ML20005C062

Joint Interrogatories,Pursuant to ASLB 811030 Order. Certificate of Svc Encl

ML20005C062
Person / Time
Site:	South Texas
Issue date:	11/06/1981
From:	Jordan W, Sinkin L Citizens Concerned About Nuclear Power, INC., CITIZENS FOR EQUITABLE UTILITIES, HARMON & WEISS
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8111180342
Download: ML20005C062 (9)

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00LKETED U%RC UNITED STATES OF AMERICA

'81 NOV -9 Pl2 :17 NUCLEAR REGULATORY COMMISSION BEFORETHEATOMICSAFETYANDLICENSINU,O'5R60[(.,5['

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In the Matter of

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Docket No. 50-498 HOUSTON LIGHTING AND POWER CO.

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50-(South Texas Project, Units 1

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ORDER OF OCTOBER 30, 1981 C

Citizens for Equitable Utilities and Citizens Cors

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About Nuclear Power file these interrogatories pursuant to the invitation of the Board in its Order of October 30, 1981, in which it set out a number of issues to be addressed in testimony on December 8-10, 1981.

We request that they be answered in writing and under oath by employees, agents, or contractors of the NRC Staff who have personal knowledge of the facts in question.

The term " document" as used here encompasses all memoranda, notes, correspondence, and other papers containing writing, whether by hand, or machine, and all other means of recording information, including computer tapes and tape recordings.

The doctrine of ejusdem generis or similar theories do not apply to these interrogatories.

The listing of specific matters of any sort should be taken only as examples and not as in any way narrowing the scope of more general terms.

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1. Please describe in detail the status of construction of the South Texas Project as of midnight, Thursday, November 5, 1981, as the NRC Staff understands it.

In so doing, please include, but do not limit yourself to, the following;

a. Provide the percentage of i:ompletion of all structures and systems.

b. Describe in detail in a narrative the status of construction of each structure and system, including locations and identification of all completed work, the status of Quality Assurance / Quality Control review of all work, and work remain-ing to be dona.

c. Please identify all work done as of midnight, November 5, 1981, that the NRC Staff considers to be irrever-sible, and explain the basis for that opinion.

d. With respect to the construction work discussed under (b) and (c) above, please identify those aspects that the NRC Staff considers to be non-safety related.

Justify the distinction in each case.

2.

Please provide a detailed schedule or description of construction at the South Texas Project for the period November 6, 1981, to March 1, 1982 as the construction schedule is known to or understood by the NRC Staff. With respect to construction work to be performed between November 6, 1981, and March 1, 1981, please a.

Identify all such construction work that the NRC Staff considers irreversible, and explain the basis for that opinion.

3 b.

Identify those aspects of such construction work that the NRC Staff considers to be safety-related and those that the NRC Staff considers to be non-safety-related.

Justify'the distinction in each case.

c. Identify those aspects of such construction work that would be performed pursuant to any aspect of the plant's design that was discussed in the Quadrex Report, re-gardless of whether that aspect of the design has been re-viewed or changed ~since tha Quadrex Report was issued or since the Quadrex review was carried out.

(i) In each case, identify where the relevant aspect of the design is discussed in the Quadrex Report.

(ii) For each. aspect of construction identified pursuant to Question 2(c), please describe all design reviews and design changes undertaken with respect to that aspect of construction since it received the Quadrex Report.

3. What is the NRC Staff's position with respect to the question of whether adequate and competent construction and QA/QC personnel will remain on the job or be brought to the job (as applicable) during the transition period?

Please state all facts and opinions on which that position is based, and identify and provide copies of all documents related to o::

considered in reaching that position.

4. What is the NRC Staff's position with respect to the morale during the transition period of QA and QC personnel now employed by Brown and Root or who will work at the South Texas Project as employees of Brown and Root during the transition

4 period?

Please state all facts and opinions on which that position is based, and identify and provide copies of all do-cuments related to or considered in reaching that position.

5. What is the NRC Staff's position with respect to the likelihood that problems related to safety and licenseability pointed out by the Quadrex Report would (assuming they exist and to the extent that they might affect transition-period construction) be continued or even exacerbated during the transition period?

Please state all facts and opinions on which that position is based, and identify and provide copies of all documents related to or considered in reaching that position.

6. What is the NRC Staff's position with respect to the conformance of items of safety-related transition period construction activities (Attachment A to HL&P's October 16, 1981, letter) to the criteria for performing transition period con-struction set forth in the body of the October 16 letter?

In particular, is it the NRC Staff's contention that the j

safety-related items identified by Note 1 conform to criterion l

2? In addition, is it the NRC Staff's position that all work items conform to criterion l?

Please state all facts and l

opinions on which those positions are based, and identify and pro-vide copies of all documents related to or considered in reaching those positions.

7. What is the NRC Staff's position concerning the possible safety significance of transition work designated as l

non-safety-related (Attachment B to October 16, 1981, letter),

i 5

j I-l particularly in light of Quadrex Report, Section 3.l(d),

Vol.

I, pp. 3-5 and 3-6?

Please state all facts and opiniona l

l on which that position is based, and identify and provide copies of all documents related to or considered in reaching that position.

8. What is the NRC Staff's position with respect to the t

t i

degree to which the quality'of safety-related work to be per-i formed during the transition period can later be verified?'

Please state all facts and opinions on which that position is based, and provide copies of all documents related to or con-l sidered in reaching that position.

l

9. What is the NRC Staff's position with respect to the 3

i relative safety implications of (a) stopping all safety-related work and work which might affect safety-related structures or equipment; (b) continuation of only such transition work out-4 lined in the letter dated October 16, 1981, as had already been commenced as of that date; or (c) continuation of work as pro-posed in the October 16, 1981, letter?

Please state all facts i

and opinions on which that position is based, and identify and l

provide copies of all documents related to or considered in reaching that position.

I

10. Does the NRC Staff believe that it would be detrimental to the safety of operation of the South Texas Project to halt i

j any aspects of construction immediately?

If so, please identify i

each such aspect of construction, and explain both why safety would be adversely affected and what point must be reached be-fore construction can be halted without adversely affecting L

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6 safety.

Please state all facts and opinions on which this position 3s based, and identify and provide copies of all documents related to or considered in reaching this position.

11. Please identify all statements and commitments in the Preliminary Safety Analysis Report related to the con-struction work to be performed during the transition period, and in each case state whether the design and construction are consistent with the statements and commitments in the PSAR.

Please state all facts and opinions on which this position is based, and identify and provide copies of all documents related to or considered in reaching this position.

12. To the extent not previously addressed, please describe in detail all actions taken by the NRC Staff or Brown and Root with respect to or as a result of the Quadrex review or the Quadrex Report related to aspects of the design of the South Texas Project for which any construction work is expected during the transition period.

Respectfully submitted, lAMLc X J a /L_ /tB William S.

Jordan, III HARMON & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C.

20006 For Citizens for Equitable Utilities

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k Ik-a l /,f5 Lanny sinkin, 2207-D Nueces Austin, Texas 78705 For Citizens Concerned About Nuclear Power Dated: November 6, 1981

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e k'hiSOFAMERICA UNITED NUCLEAR REGULATORY COMMISSION BEFORE Tile A'f$$11NON9Efl2 *v6D LICENSING BOARD

{f{hCgg In the Matter of SPANCH )

liOUSTON LIGHTING AND POWER

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Docket Nos. 50-498 et,

(

COMPANY, et al.,

)

50-499 OL

)

(South Texas Project,

)

Units 1 and 2)

)

CERTIFICATE OF SERVICE I

I hereby certify that copies of Citizens for Equitable Utilities and Concerned Citizens about Nuclear Power Joint Interr og atories to The NRC Staff Pursuant to The Boar d 's Order of October 30, 1981, and Citizens for Equitable Utili*ies and Concerned CLiiZens about Nuclear Power Joint Interrogatories to liouston Lighting and Power Company Pursuant to The Board 's Order of October 30, 1981, l

dated November 6, 1981, have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid on This 6th day of November, 1981.

Charles Bechhoefer, Esq.

Brian Berwick, Esq.

Chief Administrative Judge Assistant Attorney General Atomic Safety and Licensing for the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Commission Division Washing ton, D.C.

20555 P.O. Box 12548, Capitol St ation pr. James C. Lamb, III Austin, Texas 78711 Administrative.Todg e 313 Woodhaven Road

• Jack R. Newman, Esq.

Chapel 11 i 1 1,

N.C.

27514 Lowenstein, Axelrad, et al.,

1025 Connecticut Avenue, N.W.

Ernest E. 111 1 1 Washington, D.C.

20036 Administ rative Judge Lawrence Livermore Laboratory Kim Eastman, Co-coordinator University of California Barbara A. Miller P.O. Box 808, L-12 3 Pat Coy Livermore, California 94550 citizens Concerned About Nuclear Power 5106 Casa Oro San Antonio, Texas 78233

• lland Delivered

aus eut Mrs. Peggy Buckhorn I.anny Sinkin Executive Director 2207-D Nueces Citizens for Equitable Austin, Texas 78705 Util i ties, Inc.

Route 1, Box 1684 Brazoria, Texas 77422

• Jay M. Gutierrez, Esq.

Atomic Safety and Licensing office of the Executive Appeal Board Legal Director U.S. Nuclear Regulatory 11.S. Nuclear Regulatory Commission Commission l

Washington, D.C. 20555 wash i ng ton,

D.C. 20555 Atomic Safety and Licensing Docketing and Service Section Board Office of the Secretary j

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Wash i ng ton, D.C. 20555 Commission Was hing ton, D.C. 20555 i

l William.S.' Jordan, III IIARMON & WEISS 1725 T Street, N.W.

Suite 506 Washington, D.C. 2 0006 4

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