ML19344A104

First Set of Interrogatories Directed to Bechtel.Discusses Applicant Compliance W/Qa Regulations

ML19344A104
Person / Time
Site:	Midland
Issue date:	04/22/1974
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, Saginaw Intervenor
To:	BECHTEL GROUP, INC., Atomic Safety and Licensing Board Panel
Shared Package
ML19344A096	List: ML19344A095 ML19344A100 ML19344A104 ML19344A108 ML19344A111
References
NUDOCS 8007310610
Download: ML19344A104 (10)

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ERDO. L UIIL, LAC.CPPR-SI ZL April 22, 1974 G 00CIETEI '2-t3EC UNITED STATES OF AMEliICA F APR2 S 1974> [3 ATOMIC ENERGY COMMISSION 3^ c- n e tetr l

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BEFORE T!!E ATOMIC SAFETY AND LICENSING DOARD 'f.,)td

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In The Ma.tter of )

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) 1 CONSUMERS POWER COMPANY ) Construction Permits Nos. 81 l

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(Midland Plant, ' Units 1 and 2) )

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FIRST SET OF INTERROGATORIES DIRECTED TO BECHTEL CORPORATION t

Pursuant to Section 2.740b, .Bechtel Corporation is 4

requested to answer the following interrogatories timely, separ-ately, in writing and under oath. .

DEFINITIONS

1. As used in these interrogatories the word document, documentary informa' t ion, or word of similar import is to be inter-preted in the broadest possible manner and is to include, with-out limitation, documents, writings, reports,-studies, analyses, memoranda, communications, _ letters, summaries, reports of tele-

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phone conversations or meetings and as to- each of these categories, -

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whether draft or final,' formal or informal, acceptc.d 'or' pcjected, typed or mimcographod or.xcroxcd, handwritten, and is aise to in-clude copied, however reproduced, 'of all such categories.

2.; In connection with your answer to cach category, and unless the facts arc stated ~'in your ' answer, include within your answer the facts -.upon whicli you rely for your ' answer. This direc-tive i.s meant to 'procludo 'answo::ing' any interrogatorics with "yos "

or "no" and requests' .that you scit forth the facts upon which you base any such~ answer. Unicss otherwisc stated, cach answer calling for information concerning~ Consumcrs Powcr Company is intended to

all for information' concerning cach -of its activitics which arc -

3r may bc' subject to regulation by the Atomic Encrgy Con $ission.

Cn the' event that you object to providing information for other

h.in the Midland power 'facili'ty, ' pleasc cupply the -informa tion

'?or. the Midland ~llacility and stalc your rcasonc you believe infor-talion)an .Lo;lligf lhack, Paliuadun, - Permi-1 and Quanicau::eu .a re not

'clovant -or; appropria to : lod the . iscucs which are subject to this trocccding. 'In connection with the ' answer ~ to cach o 0 Lliano inter-. f.

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'rogatories,: identify P7-names and addresses of 'rsons having

. knowledge of: the facts set forth (if different)', the names-and addre'sses'of persons who -participated in the preparatio'ns of or

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prepared cach of said answers.

INTERROGATORIES

1. Define the.words " compliance with quality assuranco regulations" as those words are employed and as you understand

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them in the Commission's Show Cause order in this proceeding. In-

'clude with your answer 'cach- fact which you claim 'must exist in order to conclude that compliance with quality assurance regula-tions exists. ,

2 Ilave you' concluded that Consumers Power Company is in compliance with quality assuranc,e- regulations concerning cach of its'facilitics. If you have, please set forth the regulations witikwhich you assert that Consumers Power company is in compliance and stato cach- fact -upon which you base your jud.gment.

3.- 'Have you cvor concluded .that Consumcrs Power Company is not :in compliancc Lwith Quality Assurance regulations in con-A

. ncction with .any of -its facilitics. .If so, plcasc set'forth each fact upon. which you -base your judgment together with each relevant Lrogulation. _

54 . T 'Hav'c you . concluded that there is reasonabic assuranco I

that Consumers Power Company will be able L to comply with quality 5

-assurance regulations through the construction process in Midland.

7 LIf you have, please state each fact'upon which you base. your con-clusion. . Include within -your answer whether you have considered the activities. of Consumers. Power Company .at any of its other' facil-ities and-if not, state why not.

'5.. Have you ever concluded th't a there is no reasonable assurance that- Consumers Power Company wil'l . comply with quality .

assurance regulations during the construction of the Midland facil-ity.- If so, please set forth each fact upon which you base your answer. In connection with your answer, state whether you have ever considered in connectiod with your conclusion any activities

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l of Consumcrs PowerJCompany at any other facility and if not, stato '

why not.

6. In your. judgment, which of the following is respon- l sible for assuring . reasonable assurance with Q.A.-Q.C. regulations at the . Midland plant facility:-

i (a) Consumers Power Company; f(b) Certain ~ named individuals at donsumers Power. Company; (c) Bechtel Corporation; (d) Certain nam $d individuals at Bechtel' Corporation; (e) Atomic Energyf Commission or any part thereof; and b

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.(f) Certain named individuals' at the Atom c

' Energy. commission or'any part thereof.

aase explain;your. answer in detail.

7. Identify 'in connection with each of Consumers Power mpany fhcilities as set forth in the definitional section each cument ever received or reviewed,'each meeting you have had (in-

.ude. dates and names of attendees) and each physical structure t

>u have reviewed ~in connection with your analysis of first com-  !~

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.iance with quality. assurance regulations and second reasona }'

surance of continuation with~ compliance with quality assurance, 'k

'1 gulations. EI

8. Do you believe that evidence of willful failure by Atomic tsumers Power Company to report any violation of any P I

rgy Commission regulation is relevant evidence as to whether '

ro is reasonable assuranceLthat Consumers Power Company will i e l

[l ply.or continue to comply with quality assurance regulations I ,

If not, state why:not.

ernin~g the Midland facility. -!

9. Define the words " reasonable " assurance"'as those i are ' u s e d, and vas you understand them in the Show Cause .

E in this proceeding. . Include with_your answer each fact you claim'myst. exist in order to conclude that reasonable

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10. _- With reference to your " Petition To Intervene"

-' filed _.in;this proceeding state:

' (a)' . Define and listiin as much detail as ,

possible Lthe " broad experience" which

-you allege in paragraph 1; .

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.(b) Describe in detail _ (and attach' a copy)

- of.the. relevant portions.of-your con-

, , tract with' Consumers Power' Company

-setting forth your " direct responsi-4 bility" as. set forth in paragraph 1; (c)_ State each fact upon which you rely for the allegation in'the first sentence of paragraph 2 of.your petitions

, (d) State each fact upon which you rely for

your allegation contained in the second sentence of paragraph 2 of your petition including a definition and characteriza-tion of your~" established reputation in the nuclear industry;"

-(e) State each fact upon which you rely for the allegations in-sentences 3 and 4 of. '

paragraph -2 of your petition. .i li (f)_ ~Describo in detail each -issue -adverse' to  !

the continuation of Construction Permits-Nos.L81'and 82Jas you use1those terms in

' paragraph;3 of your petition; (g).

. Describe 1each _ fact ' upon which you base L(and to which you make referenceiin)?the ,

last two sentences of the first paragraph-

_, gof paragraph _4 of.your petition;

. : (h) . Set forth in detail each fact upon which

' you base' the . allegations in the second

paragraph of_ paragraph:4 of your petition -

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. (i) State' each; fact upon which you base the ,

allegations-in the third paragraph of

' naragraph 4'of;your; petition including:

-wi thout l mi itation an identification of

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. the various=Bechtel quality-assurance, q

quality-control programs, how they have been implemented in accordance.with

! ' evolving-AEC' codes and identification of such codes, regulations and inter-  :

• :pretations to-which you refer, and l definition of " reasonable' assurance" (including.all facts which support such a definition) as you use those~ terms in your

. petition.

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List each decision which you have'_taken or. failed' to'take in connection with quality-assurance and quality-control at the Midland facility which action, or failure to act, was -

based in,any..part upon the expenditure =of. funds.

This Interroga-tory is intended.torsolicit your. answer as to what role the cost of providing quality-assurance and quality-control play in

-ihe -quality-assurance and quality-control activities you re--

,,  ? commend or implement.

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~ 12 . - -With: respect-to each'of the nuclear facilities-as to whichlyou-:have been a contractor.or subcontractor, state:

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-(a) .

Are iall of your quality-assurance and quality-control plans ide'ntical?- If

'they are not,Lstato the differences for .

ea'h~of:the c relevant nuclear-facilities. t Include-within'-your! answer why,there are-differences 'and which plan -is , in your l judgment,.the best:to' accomplish;the- ,

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,'(b) List each quality-assurance, quality-control violation which has occurred at each such site and include whether .

the violation'was reported to AEC of-ficials;

-(c)' List'each quality-assurance, quality-

' control incident which was -not reported to AEC or which was not considered a violation but as to which discussion was

. had whether.it was a violation; l

l 13 '. With' respect to the Palisades facility, explain in ' detail. and characterize. the type of quality-assurance and quality-control. activities'which occurred. Include within your answer the following:

(a) 'tho is responsible for. the type of quality-assurance and q'uality-control incidents which occurred at that facility; '

03) Are any of the existing structural pro-blems at the Palisades facility traceable to quality-assurance, quality-control ac-tivity?- If so, list them;

-(c) Do you consider your activity at Palisades ,

quality-assurance, quality-control activity l

'to be in compliance.with regulations now I 1

existing? 'Please explain your answer.

(d)- lault changes have- you made or do you suggest ~

in either your role or:the role of Consumers

. Power Company.at the Midland facility in-light of the Palisades' experience? J

14. . With respect to the Midland facility quality-assur-ance, state:

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(a) JDo you agree with the allegations set

-forth in_the Show Cause order and the referenced documents?- If not, state

'each allegation with which you do not .

agree and explain why; (b) As a result of the Show cause order,

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have you recommended o*-taken any action e to change.your role or consumers role at

- the Midland facility? - If'not, state why not, and if yes, explain such changes in implementations and recommendations in detail.

15. What is_your opinion of consumers as a utility in,the quality-assurance, quality-centrol area in light of your

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Knowledge and escperience with other utilities? Please include within your anmier the facts upon which you base your answer .

and an identification of other utilities contained in your com-parative answer.

16. Describe in detail each classification or cate-gory of document (as defined herein) which you maintain in

-connection with quality-assurance or quality-control regarding.

4 the Midland site, whether maintained at the Midland site or elsewhere. This Interrogatory _is intended to solicit.informa-tion for.a motion to produce and is intended to have you describe

- documents whether of a formal or informal nat'ure, and whether they areedocuments' internal to your company or not, and also whether or not they are-documents which are or are not discloscd to someone -other than persons in your' company.

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. 17. Please list the-name and address of each witness l

whose testimony;you intend to offer at the proceeding. Include

.with .your answer a summary of the scope of each witness's tes-

. timony., In the event that you do.not presently know-who your-

witnesses will be, please list the areas of evidence or testi-mony which you presently believe you will introduce.

If you cknnot answer this Interrogatory, please explain in detail why you-cannot. -

18. Please list all of.the documentary evidence which you presently plan.to introduce at the proceeding. If 1

you are not in a position to. presently; state what documentary evidence you will introduce, please. state what categories of-documentary evidence you will introduce.. If you are not in a position 'to. answer this Interrogatory, please explain why not.

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- By: e Myron h/ Cherry /

Attornef for Saginaw Grou j

. Myron M. Cherry.

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One I~B'M Plaza.

t: . Chicago,-Illinois 60611 '

_(312) -222-9350 s f

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