ML20008G217

Summary of Intervenor Stamiris Outstanding Discovery Requests Per 801204 Document Requests & Interrogatories, Revised 810126.Related Correspondence

ML20008G217
Person / Time
Site:	Midland
Issue date:	04/28/1981
From:	Stamiris B AFFILIATION NOT ASSIGNED
To:
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8107020462
Download: ML20008G217 (9)

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ll dB t g2 (%e e U.S. NUCLEAR REGULATORY CCMISSICN f m In the matter of Docket Nos . 50-329 C.P. Co. Midland Plant 50-330 Units 1&2 OM & OL BEFORE THE ATOMIC SAFETY AND LICENSING EOARD l 4/28 /81

SUMMARY

OF INTERVENOR OLTTSTANDING DISCOVERY RECLTSTS Document Requests and Interrogatories of 12/4/80 RECUEST, REVISED 1/26/81 DOClMENT RECUESTS: tJNANSWERED

2. What are the most recent estimates for total soil settlement. costs..?

!.pplicant's 2/27/81 reply stated Bechtel was developing " additional cost and schedule projections." I have received additional'schedula projections only. I want the mos t recent total cost projections ,

including attimates far Borated WST and Service Water Building revisions when they are ready.

4. I requested documentation of " discussions or considerations concerning possible lawsuits involving soil settlement matters" on 12/4/80. On 3/23/81 I accepted the claim of attorney client privelege for the one document cited in Applicants 2/27/81 response, beyond the one provided. Cuestions 4a,b,c of 3/23/81 require 54 9sa-(

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simply a yes or'no ans=cer to confirm or deny the existance of '

the documents described. Part d requests identification of documents I objected to here.

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5.I requested documents regarding the Administration Building settlement and did receive such documents. In our March compromise ,

conversations,(regarding interrogatories 2 and 3) Mr. Brunner i indicated that he had giver. me the whole file on the' Administration Bldg.

and thought I would find answers to my own questions therein.

I did not, and filed the 3/13/B1 motion to compell Sb-Se, which answers are still outstanding.

INTERROGATORIES: FOLLOW UP I

l 2.and 3..These questions.regarding consultant differences,and changes to consultant recommendations,respectively,were answered according to our 3/b! compromise conversations on March 30.

The following questions represent my first opportunity to ask any follow up or clarifying questions to these answers, combined in Applicants March 30 Response.

1. /ho made up the decision making Bechtei/CPCo " task group" as it functioned in 19787

2. On what basis were these individuals appointed?

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5. Describe in detal!'the " management review" process. <

4. How has this group and its management review changed or evolved since 1978 (regarding members, function or other changes)?

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5. Were a!! decisions of the task group subject to this management review? If not, describe who determdned which decisions were so

. reviewed and on what basis.

6. Who were the management individuals involved in this review in 1978-79, and at the present timmt FOLLOW UP ctESTICES TO 1/14/41 REQUEST IST ANSWERED BY APPLICANT 3/30/81 (numbers correspond to original request)

4. Were any attempts made to measure settlement or stress at the Administration Building between the Sept. 1977 reaediation and the Sept.1978 settlement monitoring program? .t:

5. The reports provided were numbered SB 13752- SB 13956 although not in that sequence and with many pages missing. It appears that these Bechtel reports stemming from the Administration Building settlement problem have to do with plant area f!!! soils and as such are-Important to this proceeding. Please provide tnere f11e pages: SR 13770,1J771,13790-13794, 13816,13817,13818,13820-13854,13867-13912,13920-13953,13955 and any beyond SB 13956 in l this s e r ic's on -sotts'.

PIcase provide all studies, reports,information , or test results initiated in 1977or 1978 relating to plant area soils which have l

not already been presented to the NRC as 55e or 54f reports ,or requests.

D6 such docwaents exist that yo" consider not related to this proceeding?

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6. When specifically were the Bechtel specifications and drawings issued which established the foundation data survey program for the ~D3B7 ,Wers other rettlement monitoring programs established or revised in 1977. Ifryes,when?!.Di@.thare relate in any way to stud [c3 following the Administration Building settlement?

7. Were there any scribe marks or benchmarks for DGB foundation prior to May 19787 Describe and give dates of such.

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8. In the Sept. 28 ,,2978 meeting notes, tab 1 Vol.3 50-54f, item 3b. mentions-the excavation at the Admir:1stration Building. Was the reason tfor this excavation explained or discussed with Dr.

Peck at this meeting? If so relate the details of this disclosure.

9. 'According to Mr. Gallagher, this information te not correct.

10. In seeking these documents, I hoped to find out on what basis the original dewatering plan was eliminated. This is related to a matter in controversy as set forth in discovery provision 2.740(1). Documents concerning the basis for this elimination decision should be provided.

II.No questions.

12. The response does not answer the question asked. The Sept. 28, 1970 meeting, tab 1 Vol.3 50-54f, item 4 states "no long term recordr. of ground water are available for the Midland site."

Ars. there not requirements for such information established by the NRC or the Applicant ( which demanc that groundwater levels be known1 What are these recuirements7

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13. What, work was done between Dec. 6,1979 and the end of Apr.  ;

1960 on the DOB cr its foundation? Please dCacuss any e n avations howe ,sr minor,:. seating of cracks, or hther work re!&ted directly or I tractly to soil ortteil settlement. Give he dates of such

.s work"and whether or mot the NRC was notified. Provide the cousun-ic'atio'n to the ASI.B regarding temporary davatering. Describe the y .

4ocation and the work mentioned regarding curbs and grade slabs.

I(I incorrectly remembered the date of the voluntary stopwork announcement when asking for work since April. If there are additions to the information provided for the post April time frame in view of the above requests, please provide such additions.)

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16. Provide the names and addressesiof 1.

CA or CC personnel, or management who have terminated their employment with CPCo. or Bechte t in 1980-81. Give job titles.

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1 p . FURTHER OtJTSTANDING REOliESTS :

THE 3/Z7/83 DISCOVERY REOUEST (OBJECTED TO 4/16/81, ANSWERED 4/23/81)

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QUESTICNS ON CONSULTANT,RECOWINDATICits & COMMUNICAT1cN,5 OF C.J.D.

(These questions are:not .

related to. answers given, but had my 12/4/80 requests:. bee ansm ered sooner, I be'lieve I would have comer up' with.1thesequsit f ods0within a few weeks of such answer.

I m a11re they are beyond the scope of thu March compromise I

agreements, and therefore'iseek to ask them only with the Board's affrovo).) .

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f 1.The Oct. 18,1978 meeting notes (tab 5 Vol'.3 50-54f) item 10 in . .

states " Insta!!ation wou1;1'need to be manned by Bechte! due to current GZD work lohd'! n) What were the qualifications and experience of -the Bec bel personnel. Involved.7 b)'Did SRI approve Bechtels Installa on plea and work? c).What was the il reason (according to CJ Duncliff)that he sent the SRI CA r.unnual for Marshall to"acknowledgle or return"? (Nov.1,1978 CJD memo, it tab 10 Vol.3 S4f) d) What. kere Bechts!s decisions on settlement

S gages as discussed in items 6 and 7 in 11/1 meno? e) Why didn't i

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Bechtel await SRI personnel accomplishment of installation work?

f) Were these and other in'strumentation and Installation decisions made and reviewed by the " task group " process described in the previousquestion27g)Wh;enwerethetwopiezometersinstalled, discussed in item 8 of the! Nov. 6,1978 (tab 10 Vol.3 54f)7 Give l I

dates of any earlier CJD lnstrumentation installed. h) What was the dollar amount of equipment ordered from SRI or'Its suppliers

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I April 28, 1981

Dear Judge Bechhoefer and Consumers Attorneys,

This document contains no new requests, but brings together l

my previous outstanding discovery requests in an attempt to facilitate the review necessary. As such this document supercedes the 4/23/81 FOttDW UP REOUESTS presentea af, the Prehearing Conference April 27th.

I believe a major disagreement between myself and the Applicant concerns the relevance of the Administration Building settlement problem to this proceeding. Although it is not a Category I structure, i "It is supported by plant area fill material compacted and tested to the same requirements as material supporting safety-related structures and therefore pertinent to the current settlements I

being experienced by the DGB." as stated in NRC I&E Report 78-20.

Applicants 4/12/81 objection to my 3/23/81 motion to compell anst.ers 5b-Se on the Adadnistration Building, states that the l

1 relevance of the Administration Building to these proceedings is limited to my contention Sc.which states that the Administration l' Building "should have served as a quality indicator, creventing the same inadecuate proceedures from occuring in the 1978 construction 1

of the DGB..."

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Although,asIagatedismy3 /b3 answa to App!! cants (Sm,3n)

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' interrogatories, I now realize thaththe. fill ' soils'were placed

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in the saas time'fraa4(for the Adalhistration[ Bldg. and the DOB, s., ve . .

and that ths 'first; hirNr for' the DG$ took'placs in Oct.1977; I s- .

,{-  ?,t maihtiin'thhtnit6'setttementPshould.have: served as a quality' l

s. . 1 indicator" prevehting" the DGB sett1lement prob'.lems.

It isprecksely'thispointtNatI'amattemptingtofurther I

eartablish in my interrogatories and document requests relating )

to the Administration' Bu!1 ding. I believe that there may be a I l

great deal of information relating to plant area till soils 1

which is relevant to this proceeding which has not come out because the Applicant cons'iders the Administration Building probles irrelevant to this. proceeding, ras -it!!s 'not a Categor / - 1 I structure. My studies of the documents produced have raised many unanswered questions and led me to believe there are more documents on plant area soils regarding studies and information, which arose from the Administration Building problem,that could be crucial to this proceeding For these reasons,I consider my document requests on this subject (/5 of 1/14/81 Fo11ov Up Requests) as essential to my position and this proceeding as a whole. Further part 2.740(b)1, on the scope of discovery clearly permits seeking information

" reasonably calculates to lead to the discovery of admissable l 1 i

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j evidence.' Although t,his request may involve a large nsaber of documents,, thers should act be sa madee burden placed on the Applicant as there should be ao redactlea involved.

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6 Sincerely, A hwd4A copies sent:

Judge Bechhoefer,ASLB Dr. F. Cowan, ASLB Admin. Judge R. Decker,ASLB Wm.Paton,Esq.,NRC J. Brunner,Esq,CPCo Secretary, NRC ,

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