ML19341D535

First Set of Interrogatories & Requests to Produce Directed to Applicant.Certificate of Svc Encl.Related Correspondence

ML19341D535
Person / Time
Site:	Comanche Peak
Issue date:	02/26/1981
From:	Mccoll A CITIZENS FOR FAIR UTILITY REGULATION, MCCOLL, A.C.
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8103050769
Download: ML19341D535 (9)

Text

February 86, 1981 Att:.LLTED CO" 3SPONDENCB UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD SEI L .::-

In the Matter of 9 e 'Q s 4 TEXAS UTILITIES GENERATING 9 Docket Nos. 50-445 g oo %ETED COMPANY, et at-- 0 usHC 0 2 gg 21981 > d (Comanche Peak Steam Electric Q (Application for L- p Station, Units 1 and 2) i Operating License) Otgcl,t smge, p o3 smch CFUR'S FIRST SET OF INTERROGATORIES ca N \&

3 TO APPLICANT AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R. Il2.740b and 2.741, Citizens for Fair Utility Regulation

("CFUR"), hereby serves CFUR's First Set of Interrogatories and Requests to Produce upon Texas Utilities Genereting Company, et al (" Applicants"). Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all peritnent information known to Applicant, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of Applicant, its officers, directors or members as well as its employees, advisors or counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request preccding each answer or response.

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.. , .41 cy These interrogatories and requests shall be continuing in' nature.mThus, anyc. x,

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time Applicant obtains information which renders any previous response'inco'rrect or indicates that a response was incorrect when made, Applicant should supplement its

. .s previous response to the appropria

• terrogatory or request to produce. Applicant , , ',,~

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should also supplement its regb s as riecessary with respect to identification of N. fI ll 7p 2 ~ '**('

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b l each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. The term

" documents" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained. We request that at a date or dates to be agreed upon, Applicant make available for inspection and copying all documents subject to the requests set forth below.

I.

CFUR'S INTERROGATORIES AND REQUESTS TO PRODUCE

1. Have the Applicants relied upon Westinghouse, any other vendors, the NRC, the NRC Staff, or other entity to specify equipment, perform analyses, write procedures for operation and/or conduct training for operationg of CPSES?

2. If your answer to the preceding Interrogatory is anything but "No,"

answer the following:

a. On what entity did the Applicants rely;

b. On what documents, representations and other information did Applicants rely;

c. State approximately the time of reliance;

d. State what equipment specifications, what analyses, what operations procedures and what training Applicants relied upon. For each, identify what entity was relied upon, what documents, representations and other information was relied upon and the time of each reliance.

3. Has the Applicant made any contribution to the creation of the WCAP and other topical report. referred to in the CPSES CSAR?

4. If your response to the preceding Interrogatory is anything but "No,"

answer the following:

a. To which WCAP and other topical reports referred to in the CPSES FSAR did Applicants made contributions;

b. For each WCAP or other topical report listed above, state in detail the substance of all contributions;

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c. Identify with particularity all documents containing and '

otherwise involved with your contributions.

5. Have the Applicants conducted any idependen.t investigation on veri-fication of the WCAP and other topical reports referred to in the CP.SES FSAR?

6. If your response to the preceding Interrogatory is anything but "No,"

answer the following:

a. For which WCAP and other topical reports referred to in the CPSES FSAR have you conducted independent investi-gaiton or verification;

b. For each WCAP and other topical report listed above, state in detail the independent investigation or verification conducted, the names, business addresses and business positions of all persons who conducted each investigation or verification, the date of each investigation or verifica-tion, and the result of each investigation or verification;

c. For each topical report listed, describe in detail all documents which were relied upon in conducting each investig6 tion or verification, all documents which were created during each investigation or verfication, and all document = created as a result of each investigation or verification.

7. Do the Applicants agree with all portions of all WCAP and other topical reports referred to in the CPSES FSAR?

8. If your response to the preceding Interrogatory is anything but "Yes,"

answer the following:

a. With which topical reports do you not agree in total;

b. For each topical report listed, identify with particularity the portions you do not agree with;

c. What are your technical ' bases for your disagreement with each of the listed topical icports; '

d. State the name, business address and business position of each person who has provided technical bases or other information upon which you base your disagreement with each listed topical report;

e. Identify with particularity all documents which are involved with the technical bases upon which you base your dis-agreement with each listed topical report.

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9. IIave Applicants relied upon Westinghouse, any other vendor, the NRC, the NRC Staff, or any other entity to review the equipment, analyses, procedures and training to insure safe operation of CPSES?

10. If your answer. to the preceding Interrogatory is anything but "No,"

answer the following: .

n. On what entity did the Applicants rely;

b. On what documents, representations and other information did Applicatns rely;

c. State approximately the time of reliance;

d. State what reviews of equipment, analyses, procedures and training Applicants relied upon. For each review listed, identify what entity was relied upon, what documents, representations and other information was relied upon and the time of each reliance.

11. IIave Applicants conducted any independent review or investigation of the

. equipment, analyses, procedures and training for operation to insure safe operation of CPSES?

12. If your response to the preceding Interrogatory is anything but "No,"

answer the following:

a. For which equipment, analyses, procedures and training for operation have you conducted independent safety review or investigation;

b. For each equipment, analyses, procedures and trainings listed above, state in detail the independent safety review or investigation conducted, the names, business addresses and business positions of all persons who conducted each safety review or investigation, the date of each safety review or investigation, and the result of each safety review or investigation;

c. For each safety review or investigation listed above, identify with particularity all documents which were relied upon in conducting each safety review or investigation, all documents which were created during each review or investigation and all documents created as a result of each review or investigation.

13. Have Applicants relied upon Westinghouse, any other vendor, the NRC, the NRC Str/f, or any other entity to review the WCAP and other topical reports referenced in the CPSES operating, licensing application to insure that safety function will be accomplished?

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14. If your response to the preceding Interrogatory is anything but "No," <

answer the following:

a. For which WCAP and other topical reports referred to in the CPSES operating licensing application have Applicants relied on other entities for safety review;

b. For each WCAP and other tpical report listed, identify upon whom you relied;

c. For each WCAP and other topical report listed, identify '

what documents, representations and other information Applicants relied upon.

15. Have Applicants conducted any independent review of the WCAP and other topical reports referenced in the CPSES operating licensing application to insure that safety functions will be accomplished?

16. If your response to the preceding Interrogatory is anything but "No,"

answer the following:

a.. For which WCAP and other topical reports referenced in the CPSES operating licensing application have Applicants con-ducted independent review to insure that safety functions will be a'ecomplished;

b. For each WCAP and other topical reports listed, state in detail the independent safety review conducted, the names, business addresses and business positions of all persons who conducted each safety review, the date of each safety review, and the result of each safety review;

c. For each WCAP and other topical report listed, identify with particularity all documents which were relied upon in conducting each safety review, all documents which were created during each safety review and all documents created as a result of each safety review.

17. For each section and subsection contained in the CPSES FSAR, identify each entity who contributed to the content of each section, the substance of the contribution of each entity, and the names, business address, employer and business position of all persons responsible for each contribution of each entity. In answering this Interrogatory structure your answers according to each section and subsection set out in the Volume Table of Contents, pages i through xxxvii of the CPSES FSAR.

18. Identify with particularity all agreements between Westinghouse and Applicants which relate to the preparation and/or defense of any portion

of the CPSES FSAR.

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19. Attach copies of all agreements listed in your response to the preceding Interrogatory. (Please insure you have attached that portion of the December 27, 1977 agreement between Westinghouse and Applicants which relate to the preparation and/or defense of any portion of the CPSES FSAR.

20. If you have not complied fully with the preceding Interrogatory, why not?

Respectfully submitted, h

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ARCH C. McCOLL, Ill The Katy Building, Suite 302 701 Commerce Street Dallas, Texas 75202 214,744-5044 JEFFERY L. HART

. 4021 Prescott Avenue Dallas, Texas 75219 214/658-1600 O

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4 UNITED ST/ 9.S OF AMERICA NUCLEAR REGL.10RY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0 @ IN9d-x.. .

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In the Matter of f Q .

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MAR 21981 > I..

TEXAS UTILITIES GENERATING i Docket Nos. 50-445 5 --

COMPANY, et al 6 50-446 F

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(Comanche Peak Steam Electric Station, Units 1 and 2) 0

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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "CFUR's First Set of Interrogatories to Applicant and Requests to Produce," in the captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 26th day of February,1981:

Valentine B. Deale, Esq. Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Board Panel Licensing Board U. S. Nuclear Regulatory 1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555 Elizabeth S. Bowers, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington D.C. 20555 Marjorie Ulman Rothschild, Esq.

Dr. Forrest J. Remick, Member Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory Commission 305 E. Hamilton Avenue Washington, D.C. 20555 State College, Pennsylvania 16801 David J. Preister, Esq.

Dr. Richard Cole, Member Assistant Attorney Generci Atomic Safety and Licensing Environmental Protection Division Board P. O. Box 12548 U.S. Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C. 20555

a Mr. Richard L. Fouke Mrs. Juanita Ellis CFUR President, CASE 1668B Carter Drive 1426 South Polk Street Arlington, Texas 76010 Dallas, Texas 75224 Jeffery L.- Hart, Esq. Mr. Geoffrey M. Gay 4021 Prese)tt Avenue West Texas Legal Services Dallas, Texas 75219 100 Main Street (Lawyers Building)

Fort Worth, Texas 76102 Mr. Chase R. Stephens Doc!ceting & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ARCH C. McCOLL, Ill b

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