ML20039C691

Joint Interrogatories & Request for Production of Documents. Certificate of Svc Encl

ML20039C691
Person / Time
Site:	South Texas
Issue date:	12/21/1981
From:	Buchorn P Citizens Concerned About Nuclear Power, INC., CITIZENS FOR EQUITABLE UTILITIES
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8112300046
Download: ML20039C691 (6)

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY CChhISSION g g

ta:gg-BEFCRF THE ATCNIC SAFETY AND LICENSING BOAlj])

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CEU AND CCANP JOINT I::TERROGATCRIES AND REQUEST at FCR FRCDUCTION GF DCCUMENTS TO NRC AFF PURSUANT TO BOARD ORDER OF DECEMBER , 1981 Citizens for Equitable Utilities and Citizens Concerned About Suelear Fower file these joint interrogatories and request for production of documents pursuant to the board Order of Lecember _ ,

1981, in which CCANP Contentions 23 through 26 were admitted and discovery on I.&E. Report /181-28 was granted. Intervenors request that they be answc"ed in writing and under oath by employees, agents or contractors of the NRC Staff who have personal knowledge of the facts in question.

4 in connection wi b these interrogatories the following definitions shall apply:

As used herin, the term " document" means any '.ritten or graphic matter of communication, however produced or reproduced, and is intended to be comprehensive atd include, without limitation, anp and all corres-pendence, letters, telegrams, agreements, notes, l contracts, instructions, reports, demands, memoranc",

i data, schedules, notices, work papers, recordings, l

l wnhther by electronic or other means, computer data,

, b /.rs . Buchorn had not received the Board Grder and was unable j to place the exact date of the Board Order on this document.

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computer print outs, photographs, microfile, microfiche, charts, analyses, intra-corporate or intra-office commun-ications, notebooks, diaries, sketches, diagrams, forms, manuals, brechures, lists, publications, drafts, telephone minutes, minutes, statements, calendars, journals, crders, confirmations and all other written or graphic material of any nature watsoever.

(1.) '4 hat is the ':RC Staff position on CCAUF Contention #23*:

Jtate all facts and opinions and identify and provide copies of all documents on which that opinicn is based.

(2.) Xhat is the hRC Staff position on CCAMP Contention #24?

State all facts and opinions and identify and provide copies of all documents considered in reaching that opinion.

1 (3.) Please explain in detail how the decision is made in assigning initials to individuals involved in I&E Report 81-28. In addition please set cut the physical location of each individual that was interviewed, civing the address of each.

1 (4.) dere an.y Brown a Root em_ulo. vees interviewed during. the 81-28 i investigation? If the answer is yes, please state which individuals 4

and cive the time and physical location cf each at the time of the interview. If the answer is no, please explain why not. l 1

( .) ,oy each individual _55R J

lease state a,ll inferration supplied erployee in detail including but not limited to all documents, meccs, notes and letters examined by +he investicators/ inspectors.

l (E.) Jhat is the UP: Ztaff position en 1 CAMP Contentien t!25? State  ;

c11 facts and opinicns and identify and provide copies of all l l

dccumentp consicered in reachinr that position.

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(7) Please provide copies of the following documents:

'i;ccument 1 - liilP office memo SG-7050, dated June 5, 1981 Document 2 - !!II1 office memo 6Q-9000, dated June ll,1981 Document 3 - 1%R letter, SFG <Q-0100, dated June 30, 1981 Document 4 - i!IAF office memo ng-5 COO, dated July 24, 1981 Document 5 - :iL&P letter, SFU yu-3200, dated August 24, 1981 (S) Please explain in detail how the NEC investigator / inspectors identifiec UCR ST-51 as the UCR referred to in the IIL&P office meto dated June 5, 1981.

(9) Is the NRC aware of any actions after August 22, 1981 taken by individual W regarding the resolution of NCR ST-5A? Please explain in detail providing copies of all documents relied on in formulating the answer to this interrodatory.

(10) Please provide copies of all documents, including but not limitec to the notes taken by investigators / inspectors, regarding the investigatien leading to I&E Report 81-28 (11) Please describe in detail all centuets between NRC investigators /

inspectors and h i- !.ucitors subsecuent to the respcnce letter re fe rred to as Attachment 5 in 1h , Heport 9-28.

4 (12) <lhere was individual C located? siouston, Eayview or STP Site?

(13) Xhere was individual .. located at the time he supervised individual C?

(14) ~cihere was individual h located at the time he supervised individual C?

(15) Please state your inpressions or belief regarding the reason that supdrvision of individual C was removed from individual X and given to individual 4.

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(16) Given the fact that both individual X and individual W are 90 miles from individual C, is there reason to believe that the background, experience and expertise of individual W is superior to that of individual X? Please explain in detail whether the answer is yes or no and provide copies of all documents relied on in formulating the answer to this interrogatory.

(l'/) To the bes' af your knowledge, has individual W clarified individual C's job function. Please explain in detail and provide copies of all documents relied on in formulating the answer to this interrogatory.

(18) Please detail the nature of the confusion on the part of

llb? QA personnel as to who actually writes up an NCR?

(19) Please identify which three individuals stated that they h&d nct _ound any discrepancies and therefore had not written an UCR in the 6 months prior to the investigation.

(20) Please identify the one individual that discovered an NCR condition, took his concerns to individual C, and was told to "t ell 13rown a F c o t to write up the NCB". 2xplain fully what the 4

condition was and if the HRC investigator / inspector determined

'thether IER personnel actually wrote up the NCR.

(21) I;id the individual beleive it was within his power to determine whether or not P5R actually wrote up the NCR and did he state that it was resolved in a timely ar.d effective manner?

(22) Please indicat wnich individual was absent during one of the training periods on HIn? procedures.

i (23) Fle.ase state whether or not the :IRC investigator / inspectors were given access to individual O's lor of his departments NCR's.

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e (24) If the answer to interrogatory 23 is yes, please provide a copy of the log and any other documents provided by individual C.

If the answer is no, please explain.

(25) What is the NRC Staff position on CCANP Contention //26?

State all facts and opinions and identify and provide copies of all docu:r.ents considered in reaching that position.

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Respectfully Submitted,

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l' 9 tju ! b cyr2n Mrs. Peggj Buchorn, Exec. Dir.

Citizens for Equitable Utilities Route 1 Box 1684 Brascriu, Texas 77422 4

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CEHTI FIC ATE CF S':"n VICE I hereb;, certify that copies of the attached documents were T. ailed first class postage pre-paic this 21st day of Decem-ber, 1 81 to the following:

"- arles Jechoefer, Esq., Chairman 'i.elbe r t Schwartz , Jr. , Esq.

itcric 'afety and !.lcenrine Baker and Botts roard Pan-~ 1 'ne Shell Plaza U.J. ':uclear ~ierulat or: Ccamissicn iouston, I'X . 77007

.arinr*.on, l.J. 'OY Mwin J . Reis

.r. vames J. Lamb, lii affice of Executive Legal

??5 acedhaven Reai Directcr apel Hyll, ': ort:. 'arelin; ' 14 " . :1  !;uclear Regulatory coraissicn

r. I.rnest c. . iill ..c:chington, U.C. 20555

.awrence Livermore Lataratcry

'niversity of California Jack 11. Newman, Esq.

.u. -3cy rn-a c, u-r

. .r' Lowenstein, ..ewman, n eis, .

Iverrare, California 4'50 & Axelrad 1025 Conn ec ticut Avenue ,I;.W. ,

sria". 2erwick, Esq. F1214

'. s s i s t an t At t orne:. General z.ashington, D.C. 20036 ynvirennental Protection Div.

.u. 1 locketing and Service

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,ex? as54 -,b8, C'ipitol Stati on i t i l

e e ,v i o n Jffice of the Secretary Kr. .illian J. Jeriin III 11 1 'Iuclear Regulatory

..rTan d.d /eiss Commission "M i g reet, ': . h . Aashinrton, D.C. 20555

.alte Ce .

abington, .u. 0mtvo

Lanny Cinkin Pat Cov 22C7-1; :ueces Citiseils Concerned About Austin, TX 76705 Huclear Power 5106 Casa Oro Atomic Jafety and Licensing San Antonio, Texas 78233

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