ML20003E220
| ML20003E220 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/23/1981 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8104020549 | |
| Download: ML20003E220 (6) | |
Text
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D, gR 3 0 $81 P ra BEFORE THE ATCMIC SAFETY AND LICENSING BOARD f
in the Matter of i
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. HOUSTON LIGHTING AND POWER Oceket Nos. 50-498 COMPANY, ET AL i
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to (South Texas Project, Units 1 and 2 i
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[E CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC.
SUPPLEMENTAL ANSWERS TO APPLICANT INTERROGATORIES T. "' *-
2 /' /g f' Tc On March 16, 1981, CCANP delivered to Applicants a docu-y g
s ment entitled ANSWERS OF MR. LANNY SINKIN TO QUESTIONS FROM
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APPLICANTS.
In those answers, item No. 2 requested the names N
of CCANP members who assisted Mr. Sinkin in answering Applicant Interrogatories. Since the hearing, Mr. Sinkin has reviewed the file of working notes from which the answers in question were prepared. Based on this review, Mr. Sinkin now supplements his answer to state:
"In answering the Interrogatories, I was assisted by a Mr. Patrick O'Mara. Mr. O'Mara was not a member of CCANP to the best of my recollection, but did assist me by referencing information already in our possession to the Applicants' ques tions.
Mr. O'Mara w'as net involved in collecting any informa-tion, only in organizing information already on hand."
On March 17, 1981,- CCANP representatives met with Appil-cant representative to discuss additionel information sought by Applicants in response to Applicant's second interrogatories.
Y Below are the answers sought, including answers potentially covered by the protective order entered by the Board on March 18, 1981.
8104020554L
. 2.(b) Id.ent i f y each persen contacted by CCMP during its participation in the aucve referenced investigation.
IFBil "The only na :e i can recall which was provided by COMP to the FBI for purposes of their investiga-len and the only person so providec with infermatica relate: to Contentiens I and 2 er whose questicning is likely to lead to infer.ation en Cententiens 1 and 2 is Caniel E. Swayze."
5.(c) Has COMP spcken with any official of the PRC cr any other persen cencerning any activity of HL&P and/cr its centrac-ter for the STP project which CCMP regards as part of "exten-sive, pervasive, and willf ul violations of 10 C.F.R, Part 50."
ider.tify each such persen and describe the substance of each conversatien.
"During and after the Ceder to Show Cause investigation, CCANP discussed such violations with Mr. Victer Stello and rnembers of his staf f whose names i do nc+' recall and with Mr.
James Lieber en and rnesters of the CELD staf f whese names i do not recali. The esser.ca of these conversaticns was to explain the allegations in CCNP's pleadings and to s.nk infor atica cn when the Investigatien wculd cenclude and w'iether the allega-
?Icns were being substantiated.
The only ncn-tRC person with wher COMP discussed what CCNP consider to be extensive, pervasive, and will f ul viola-tiens of 10. C. F.R., Part 50 who has infer ation related to Cententions 1 and 2 er whose questioning in iIkely to lead to infor ation en Cententiens 1 and 2 is Daniel E.
Sway e. - The substance of the conversaticos is embodied in Contentions 1 0-
. and 2 as' accepted by the Beard; answers of CCANP to Appilcants' first set of interrogatories #'s 3-5 and 9-38; and answers of CCANP to Applicants' second set of. Interrogatories I's 2-5, 9-17, 19, 20, 22-25, 28, 29, 31-37, 39-45, 46(d)."
6.(b) Identify the source of the information in (a) above (f acts or occurences contributing to "a
climate of fese at the construction site."]
" Daniel E. Swayze" 6.(c) Names of persons who refused to provide Information for fear of losing his or her job.
CCANP was contacted by a person who stated he worked in the electrical department at STNP and that there was very poor work.manship regarding holders of high voltage lines. Said person did finally agree to a meeting but failed to appear. CCANP attempted to get this person to agree to a meeting, but this person expressed fear for his job with Brown and Root, Inc..
Subsequent attempts by both CCANP and CEU to locate this person failed.
It is possible the person used an assumed name, but in case the name gi4en is the real name, this name will be provided under separate cover for inclusion under the protective order.
The only other persons relevant to this interrogatory are persons - whom Mrs. Buchern talked to. Other than people named on the 1981 tape given to l&E, CCANP cannot recall any names of persons who expressed this sentiment."
- 40. Identify exactly that portion of the PRC Regulations and/cr Scuth Texas Project Quality Assurance ' Procedures which CCANP
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. 1 asserts requires that the " original designer" approve design changes.
"CCANP makes no such assertion. CC5NP knows of no such tRC or STNP regulation or" procedure."'
45 (a) Identify specifically each and every instance of "Inti-midation" or " abuse" which CCANP asserts was " endemic".
"CCANP references answers to Applicants' first set of interrogatories #'s 32-37; answers to Applicants' second set of
' nterrogatories 42-44; and the Order to Show Cause."
i 46.(c) Identify each instance in which CCANP asserts that "per-vasive construction errors" caused " tension between construction workers and inspectors."
" Answers to Applicants' first interrogatories #37; Crder to Show Cause page 49 and supportive investigative findings."
- 46. (e) Produce each document upon which CCANP relles for the conclusion set forth in-(c) above.
" Answers to Applicants' fIrst interrogatories Exhibit O and P; Answers to AppiIcants' second interrogatories Exhibit 4; Crder to Show Cause."
- 47. Identify each and every construction record, other than
" pour cards" referenced in Contention I,
Paragraph d.,
which you assert has been falsified.
"At the March 17, 1981 meeting with Applicant representa-tives, CCANP representatives-recalled another allegation of falsification. A letter recounting that allegation, the source of the allegation, and the alleged falsifiers has been sent to NRC l&E. Washington for investigation. Rather than compromise k
'. the investigation, CCANP awaits l&E determination of the vali-dity of the charge."
As to the names on the tape fr'om Mr. Swayze's attorneys, I have sent Mr. Swayze a letter requesting his permission to release the tape to the NRC. If such permission is received, I will review the tape to see if there are matters related to Contentions 1 and 2 or where questioning of the inspectors is
.Iikely to lead to information. relevant to Contentions I and 2.
If there is such information or the likelihood of such informa-tion being developed, I will provide the names to the Applicants either under the protective order or in the witness Iist."
LannySpkin STATE OF TEXAS i
5 COUNTY OF BEXAR 5 BEFORE ME, the undersigned authority, on this day per-sonalsy appeared Lanny Sinkin, who on his oath states that he has read the foregoing CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. SUPPLEMENTAL ANSWERS TO APPLICANT INTERROGATORIES and knows the sat 5e to be true and correct.
Lanny p nkin l
SUBSCflBEDAND SWORN TO before me by LANNY SINKIN on 13' day of March, 1981.
this FAY YK l
c_
N p ry Public in and for Sexar County, Texas i
l My Commission expires:
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y w g u cu. C C. DD CE CEETIFICATE OF SE:V!CE I hereoy certify ena: the foregoing cocu ent has been servec en :ne following individuals and entities by cercsi in the U. S. ra i l, f i r s t class, postage precaic en thisJS*' cay of r.aren, 1931.
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.x cc-Ge em Kim East an Charles Sechhoefer, Esq.
Mr. Jack New.an Chairman, Atomic Safety and Lowen s te in, New.an, R e i s, & A2 e i r a c Licensing Board 1025 Ccnnecticut Ave. h4 U.S. Nuclear Regula tory Ccernission Vashington, D.C. 20036 Vashington, D.C. 20555 Gocketing anc Service Section (7)
Dr. Jates C. La o Office of the Secretary 313 weechaven Road U.S. Nuclear Segulatory Ccmissien Chapel Hill, North Carolina 27514 washington, D.C. 20555 Mr. Ernest C. Hill Atomic Safety and s 2nsing Lawrence Livermere Laboratory Board Panel University of California U.S. Nuclear ~egulatory Comission P.O. Box 809, L-123 Washingten, D.C. 20555 Livermore, Calif. 94550 Atomic Safety and Licensing Ec in J. Reis Acceal Panel (5)
Office of the Executive U.S. Nuclear Regulatory Cecr-issien Legal Director Washing:cn, D.C. 20555 U.S. Nuclear Regula tory Comissien Washington, D.C. 20555 Thomas S. Mudson, Jr. Esq.
Baker & Botts Brian E. Berwick, Esq.
3000 One : hell Plaza Assistant Attorney General for Housten, Tx.
77002 the State of Texas 5th fleer, Reagan Sleg.
Austin, Tx. 78711
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Mrs. Peggy suchorn coCFm:
Executive Director, CIU 6
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