ML19329F727
| ML19329F727 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/13/1980 |
| From: | Sinkin L COMMITTEE FOR APPLICATION OF NUREMBERG PRINCIPLES |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8007110001 | |
| Download: ML19329F727 (9) | |
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~ NUCLEAR REGL'LATORY COMMISSION "[ JUN1 9 N00 P [7 CV CY.cs at t'.a Se7s*f BEFORE THE ATOMIC SAFETY AND llCENSING BOARD, P+.2M.a in;*
in the Matter of $ - E g 'mili HOUSTON LIGHT!NG AND POWER Docket Nos. 50-498 COMPANY, E T. AL.
50-499 -
4 (South Texas Project {
- Units I and 2)
ANSWERS OF CITIZENS CONCERNED ABOUT NUCLEAR POWER. INC. TO NRC STAFF INTERROGATORIES T0, AND REQUEST FOR 00CUMENTS FROM, '
CITIZENS CONCERNED ABOUT NUCLEAR POWER PREFACE The staff of the Nuclear Regulatory Commission submitted interrogatories to Citizens Concerned About Nuclear Power in .,
November, 1979. During the same period of time, CCANP received interrogatories from the Applicants.
In December, 1979, CCANP submitted answers to the inter-rogatories from the Applicants with a prefatory note that: s..
"Each set of interrogatories requests ' essentially ,
the same information. Therefare, CCANP submits the following answers to both sets of interrogatories Should the Nuclear Regulatory Commission staf f find this procedure unacceptable and so inform CCANP, CCANP will resubmit answers in conformance with the form of the NRC interrogatories."
Subsequently, the NRC staff informed CCANP that they would like to have answers to their interrogatories.
In reviewing once again the questions of the NRC staff.
CCANP again reaches the conclusic' that the questions are essentially answered in either the answers to Applicants first interrogatories, hereinafter referred to as Applicants' First hereinafter or the answers to Applicants second interrogatories, referred to as Applicants Second. CCANP, therefore, references herein the answers to the Applicants' interrogato-ries which answer the NRC staff interrogatories.
ANSWERS TO f1 TERR 0GAf 0 RIES 1
1-1 a Upon wha person or persons do you rely to substantiate your case on Contention 1.
- 1. On the surorying error, CCANP relies upon Turner, Vice Presider t. Power Plant Construction & Technical E. A. A i
Services. Houston Lighting and Power Company. ,,
- 2. On the extins ive voids, CCANP relies upon C. W. Oprea , l' Jr.
Company.
, Executive Viae President, Houston Lighting and Power 1" L
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- 3. On the lost field document relating to cadweld inspec- .
tien, CCANP relles on Mssrs. R.
E. Hall and A. B. Rosenberg ]
of Texas. the Nuclear Ragulatory Commissioa :!3ff in Arlington, g
. T l 4 On the membrane damage, CCANP relies upon Mr. Daniel I E. Swayze and upon the Non-Conformance Reports at the South h h; Texas Nuclear 'roject. " '
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_ . . 4 5. On the missing reinforcement bars CCAMP relies upon
""N Mr. Daniel E. Swayze and upon the Non-Conformance Reports at w the South Texas Nuclear Project. ,
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- 6. On the cadwelds not capable of being verified. CCANP --- o relies upon Mr. Daniel E. Swayze and upon the Non-Conformance ~ OL Reports at the South Texas Nuclear, Project. .
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- 7. a. On the ~ design changes. CCANP reites'upon Mr. ' Daniel wayze.
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, b. On the personn'el other t'han' the or'iginal designer ~
4 approving design changes. CCANP reites upon Mr. Daniel E.; l,; g g
, Swayze. ' ,
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- c. On the' unqualified personnel making design' changes,
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' CCANP relies upon Nr. Daniel E. Swayze. : 'Xr, L . ~ *
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C. On the falsification of pour cards CCANP relles upon Mr. Daniel E. Swayte.
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- e. On the assaults, intimidations, etc. directed at '
inspectors CCANP relies upon : Mr. Daniel E. ' Swayz e; 'the various persons preparing reports on the beating sf Mr.
James Marshal! (See Applicants' Second, Exhibit 23 ); Mssrs.
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D. W. Hayes, R. Herr, H. 5. Phillips. E. P. Jernigan, R. M. 7 Compton, and R. B. Landsman of the Nuclear Regulatory Commis- . !;;d sion staff; and the as yet unidentified inspectors addressing ,
- ,19 these problems in NRC Report No. 50-498/79-19; 50-499/79-19
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- 'MW Provide the addresses and ' education and professional 1-1 b. ' 4%
qualifications of any persons named in your ress:ense to a.
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- M Identification of Mr. Daniel E.
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.m Applicants' First,Section I, page 5. 'Swayze is provided in y -
Identification of the other persons noted above, parti- * $;f cularly their qualifications, is not possible for CCANP.
- 1-1 c. Identify which of the above persons you intend to call as witnesses on this contentics.
For the moment. Mr. Swayze is the only person CCANP intends to call as a witness. Should the identities of the inspectors int erviewed in NRC Report No. 50-498/79-19; 50-499/79-19 be denied to CCANP, then CrANP intends to call the persons who prepared that report and perhaps other personnel in the NRC office in Arlington, Texas and Washington, D.C..
1-2 Provide summaries of the views, positions or proposed testimony on Contention NO. I of all persons named in response to Interrogatory 1-1, that you intend to present during this '
proceeding.
^
- 1. On the surveying error, Mr.' Turner stated: "Due to a f survey calculation error, the t'a s e m a t of Unit 2 Mechanical-Electrical Auxiliary Building was constructed one foot short j
j, on the east side of the building."
- 2. On the extensive voids, Mr. Oprea reported to the NRC on the extent of the confirmed voids and stated: "it was d]
determined that if left uncorrected, these voids could have 4l
[ j compromised the structural integrity of the Containment shell e 9 in that the as-built configuration would not have met its I design load and shieldirg criteria."
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- 3. On the lost field document r e l a t.i n t! to cadweld inspection, Mssrs. Hall and .osenberg stated: "Cadweld location
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field sketcA No. FSQ 030 had been lost and was no longer available.
4 On the membrane damage, see Applicants' First Answers 10 and 11, pages S threugh 10 and Applicant s' Second, Answers 19 and 20, pages 16 through 17. Again, CCANP takes note that .
while the position of the Applicants today is that they favor
, complete ad open discovery, the records rsquested by CCANP during discovery ?t the plant site regarding membrane place.
ment and inspection ,ere denied to CCANP on the grounds that the contention did not specify the buildings for which records were requested. '
- 5. On the missing refaforcement bars, see Applicants' First, Answers 12 through 15, page 10 and Applicants' Second, Answer R4, page 18.
- 6. On the cadwelds 'not capable of being v e ri fi ed , see ~~
Applicants' First, Answers 16 and 17, pages 11 through 16; Applicants' Second, Answers 27 through 33, pages 18 through 20; and Applicants' Second, Answer 35, pages 21 and 22.
- 7. On Contention 1. numbers i a through c, see Applicants' ~
First, Answers 19 through 31, pages 16 through 18 and Appli-cants' Second, Answers 36 through 41, pages 22 and 23.
On Contention 1, number 7 d, the falsification of pour cards, see Applicants' First, Answers 31 through 34, page 18 and Applicants' Second, Answer 42, pages 23 thrcugh 26 On Contention 7 e, intimidation, see Applicants' First, Answers 35 through 37, pages 18 and 19; Applicants' Second, Answer 43 through 45; NRC Report No. 50-498/79-19; 50-499/79-19; NRC Order to Show Cause (Effective immediately) dated April 30, 1980, 1-3 State the specific bases and references upon which the persons in Interrogatory 1-1 rely to substantiate their views regarding Contention 1.
- 1. Mr. Turner apf Atly relied on surveyc's hired tc examine the building in <estion.
- 2. Mr. Oprea apparently relied on the evaluation of . .
voids conducted by the Applicants and their contractor.
- 3. Mssrs. Hall and Rosenberg apparently relied on their -
own inability ano that of the Applicants to locate the missing !
document. + 1 5
- 4. Mr. Satyre relies on his memory. ),
- 5. Mr. Swayze relies on his memory and CCANP relies on the NCRs. ;
- 6. Mr. Swayre relies on his memory and CCANP relies on (
the NCRs. "
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- 7. Mr. Swayze relies on his meinary for a through e. The w e Applicants apparently rely on the statement taken of indivi- 0
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duals who witnessed the attack on Mr. Marshall (e). Mssrs. i" ,
Hayes. Herr, Phillips, Jernigan, Compton, and Landsman appa-rently rely on the sworn statements and other information they gathered auring their investigation. The unidentified df' y
inspectors apparently relied on either their direct experiences j l8 Ov Page 3 ff
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1-4 Identify (noting the basis for each identification) the location of the voids which " exist in the; concrete wall
, enclosing the containment building.
The voids, both suspected and confirmed [are identified
' N .in NCR #S-C 3461 and the 27 drawings attached thereto. The
't volds the Applicants admit to ,are found in Notification SFN: .
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V-0530, further identified as ST-HL-Ae-419 submitted to the
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NRC in February of 198d. by Houston Lighting and Power.
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( 1-5 Identify the " field document relating to-cadweld inspec-tions" that you assert has been lost.
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lI No. FSQ 030 ,
$ 4 1-6 Identify (noting the basis for each identification) the specific location of the " membrane seals in the containment structur'e which are damaged."
CCANP believes that there are damaged membrane seals on
, the Unit 1 and Unit 2 fuel handling buildings and the Unit I and Unit 2 mechanical electrical auxiliary buildinC.
The basis for this identification is M. Swayze's memory. , _ , ,
1-7 Identify (noting the basis for each idantification) the
, specific location of the " missing reinforcemen't bars".
CCANP believes there are missing' reinfcrcement bars around the eculpment hatch or- ' equipment door. For this contention, CCANP relies on the memory of Mr. Swayze.
From the NCR log at the plant site, missing bers were found in the following locations:
Pours CII-555; CII-58; Cl2-W14; CII-W44A; CII-340; C12-58; C12-W17; CII-W44; CIl-W24F; CIl-W29; CII-W450; C!1-344; CII-W34; C11-355; Cll-W99A; CSI-W37; CII.W205; C11-W76.
1-8 Identify (noting the basis for each identification) the specific location of the cadwelds "which are not capable of being vert fied".
See Applicants' First, Answers 16 and 17, pages 11 through 16 and Applicants' Second, Answers 27 through 33, pages 18 through 20.
1-9 Specifically identify all " efforts" referred to in Con-tentlau 1.7.a. and explain in detail how these " efforts" were " thwarted". 'O See Applicants' First, Answers 19 through 24, pages 16 through 17.
l-10 Identify the " personnel" in Contention 1.7.b as well as k<
your bases for your belief that such " personnel had no d,
" knowledge of the purpose of the original design".
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! See Applicants' First, Answer 25, page 17 d; ou l-11 Identify the " personnel" in Contention 1.7.c as well as your bases f or your belief that such " personnel" were "unqua- ]t lified in the type of design where the change was made". i (g
w ]I, See Applicant s ' Fi rst , Answer 29, page 17 and Applicant s' 3I
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._ _ Second, Answer 41 ..page 17. . ._. _ . ,
1-12 Identify: a) which pour cards referenced in Contention 1.7.d were "f alsified" and indicate what areas of the facility are affected, if any, explaining, the bases for your belief that the alleged f alsi fica'. ion would affect the facility and its ability to operate safeiy; and b) the names of the persons who " falsified" the pour cards as well as the dates (as accurately as possible) of such falsification. ,
See Applicants' First, Answers 32 through 34, page 18; Applicants' First, Answer 36, page 19; and Applicants' Second, Answer 42, pages 23 through 25.
As to the bases for our belief that the alleged falsiff-cation would affect the facility and its ability to operate safely, CCANP asserts that the inspection program was speci-fically for the purpose of assuring the safe construction of the plant. If the inspection process was suborned to the extent t, tat there was a " continuing trend" for inspectors to s'gn off on inspections whether the work was in conformance or not, then there can be no assurance of the safe construction ;
of the plant. Withou* this assurance, there can be no assurance that the facility will operate safely.
1-13 Identify the type, extent, and da*e of assaults referenced
- in Contention 1.7.e as well as the names of those persons - 4 involved with ea:h assault.
See Applicants' First, Answer 35, pages 18 and 19 Appli-cants' Second, Answer 43, page 26, 1-14 Identify all instances of -6 hreats of bodily harm",
"fi ring", and " behavior designed to intimidate" referenced in Cantention 1.7.e describing for each instance the names of the persons involved. '
See Applicants' First, Answer 35, page 18; Applicants' First, Answer 37, page 19; and Applicants' Second Answers 43 through 45, pagas 25 through 28.
1-15 Identify all the inspections (giving dates and specific detail with respect to what was to be inspected) that were never Jone as a result of the " intimidations" referenced in Contention 1.7.e. In addition, state the names of the persons who were to conduct each of these inspections.
i See Applicants' First. Answers 32 through 34, page ,
18; Applicants' First, Answer 36, page 19; and Applicants' ~
Second, Answer 42, pages 23 througn 25. In addition, since i the NRC itself found a " continuing trend" of inspectors 2-signing off on items whether these items were in compliance j*
or not to avoid confrontations, there i? little likelihood )
that all tnese items can ever be identified. O i
1-16 Identify all documentary or 'other material that you i ,
intend to use during this preceeding to support this contention j [
and that you intent to offer as exhibits on this contention m or refer to during your cross-examination of witnesses pre-sented by applicants and/or the NRC staff. {~
CCANP intends to use everf inspection report ever done by the NRC on this plant which contains material relevant to the contention. Research is underway at the present time tt
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identify just which reports fall into this category. CCANP y-)
intends to use all construction records of the plant which p ,
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support this contention 'of"which there are hu'ndreds of pages
__ copied -during discovery. CCANP intends to use internal docu-ments of tne Applicants and their contractor which have been attached as- exhibits to Applicants' First hnd Applicants' Second.
Contention No. 2
- 2-1 a. Upon what person or persons do you rely to substantiate .
your case on Contention 27
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- 1. On 50-498/77-03 CCANP relies upon W. A. Crossman, R. G.
Taylor, and V. C. Seidle of the NRC Region IV staff.
- 2. On 50-498/78-03 as reported in 50-498/?7-05, CCANP re- si lies upon R. C. Taylor, R. E. Hall, R. A. Hermann. W. E.
Vetter, and C. L. Heck af the NRC Region IV staff.
- 3. On 70-08, review of this report indicates that there may have been t- mistake in the reformulated contgntions. 50 493 and 50-499/78-07 also dated in May of 1978 contain information related to falsification of documents. CCANP relies upon W. ,
G. Hubacek, A. B. Rosenberg. L. D. Gfibert, and Ron J. Garcia of the NRC Region IV staff. -
- b. Provide the addresses and education and professional qualifications of any persons named in your response to a. : .a abovf. ,
CCANP is unaware of the qualifications of the NRC personnel.
- c. Identify which of the above persons you intend to call as witnesses on this contention.
If necessary, CCANP will call all persons noted above as ,
witnesses.
2-2 Provide summaries of the views, positions or proposed testimony on Contention No. 2 of all persons named in response to Interrogatory 2-1, that you intend to present during this . - . .
proceedir1 J
- 1. An inspect or with Pittsburg Testing Laboratory f alsi-fled sand inspection records. The insepctor's action apparently j. ,
resulted from production pressures.
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- 2. This ftem on falsified sand inspection records was I' closed out after analysis of records. J-i,
- 3. Four bolted joints marked at joint as only partially '
inspected. Review of record print showed inspection as complete. [/
2-3 State the specific bases and references upon which the l i t.
persons in Interrogatory 2-1 rely to substantiate their views 3 0 regarding Contention 2. j
- 1. Interviews with personnel involved.
- 2. Item closed out after inspection of records generated 4Y by falsifier and comparison of those records with other ;I inspectors doing simtlar work. [
- 3. Visual inspection; on-site review.
2.. ,nd, cat. ,n d.t.,, wh.t _, o, -.g. o, t,. ,
Inspection Reports cited in Contention 2 support your assertion y
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, ._ that STP construction records have been falsified by employees . -
of Houston Lighting .nd Power Company and Brown and Root. In addition, set forth the names of those employees referenced in Contention 2 who falsified STP construction records, indicating how and when these documents were falsified.
- 1. In the findings uf this investigatioE. the NRC staff concluded the records were f alst fied and that the f alsification was the falsifier's response to production pressures rather than malice. (See also SC.1, C.2, and D.1 of the report.) '
g 2. The close out is detailed in SVII. B..
- 3. The IE inspector informed the licensee that marking the record print to indicate that the inspection of the joint was completed when the inspection was not completed is in noncompliance with 10 CFR 50, A>pendix B, Criterion XIV.
2-5 rdentify all documentary or other material that you intend to use during this proceeding to support this conte 9ticr. and that you intend to offer as exhibits on this contention or refer to ducirg your cross-examination of witnesses presented by applicants and/or the NRC staff.
- 1. Inspection and Enforcement Regort 50-498/77-03.
- 2. Inspection and Enforcement Report 50-498/77-03.
- 3. Inspection and Enforcement Report 50-498; 50-499/77-07 Contention No. 3 3-1 a. Upon what person or persons do you rely to substantiate your case on Contention 37 Jale G. Bridenbaugh and Richar$ Hubbard
- b. Provide the addresses and education and professional qualifications of any persons named in your response to a.
above. -
MHB Technical Associates, 1723 Hamilton Avenue, Suite K.
San Jose, Califernia, 95125. >
Mr. Bridenbaugh is
- graduate engineer, thoroughly fami- 3 liar with the operation of nuclear generating plants, includtng 7 operating difficulties that lead to reductions in nuclear power plant reliability and operability. He received his l Dachelor of Science in Mechanical Engineertng from South 3 Dakota School of Mines and Technology in 1953. From June, i 1953 until F e b ru a ry , 1976, he worked as an engineer and ]
manager with the General Electric Company in the areas of 4 power generation equipment design, manuf actura, and operation, During the last ten years with General Electric, Mr. 9riden. "
y, baugh had the responsibility for managemer*. of the operation i of nuclear power plants and development and implementation of solutions to operational problems. Sinre 1976, Mr. Briden-baugh has been a partner and technical consultant in MHB Technical Associates.
Mr. Hubbard has a Bachelor of Science in Electrical 2.
Engineering from the University of Arizona and a Masters in j1 Business Administration from the University of Santa Clara. p from 1960 to 1976 Mr. Hubbard worked for General Electric !
Company. Mr. Hubbard held various supervisory position; regard- ;
ing the application, design, and manufacture of nuclear
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Mr. Hubbard was the Manager of Quality Assurance for the Nuclear Energy Control and Instrumentation Department. Since his resignation. Mr. Hubbard has worked with MdB Technical Associates.
- c. Identify which of the above persons you intend to call
. as witnesses on this contention.
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Dale G. Bridenbaugh and Richard Hubbard
, 3-2 Provide summaries of the views, positions or proposed testimony on Contention No. 3 of all persons named in response to Interrogatory 3-1, that you intent to present during this prnceeding. '
Pressurized water reactors, such as the Westinghouse reactors being installed at the South Texas Nuclear Project, are known to develop pressures in excess of design limits, i
particularly during start up and shut down.
l 3-3 State the s'p e ci f i c bases and references upon which the j persons fru Jiterrogatoriy 3-1 rely to substantiate their i views regarding Contention 3.
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From their long experience with nuclear power plants. -o .
Mr. Bridenbaugh and Mr. Hubbard have accumulated extensive ,
,i information on the operating performance of such plants. They have offered testimony in numerous hearings, including the ,
a River Bend and Diablo Canyon proceedings. Their basis for the i 4
overpressurization contention is actual instarces of over-3 pressurization in nuclear power plants.
1 a 3-4 Identify.all documentary or other material that you intend '
to use during this proceeding to supoort this contention and that you intend to cffer as exhibits on this contention or refer to during your cross-examination of witnesses presented ,,
by applicar.ts and/or the NRC staff.
NUREG 0410: NRC Program for the Resolution of Generic 4
- Issues Related to % clear Power Plants, January 1978; NLdEG i 0224: Final Report on Reactor sessel Press;re Transient M'.
Protectton for Pressurized Water Reactors, September, 1978; QL NOREG 0510: Identification of Unresolved Safety Issues Relating s4 to Nuclear Power Plants, January, 1979; NUREG 0649: Task 4i Action Plans far Unresolved Safety Issues Related to Nuclear }t Power Plants, February, 1980 - i r. this NUREG, the staff has identified this issue as *staf f resolved" but is still carried because not implemented in all cases. Wr I"
STATE OF TEXAS -k COUNTY OF BEXAR : i I
9EFORE ME, the undersigned authority, on this day perso- l' nally appeared L'tf NY ALAN'S!NKIN, kr own to me to be a credible 'I person, wno on his oath says that he is the co-coordinator of >
CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. ano ' chat he has I read the foregoing Answers of Citizens Concerned Atout Nuclear [
Powtr, Inc. to NRC Staff Interrogatories to, and Request for Documen.5 from, Citizens ConserneAAbout Nuclear Power. 4 ht MKM LANNY ptAN SINKIN, CO-COORDINATOR
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SLCSCRICED AND SWORN to before n by L A7.NY AL AN $!NK!N on k this the 13th day of June, 1980. i
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. . s yL%.w.Mi a926"'L W a3 UNITED STATES OF AMERICA
_ NUCLEAR REGUtATORY COMMISSION , _ , , , , _ _ .
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5
HOUSTON LIGHTING AND POWER % Docket Nos".' 50-498 COMPANY, ET. AL. 4 50-499 4 *
(South Texas Project 4 Units 1 and 2).
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " ANSWERS OF CITf2 ENS CONCERNED ABOUT NUCLL1R POWER, INC. TO NRC STAFF I NTE R R OG ATO.'I E S T0, AND REQUESTS FOR PRODUCTION OF DOCUMENTS FCOM CITIZENS CON-CERNED ABOUT NUCLEAR POWER" in tne above-captioned proceeding were served on the following by deposit in the United States Mail, postage prepaid this 13th day of June, 1980.
Charles Bechhoefer, Esq. Mrs. Peggy Buchorn Chairman Executive Director Atomic Safety and Licensing Bnard Citizens for Equitable U. S. Nuclear Regulatory Commtssien Uttlities Wasington, D.C. 20555 Route 1. Box 1684 ._ .
Brazoria, Texas 77422 Dr. James C. Lamb, III 313 We'dhaven Road Melbert D. Schwarz ~
C$ ape Hill, North Carolina 27514 Baker and Botts -
3000 One Shell Plaza .
Dr. frmeth A. Luebke Houston, Texas 17002 Atomic Safety and Licensing Board U. C. Nuclear Regulatory Commission Jack R. Newman Washington, D.C. 20555 Lowenstein, Newman, Reis.
Axelrad, and Toll Henry J. McGurren. Esq. 1025 Connecticut Ave., N.W.
Hearing Attorney Washington, D.C. 20036 Office of the Executive Legal Director Atotic Safety and Licensing Board- 3 U. S. Nuciear Regulatory Commission Panel Washington, D.C. 20555 U. S. Nuclez" Regulatory ;
Commission .;
Richard W. Lowerre. Esq. Washington, D.C. ;3555 4 Assistant Attorney General ,i for the Stat.e of Texas Atomic Safety and Licensing ; t P. O. Box 12548, Capitol Station Appeal Panel 1 4 Austin, Texas 78711 U. S. Nuclear Regulatory a b Commission aq g-Honorable Burt O'Connell Washington, D.C. 20555 j County Judge, Matagorda County 'f ;
Maragorda County Court House Docketing and Service Section (4) , o Bay City, Texas 77414 Office of the Secretary U. S. Nuclear Regulatory Commission [ ,
Washington, D.C. 20555 ,
June 13, 1980 J.w w w
,. n, Lanny.pAlan Sinkin E D 116 V1111ta San Antonio, Texas 78205 fy C03EE3 (512) 226-2959 it L5NR3 L
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