ML20008G147

Interrogatories Directed to NRC Re Partial SER,NUREG-0780, Pursuant to ASLB 810421 Order.Certificate of Svc Encl. Related Correspondence

ML20008G147
Person / Time
Site:	South Texas
Issue date:	05/04/1981
From:	Jordan W CITIZENS FOR EQUITABLE UTILITIES, HARMON & WEISS
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8107020354
Download: ML20008G147 (10)

Text

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t U?';pc UNITED STATES OF AMERICA . MAY Q198I, s. 7 NUCLEAR REGULATORY COMMISSION [ '- [ . 7 c:=c.)

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BEFORE THE ATOMIC SAFETY AND LICENSING BOAR l% C

)

In the Matter of )

) Docket No. 50-498 HOUSTON LIGHTING AND POWER CO. ) 50-499 (South Texas Project, taits 1 )

and 2) )

)

CEU INTERROGATORIES TO THE NRC STAFF BASED ON THE PARTIAL SER Pursuant to the Licensing Board's Order of April 21, 1981, CEU poses the following interrogatories to the NRC Staff, to be answered under oath. Please identify the person providing each answer.

1. Is the Partial SER (NUREG-0730) based on any review other than the February 17-19, 1981, visit by the NRC Staff to the corporate office of HL&P in Houston and the plant site near Bay City? Detail any and all other visits, interviews, studies, or documents in-volved in preparation of NUREG-0780.

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2. Please provide a copy of NUREG-0731, " Guidelines for Utility Management Structure and Technical Resources,"

referred to in the Partial SER.

3. With regard to the Staff's preparation of the Partial SER, provide a schedule with the following information:

a. the Staff persons involved in the February 17-19, 1981 visit to HL&P offices and the plant site: 'b3 0l 810.7020MY

b. the Staff persons involved in preparing NUREG- ,

0780 and the responsibilities of each; j

c. the person-hours devoted by each individual l listed under parts a&b above to the investiga-tion, review and all other preparation of NUREG-0780; and

d. the HL&P and Brown and Root persons involved in the February 17-19, 1981, visits or otherwise contacted by the NRC Staff in the course of its review of the matters discussed in the Partial SER. In each case, provide the name, title, and function of the HL&P or B&R person, the date of the contact, and the substance of the contact.

4. Provide a copy of any agenda, checklist, analysis, dis-covery request (formal or informal) , or production request (formal or informal) utilized by the Staff in its prop-aration for the February 17-19, 1981, visits and any other visits related to the preparation of NUREG-0780.

Provide any responses that have been provided by the applicant or its contractors or agents to such discovery or production requests.

5. Provide a copy of any correspondence (or notes or memos of conversations) between the Staf f and Applicant or its contractors or agents prepared between September 22, 1980, and February 17, 1981, relating to the visits vhich occurred on February 17-19, 1981, the preparciton of the Partial SER, or to any matters considered by the Staff in preparing the SER.

6. Who on the NRC staff will continue to monitor the devel-opments in the areas of management capability and the quality assurance programs?

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7. Define and detail the duties, responsibilities, job functions and qualifications for a Shift Technical Advisor.

8. Recognizing that the NRC staff has not completed its review of the listing of systems, structures and compo-nents that should be under the control of the qualiry assurance program, provide a description of the work in progress on that subject. Separately designate those portions and components which the NRC staff believes to be "important to safety."

9. Produce a copy of all notes, documents, and exhibits prepared by the NRC Staff pertaining to the February 17-19, 1981, visit. We have a copy of the formal trip report itself, which need not be included. However, all drafts of the trip report should be included.

10. On page 13-2 there appears the statement, "He (Manager, South Texas Project) interfaces with the nuclear steam supply system project manager, and the architect-engineer /

contractor project manager for management decisions affecting the STP plant." With regard to that statement, answer the following:

a. what is meant by " interfaces"?

b. how are decisions arrived at during the interfacing process?

c. must each of the decisions made in the above pro-cess be cleared by the Executive Vice President or the Vice President, Nuclear Engineering and Construction, or'any other level of HL&P manage-ment? If so, which level?

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14. On page 13-10 there appears the statement that, "The principal function of the existing STP QA organization is to provide programmatic direction to the Brown & Root QA organization." With regard to that statement answer the following:

a. What does the statement mean? In particular, describe in detail what is meant by " programmatic direction," giving all examples that were con-sidered in reaching that conclusion.

b. If such programmatic direction is written, pro-vide a copy of each such document.

c. Define, describe, and detail (with charts) the Brown and Rcot QA/QC organization.

d. Detail the changes (including personnel) that have occurred in Brown & Root QA/QC organization since April 30, 1980,

e. Define and describe what HL&P people actually do with regard to QA/QC. Define and describe all positions and daily responsibilities.

f. Does HL&P conduct any actual QC investigations or inspections? What is their frequency and cause?

15. What actual changes will occur in both HL&P and B&R l

QA/QC operations as a result the implementation of the organization detailed in Figure 13.3?

16. Page 13-13 notes that plant personnel "will conduct much l

of the precoerational testing of Unit 1." What aspects will they conduct and who will conduct the rest?

17. Three positions on Figure 13.4 show "1981" rather than a name. Have those individuals been selected? If so, who are they and what are their qualifications? If not, when will they be chosen?

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14. On page 13-10 there appears the statement that, "The principal function of the existing STP QA organization is to provide programmatic direction to the Brown & Root QA organization." With regard to that statement answer the following:

a. What does the statement mean? In particular, describe in detail what is meant by " programmatic direction," giving all examples that were con-4 sidered in reaching that conclusion,

b. If such programmatic direction is written, pro-vide a copy of each such document.

c. Define, describe, and detail (with charts) the Brown and Root QA/QC organization.

d. Detail the changes (including personnel) that have occurred in Brown & Root QA/QC organization since April 30, 1980.

e. Def'ine and describe what HL&P people actually do with regard to QArQC. Define and describe all positions and daily responsibilities,

f. Does HL&P conduct any actual QC investigations or inspections? What is their frequency and cause?

15. What actual changes will occur in both HL&P and B&R QA/QC operationsas a result the implementation of the organization detailed in Figure 13.3?

16. Page 13-13 notes that plant personnel "will conduct much of the preoperational testing of Unit 1." What aspects will they conduct and who will conduct the rest?

17. Three positions on Figure 13.4 show "1981" rather than a name. Have those individuals been selected? If so, who are they and what are their qualifications? If not, when will they be chosen?

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. 19. Page 13-13 refers to the fact that HL&P uses "a six-shift rotation" which "would provide for a minimum of five_ days of training in each 42-day shift cycle."

Explain what this means. In particular, what is "a six-shift rotation," and why would it provide for the training indicated.

19. At page 13-8, there appears the following statement:

HL&P stated that protection of public health and safety is of paramount importance and this will be communicated to the HL&P staff through-out the lifetime of the plant, emphasizing the responsibility of each employee to perform his or her job in a way that assures public safety.

a. Es the NRC Staff aware of any HL&P statements prior to April 30, 1980, in which the company recognized the importance of protecting the public health and safety? If so, please pro-vide a copy of each such statement.

b. Did HL&P make a commitment to protect the public health and safety when it applied for and received a construction permit?

c. How is the HL&F recognition of the importance of protecting the public health and safety as discussed by the NRC Staff different from pre-vious reccgnitions or commitments of which the Staff is aware?

d. Is the Staff aware of any efforts by HL&P prior to April 30, 1980, to communicate the importance of protecting the public health and safety to the HL&P Staff? If so, please describe such -

efforts and provide copies of any such communi-I cations.

e. How will future HL&P communications to its staff concerning the importance of protecting the i

public health and safety be different from such communications prior to April 30, 1980?

f. Will HL&P assure that the importance of protect-ing the public health and zafety is communicated to Brown and Root personne?.? Precisely how will HL&P accomplish that goal? How will HL&P person-nel themselves be involved in those communications? -

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g. Will the importance of protecting the public

' health and safety be communicated to both con-struction and QA/QC personnel?

h. Please detail the manner and circumstances in which the importance of protecting the public health and safety will be communicated and provide copies of such communications available to the NRC Staff.

20. What plants have been visited by !!L&P personnel to help

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plan for transition from construction to operation?

What personnel made those visits?

21. What consultants has HL&P enployed to study the technical support structure for transition from construction to operation?

22. Did the NRC Staff meet with the HL&P Prerident for pre-paration of NUREG-0780? If so, provide the notes of that meeting.

23. How did the NRC Staff investigate the attitudes and morale of HL&P or B&R individuals involved in the actual QA/QC program for preparation of NUREG-0780? Provide copies of any relevant documents, including specifically any surveys and survey results reviewed by the Staff in reaching its conclusions on OA/QC attitudes and morale, and identify all HL&P and B&R employees contacted by the NRC Staff in its Investigation of QA/QC attitudes and morale.

24. Define and detail any and all acts, apart from struc-tural changes, _taken by HL&P designed to change the attitudes of individuals working in the QA/QC program.

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25. How many times h3d the HL&P QA Program Evaluation Com-committee met prior to issuance of the Partial SER?

Has the NRC Staff reviewed the work of that committee?

What is the NRC's understanding of the purpose and work program.of that committee?

26. Has the NRC reviewed the QA/QC indoctrination and train-ing programs of HL&P?

27. Is any portion of NUREG-0780 intended to be an evaluation

.of HL&P's character and competence. If so, list the paragraphs which provide that evaluation. Describe how your review was designed to allow that evaluation and how the information reviewed supports the conclusions reached.

28.' Provide a copy of all written policies, procedures, and instructions implementing HL&P's QA program which were reviewed by the NRC Staff.

Respectfully submit ted- -

• ) - . ,

William S. Jordan, III Harmon & Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006

! (202) 833-9070 Counsel for Citizens fer Equitable Utilities, Inc.

May 4, 1981

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

In the Matter of )

) Docket No. 50-498 HOUSTON LIGHTING AND POWER CO. ) 50-499 (South Texas Project, Units 1 )

and 2) )

_ )

CERTIFICATE Or SERVICE l

I hereby certify that copies of the "CEU Interrogatories to the NFC Staff Based on the Partial SER," have been hand-delivered and mailed, postage pre-paid, this 4th day of May, 1981, to the following:

Richard S. Salzman, Chairman Mr. Ernest E. Ilil l Atomic Safety and Licensing Lawrence Livermore Laboratory Appeal Board University of California U.S. Nuclear Regulatory Commission P.O. Box 808, L-123 Washington. D.C. 20555 Livermore, CA 94550 Dr. John !!. B.1ck, Member Melbert Schwartz, Jr., Esq.

Atomic 'Jafety and Licensing Baker and Botts Appeal Board One Shell Plaza U.S. Nuclear Regulatory Commission Ilouston, TX 77002 Washington, D.C. 20555 Brian Berwick, Esq.

Charles Bechoefer, Esq., Chairman Assistant Attorney General l Atomic Safety and Licensing Environmental Protection Div.

Board Panel P.O. Box 12548, Capitol U.S. Nuclear Regulatory Commission Station Washington, D.C. 20555 Austin, TX 7811 Dr. James C. Lamb, III Edwin J. Reis 313 Woodhaven Poad Office of Executive Legal Chapel 11111, NC 27514 Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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, Jack R. Newman, Esq. Betty Wheeler, Esq.

Lowenstein, Newman, Reis, Tim !!offman, Esq.

Axelrad & Toll  !!offman, Stecq & Wheeler 1025 Connecticut Avenuc, N.W. 1008 S. Madison Washington, D.C. 20036 Amarillo,MrX 79101 Kim Eastman, Co-coordinator Atomic Safety and Licensing Barbara A. Miller Board Panel Pat Coy U.S. Nuclear Regulatory Citizens Concerned About Commission Nuclear Power Washington, D.C. 20555 5106 Casa Oro San Antonio, TX 78233 Atomic Safety and Licensing Appeal Board Docketing and Service Section U.S. Nuclear Regulatory Office of the Secretary Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, n.C. 20555 y n

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