ML19323J243
| ML19323J243 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 06/05/1980 |
| From: | Doggett S DOGGETT, S.A. |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8006190569 | |
| Download: ML19323J243 (11) | |
Text
.- +
i D CC? $ U
/,
g DOCKETED
,]
USNRc 3~l JUN 111980 -
Hd D.'."3$#J
.3 UNITED STATES OF AMERICA
\\
NUCLEAR REGULATORY COMMISSION
- 1.,
s1 %
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HOUSTON LIGHTING & POWER S
COMPANY G
Docket No. 50-466 5
(Allens Creek Nuclear S
4 Generating Station, Unit S
No. 1)
S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM STEPHEN A. DOGGETT AND W. MATTHEW PERREN0D TO HOUSTON LIGHTING & POWER COMPANY REGARDING CONSOLIDATED CONTENTIONS DOGGETT 4 AND PERREN0D 1 Preface Pursuant to Section 2.740b and 2.741 of the Commission's Rules of Practice, STEPHEN A. DOGGETT and W. MATTHEW PERREN0D, Intervenors propound the following Interrogatories and Requests for Production of Documents to HOUSTON LIGHTING & POWER COMPANY (hereinafter " Applicant").
Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person or persons making them no later than fourteen (14) days after service of these Interrogatories and Requests for Production, and each document recuested should be produced no later than thirty (30) days after service of these Interrogatorien and Requests for Production.
g O
. 8006190 ' 6 4 [
O
~
Interrogatories
~
1.
(a)
Identify each witness, other than an expert witness, who Applicant may call in this proceeding with respect to consolidated contentions Doggett 4 and Perrenod 1, and provide a summary of the testimony which each such witness is expected to offer.
(b)
Identify all documents upon which each such witness may rely in any way, and provide copies of any such documents.
2'.
(a)
Identify each expert witness who Applicant expects to call in this proceeding with respect to consolidated
/
contentioni Doggett 4 and Perrenod'l.
(b)
State the qualifications and credentials of each such expert witness.
(c)
Provide a summary of the testimony which each such witness is expected to offer.
(d)
State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.
(e)
Identify all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon by,such expert in-formulating the expert's opinions and conslusions, including work papers, preliminary outlines and memoranda, and communications between such expert
and Applicant.
Provide copies of any such documents.
3.
Applicant.has advertised that it estimates construction delays of the proposed Allens Creek Plant are costing $200 million a year and that to date the project has been delayed three years.
(a)
How was this $200 million per year figure calculated?
(b)
Who calculated this figure?
(c)
Has this cost figure been included in the plan for obtaining necessary funds to cover the estimated cost of contruction and related fuel cycle cost?
(d)
How doep Applicant define the word " delay" as used in its advertisements?
(e)
Does " delay" include Applicants' announcement of indefinate deferral of the Allens Creek project from September 15, 1975 to October 7, 1976?
(f)
Is any of the $200 million a year estimate attributable to increases in the cost of the quality assurance program of Applicant?
(g)
Is any of the $200 million a year estimate attributable to increases in the cost of the quality assurance program of Ebasco Services or General Electric Company?
4.
(a)
Have there been any cuts in the budgeted funding of Applicant's quality assurance for ACNGS program since inception.
4 of the Allens Creek Project.
(b)
Describe any changes in the number of quality assurance employees which have occurred since the inception of the Allens Creek Project.
5.
SER Supplement No. 2 p. 20-1 states that "the earliest date for commercial operation of the Allens Creek Nuclear Generating Station, Unit 1, is estimated to be March 1985."
Recent advertisements by Applicant list completion for ACNGS to be 1988.
(a)
What is Applicants current estimate of commerc'al
~
i operation?
(b)
Does Applicant believe the 3 years difference in estimated date of commercial operation requires reevaluation of its financial qualifications analysis in SER Supplement No. 2.
(c)
Please describe in detail any additional analysis which has been done by Applicant on the issue of financial l
qualifications.
(d)
List any documents which have been submitted to the NRC concerning financial qualifications since the preparation of SER published March, 1979.
(e)
Has applicant detected any change in the availability of viable capital markets referred to on p. 20-1 SER Supplement No. 2 since publication of same.
(f)
Has Applicant detected any change in rational
regulatory policies referred to on p. 20-1 SER Supplement No.
2 since publication of same.
(g)
Has Applicant revised its analysis to take into account increased interest rates for borrowed funds?
(h)
Has there been any significant change in Applicant's ability to sell common stock since publication of SER Supplement No. 27 6.
What was the reason or reasons for Applicant's "indefinate deferral" of Allens Creek Project in 1975-1976?
7.
List and describe in chronological order any and all changes in design, in materials used, or in modes or method of construction, whichrhave been attempted since the publication of SER in November, 1974 with the primary purpose of decreasing costs?
8.
List and describe in chronological order any add all changes in design, in materials used, or in mades or method of construction made since publication of SER in November, 1974 which in the opinion of Applicant have resulted inJdecrease in cost or cost savings to Applicant.
9.
Does applicant have any system or unit charged with responsibility for monitoring safety problems of already existing nuclear generating stations of same or similar design to ACNGS or with same as similar components as ACNGS?
10.
If the answer to question 9 is no, is-the reason for not having-such a system or unit based on costs considerations.
11.
Report of The President's Commission on The Accident at Three Miles Island, October, 1979 states on p. 44:
" Met Ed had a plan for a quality assurance program that met NRC requirements.
The NRC requirements, however, were inadequate because they did not require quality assurance programs to be applied to the plant as a whole, but rather only to systems classified as ' safety-related'.....The NRC did not require the level of independent review (i.e., outside of line management) normally found in quality assurance programs of safety-critical industries."
(a)
Does Applicant's quality assurance program apply to the ACNGS pla6t as a whole or only to systems classified.
as " safety-related?"
(b)
If the answer to 11 (a) is no, is the reason for not having such a program based on costs considerations?
(c)
Does Applicant's quality assurance program provide for periodic independent audits (that is, outside HL&P, EBASCO, or General Electric Company) of the effectiveness of the quality assurance program.
(d)
If the answer to lle is no, is the reason for not having such a program based on cost considerations?
(e)
Has Applicant budgeted sufficient funds to employ enough inspectors to do the inspections required under the present quality assurance plan for ACNGS? '
L
(f)
Has Applicant budgeted funds to require reporting, resolution, and trending of problems which are not classified as " safety-related" for_ACNGS?
12.
Has Applicant stated in advertising published in April, 1980 that... during the 1980's we'll be challenged by a multitude of problems.
Problems that threaten our ability to provide reliable service. Problems so serious that we can't guarantee you that you won't run short of electricity during the next few years - despite the biggest construction program in our company's history"?
13.
How does the STNP quality assurance program differ from the ACNGS qualitypassurance program?
14.
Does Applicant believe quality control problems at STNP have been caused by the project contractor's emphasis of higher work production and lower costs at the expenses of quality control?
j 15.
What measures are included in the ACNGS quality assurance program to prevent or remedy threatening or harrassment of quality control inspectors by construction personnel?
16.
The following interrogatories refer to Applicant's i
Response to Baker's First Set of Interrogatories to Applicant.
(a)
Regarding Applicant's answer to Baker Interro-gatory 1 (b), could the term " construction" be construed to possibly_ include ACNGS? *
(b)
Regarding Applicant's answer to Baker Interrogatory 4 (b):
(1) has Applicant contacted any insurance companies regarding coverage; (2) does Applicant have a current estimate as to the extent of coverage which will be available at the time of operation of ACNGS; (3) define the words "other insurance" used in the answer.
(c)
Regarding Applicant's answer to Baker Interro-4 gatory 5, has Applicant " speculated" or attempted to make calculations as to what its costs may be under alternative waste disposal programs and if so, what was the result of suc'h speculation?
- 17.. List and describe what steps Applicant has taken or will take to insure that it will not engage in substandard construction practices at ACNGS in the event it ever experiences a shortgage of funds?
18.
What has the cost of such steps been?
19.
List and describe what steps Applicant has taken or will take to insure that it will not engage in substradsrd construction practices at STNP in the event it ever experiences a shortage of funds?
20.
What has the cost of such steps been?
21.
SER Supplement No. 2 Mar,1979, p. 20-1 states that total nuclear production. plant costs including transmission, distribution, and general plant costs estimate is $1,055,000.
d 9
Applicant's answer to Baker Interrogatory 2 states that the most current estimate of final construction costs to be
$1,484,783,000, which estimate was made in January, 1980.
(a) does this most current estimate include transmission, distribution, and general plant costs?
(b) does the most current estimate include the same factors as the SER Supplement No. 2 estimate.
(c). was the SER Supplement NO.2 estimate prepared by the Project Management Department?
(d)
Explain why Applicant's estimates made approx-
~
imately one year apart differ by almost $430 million dollars or almost 1/3 of the durrent estimated cost.
(e)
How of ten does Applicant review or revaluate its costs estimate for ACNGS?
Respectfully submitted, 06.
kC t
Stephen A. Doggett l
_e_
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION p
BEFOR'E THE ATOMIC SAFETY AND LICENSING BOARD
\\
- geegg7g,
'Tro In the Matter of S
IgJ JUN 1119$0 c
HOUSTON LIGHTING & POWER S
LiJ!Fff COMPANY S
Docket No. 50-466 k
GJ 17^"JJ S
N (Allens Creek Nuclear S
9 SM./
Generating Station, Unit S
No. 1)
S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing First Set of Interrogatories and Requests for Production of Documents from STEPHEN A. DOGGETT sad W. MATTHEW PERREN0D to HOUSTON LIGHTZNG & POWER COMPANY in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this SIru day of June, 1980.
(
Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.
Atomic Safety and Licensing : 1 Assistant Attorney General Board Panel for the State of Texas i
U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D.C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P.O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D.C. 20555 P.O. Box 99 Bellville, Texas 77418 Mr. Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of-the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Cocmission Washington, D.C, 20555 Washington, D.C.
20555 R. Gordon Gooch, Esq.
Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N.W.
U.S. Nuclear Regulatory Washington, D.C.
20006 Commission Washington, D.C.
20555
Steve Schinki, Esq.
D. Marrack Staff Counsel 420 Mulberry Lane U.S. Nuclear Regulatory Commission Bellaire, Texas 77401 Washington, D.C, 20555 Mr. J. Morgan Bishop Mr. Bryan L. Baker 11418 Oak Spring 1118 Montrose Houston, Texas 77043 Houston, Texas 77019 Mr. John F. Doherty Robert S. Framson 4327 Alconbury Madeline Bass Framson Houston, Texas 77021 4822 Waynesboro Houston, Texas 77035 Ms. Brenda McCorkle 6140 Darnell Mr. W. Matthew Perrenod Houston, Texas 77074 4070 Merrick Houston, Texas 77025 Mr. Wayne E. Rentfro P.O. Box 1335 Mr. James M. Scott Rosenberg, Texas 77471 13935 Ivy Mount Sugar Land, Texas 77478 Mr.F. H. Potthoff 7200 Shady Villa,No. 110 Carro Hinderstein e
Houston, Texas 77080 609 Fannin, Suite 521 Houston, Texas 77002 i
' hsiw l
3TEPHEN A. DOGGETT
. _. _ _