ML20039G563
| ML20039G563 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/15/1982 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CITIZENS FOR FAIR UTILITY REGULATION |
| References | |
| NUDOCS 8201180429 | |
| Download: ML20039G563 (7) | |
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1/15/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0fIC SAFETY AND LICENSING BOARD In the Matter of U
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Docket Nos. 50- 5 p*C g
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(Comanche Peak Steam Electric
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NRC STAFF'S FOURTH SET OF INTERR0GATORIES T0, AND
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REQUEST FOR DOCUMENTS FROM, INTERVENOR CFUR The NRC Staff (" Staff") herebv requests that Intervenor CFUR, pursuant to 10 CFR 69 2.740b and 2.741, answer separately and fully, in writing under oath or affirmation, the following interrogatories and produce or make available for inspection and copying, all documentary meterial indentified in the responses to interrogatories below. Accord-ing to the schedule established by the Atomic Safety end Licensing Board
(" Licensing Board") in its " Scheduling Order" issued on December 11, 1981, these interrogatories must be answered by January 22, 1982.
All references provided in response to these interrogatories are to be identified by author, title, date of publication and publisher if the reference is published; if any such reference is not published, it is to be identified by author, title. date it was written. the quali-fications of the author relevant to this proceeding, and the location where a copy of the document may be obtained.
All persons named in response to these interrogatories are to be identifed by name, address, employer, position, education, professional
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qualifications, and publications related to their views concerning the subject matter of this proceeding.
INTERROGATORIES ON CONTENTION 7 C7-24.1/ Do you concur that the Applicants' determination of the static and dynamic properties of the materials underlying the site is adequate for:
a) foundation bearing materials that did not require grouting and which were not grouted; b) foundation bearing materials-tnat did require grouting and which were grouted in accordance with Brown and Root, Inc.
Construction Procedure 35-1195-CCP-36; c) foundation bearing materials that did require grouting, and which you contend were not grouted in accordance with Brown and Root, Inc. Construction Procedure 35-1195-CCP-36; e.g.,
areas that contain " loose reck air pockets and other ioreign material."
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C7-25.
If your answer to any of the above questions is in the nega-tive, please specify and explain the substance and nature of your objections.
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Since the first and second set of interrogatories filed by th.
Staff on January 19, 1981 and April 10, 1981 also contain interrogatories relating to Contention 7, the numbering of the interrogatories in this fourth set will begin where the second set of interrogatories ended.
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r C7-26.
Do you concur that the Applicants' determination of the maximum vibratory acceleration of the Safe Shutdown Earthquake (SSE)_is adequate for:
a) foundation bearing materials that did not require grouting and which were not grouted;'
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b) foundation bearing materials that did require grouting and which were grouted in accordance with Brown and Root, Inc. Construction Procedure 35-1195-CCP-36; c) foundation bearing materials that did require grouting and which you contend were not grouted in accordance with Brown and Root, Inc. Construction Procedure 35-1195-CCP-36; e.g., areas that contain " loose rock, air pockets and other foreign material."
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C7-27 If your answer to any of the above questions is in the nega-tive, please specify and explain the substance and nature of your objections.
C7-28.
Do you concur that the Applicants' evaluation of areas of actual or potential surface or subsurface subsidence, uplift
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or collapse resulting from man's activities is adequate for:
a) foundation bearing materials that did not require grouting and which were not grouted;
-b) foundation bearing materials that did require grouting, which were grouted in accordance with Brown and Root, Inc.
Construction Procedure 35-1195-CCP-36; l~.
c) foundation bearing materials that did require grouting, and which you~ contend were not grouted in accordance with Brcwn and Root, Inc. Construction Procedure 35-1195-CCP-36; e.g.,' areas that contain " loose rock, air pockets and
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other foreign material."
C7-29.
If your answer to any of the above questions is in the nega-
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c tive,'please specify and explain the substance and nature of e.
your objections.
s C7-30.
In response to Interrogatory C7-23, you identify George Clancy and C.A. Thetford as "ex-employees of Brown and. Root" who pro-c.
vided CFUR."with reason to believe that loose rock material j '.
was thrown into the over-excavation prior to the. pouring of
~ concrete." Wilthrespecttoeachoftheseindividuals,please provide:
, - a)
The locations where the' individual observed loose rock either in or being thrown in over-excavation and the date
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of each observation.
b) the locations where each individual observed loose rock being covered by concrete and the date of each observation.
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The specific job title and work location of the individual at the time of each observation described in 3
f response to parts (a) and-(b). above.
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Respectfully submitted, M
.u (A.. ILMclu'/d Marjorie U. Rothschild 1
Counsel for NRC Staff i
Dated at Bethesda, Maryland This 15th day of January,1982
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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TEXAS UTILITIES GENERATING COMPANY, ET AL. )
Docket Nos. 50-445
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50-446 (Comanche Pe'ak Steam Electric Station,
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Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies "NRC STAFF'S FOURTH SET OF INTERROGATORIES T0, AND REQUEST FOR DOCUMENTS FROM, INTERVENOR CFUR" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or through deposit in the Nuclear Regulatory Commission's internal mail system (*), or by express mail (**) this 15th day of January, 1982:
Marshall E. Miller, Esq., Chairman
- Mrs. Juanita Ellis Administrative Judge President, CASE Atonic Safety and Licensing Board 1426 South Polk Street U.S; Nuclear Regulatory Commission Dallas, TX 75224 Washington, CC 20555 David J. Preister, Esq.
Dr. icenneth A. McCollom Assistant Attorney General Admisiistrative Judge Environmental Protection Division Dean, Division of Engineering, P. O. Box 12548, Capital Station Architecture and Technnlogy Austin, TX 78711 Oklahoma State University Stillwater, OK 74074 Mr. Richard Fouke**
1668-B Carter Drive Dr. Richard Cole, Administrative Judge
- Arlington, TX 76010 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Nicholas S. Reynolds, Esq.
Washington, DC 20555 Debevoise & Liberman 1200 17th Street, N.W.
J. Marshall Gilmore, Esq.**
Washington, DC 20036 1060 W. Pipeline Road Hurst, TX 76053 9-w-
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i Atouic Safety and Licensing Board Docketing and Service Section (1)*
Panel
- Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Corivnission Washington, DC 20555 Washington, DC 20555 I
Atomic Safety and Licensing Appeal 1
Panel (5)*
4 U.S. Nuclear Regulatory Commission Washington, DC 20555 1
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IS Ps.,_!.e-l1 Marjorie Ulman Rothschild Counsel for t!RC Staff j
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