Identify all documents you rely upon to support this allegation.
(c)
State the name, present or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the factual basis for this allegation.
If you object to providing such infermation for any such person, identify such person generically (i.e.,
by employer or description of employer, job title, specialty, professional que'ifications, etc. ) with as much specificity as you find non-objectionable.
(d)
State the name of each person you intend to call as a witness to support this allegation.
Joint Intervenors' Contention No. 1F (Pre-Assembly Piping Formations)
'l 1F-12.
Does Kay Drey have first-hand knowledge of the factual basis for any of the allegations in your Contention No. 1F?
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person known to you to have first-hand knowledge of the facts alleged in your Contention No. 1F.
Did Kay Drey provide any information and/or documents used in your responses to Interrogatory Nos. 17-1 through 1F-ll?
If the answer to the preceding interrogatory is affirmative or other than negative, identify each such interrogatory and identify the information and/or documents provided by Kay Drey used in the response to such interrogatory.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable, each person who provided infornation and/or documents used in your responses to Interrogatory l
Nos. 1F-1 through 1F-ll, and indicate for each such person the interrogatories for which he or she provided such information l
and/or documents.
Did Kay Drey prepare any of the Joint Intervenors' responses to Interrogatory Nos. 1F-1 through 1F-ll?
If the answer to the preceding interrogatory is affirmative or other than negative identify each such
_ ~
1 i interrogatory response.
3 1F-19.
Identify generically (i.e., by employer or description of employer, job title, specialty, professional ~
qualifications, etc.) with as much specificity as you find non-objectionable, each person who prepared any of the Joint Intervenors' responses to Interrogatory Nos. 1F-1 through 1F-ll, and indicate for each such person the interrogatory responses which he or she prepared.
4 General Interrogatories Pertaining To Contention Nos. lA Through 1F F.
State the name, title or position, address and employer of each person who provided information used in preparing responses to any of the foregoing interrogatories.
If you object to.
providing such infcrmation for any such person, identify such i
person generi' ally (i.e., by employer or description of employer, l
c
. job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
G.
For each person identified in response to the preceding interrogatory, state the numbers of the interrogatories for which information was supplied.
H.
State the name, title or position, address and employer of each person who searched for doc,";nts in order to respond to any of the foregoing requests for identification and pro-duction of documents.
If you object to providing such information for any such person, identify such person generically (i.e.,
L
. by employer or description of employer, job title, specialty, professional qualifications, etc.) with as much specificity as you find non-objectionable.
I.
For each person identified in response to the pre-ceding interrogatory, state the numbers cf the discovery requests for which the search was conducted and the location where the search was conducted.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE i
1 J
By:
Thomas A. Ba'xter Richard E. Galen Counsel for Applicant 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated:
August 10, 1981 l
l l
l l
t
g 10miTED cc '!iwohnt a-c) l A
/,R> ).
P r-UNITED STATES OF AMERICA
~:
c9' NUCLEAR REGULATORY COMMISSION l
AUG111981t* ;
E-Omce of the L anf )t/
p;;n92 x ImW a T
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD q,
E:rch
/
- G y In the Matter of
)
)
UNION ELECTRIC COMPANY
)
Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Interrogatories and Requests for Document Production (Set No. 2) to Joint Intervenors on Their Contention No. 1" and Applicant's Interrogatories and Requests for Document Production (Set No. 2) to Joint Intervenors on Their Contention No.
2" were served this 10th day of August, 1981 by deposit in the U.S. mail, first class, postage pre-paid, to the parties identified on the attached Service List, be Richard E. Galen
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
~
UNION ELECTRIC COMPANY
)
Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1)
)
SERVICE LIST James P. Gleason, Esquire Kenneth M. G ackes, Esquire CMiman Chackes and Hoare Atomic Safety and Licensing Boc.rd 314 N. Broadway 513 Gilnoure Drive St. Iouis, Missouri 63102 Silver Spring, Maryland 20901 Mr. John G. Reed Mr. Glenn O. Bright Ibute 1 Atcznic Safety and Licensing Kingdczn City, Missouri 65262 Board Panel U.S. Nuclear Regulatory Ccmrission Mr. Howard Steffen Washington, D.C.
20555 Gamois, Missouri 65024 Dr. Jerry R. Kline Mr. Harold Iottmann Atomic Safety and Licensing Ibute 1 Board Panel Owensville, Missouri 65066 U.S. Nuclear Regulatory N ission Washington, D.C.
20555 Mr. Earl Brown P.O. Box 146 Roy P. Iessy, Jr., Esquire Auxvasse, Missouri 65231 Office of the Executive Iagal Director U.S. Nuclear Regulatory Ccmnission Mr. Fred Luekey Washingtcn, D.C.
20555 Rural Boute Rhineland, Missouri 65069 Docketing and Service Section Office of the Secretary Mr. Samuel J. Birk U.S. Nuclear Regulatory Comnission P.O. Box 243 Washingtcn, D.C.
20555 bbrrison, Missouri 65061
, Joseph E. Birk, Esquire Mr. Robert G. Wright Assistant to the General Counsel Ibute 1 Union Electric Coupany Fulton, Missouri 65251 P.O. Box 149 St. Iouis, Missouri 63166 Eric A Eisen, Esquite Birch, Horton, Bittner & tbnroe Treva J. Hearne, Esquire 1140 Cbnnecticut Avenue, N.W., #1100 Deputy General Counsel Washington, D.C.
20036 Missouri Public Service Ccm-ission P.O. Box 360 Jefferson City, Missc7rij5102
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