ML20040C332

Answers to Sixth Set of Interrogatories Re Contention 5. Affidavit & Certificate of Svc Encl

ML20040C332
Person / Time
Site:	Comanche Peak
Issue date:	01/25/1981
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
NUDOCS 8201270540
Download: ML20040C332 (7)

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Janugr J25, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 JAN 26 A10:0-3 BEFORE THE ATOMIC SAFETY AND LICENSINGcBOARDkL, i,vtr,t nou & SW BRANCll In the Matter of )

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_and TEXAS UTILITIES GENERATING ) _

COMPANY, et al.

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-) (App cation _for G g (Comanche Peak Steam Electric ) Operating Licenses G Station, Units 1 and 2) )

G NC5]y gD :y APPLICANTS' ANSWERS TO CASE ' S

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SIXTH SET OF INTERROGATORIES I 67gO2A '

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Pursuant to 10 C.F.R. S 2. 740 (b) , Texas Ut.ilities Gen Company, et al. (" Applicants") hereby submit answers to " CASE's Sixth Set of Interrogatories to Applicants and Requests to

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Produce," served January *, 1982. Applicants will respond to CASE's requests to produce pursuant to and on the schedule provided for in 10 C.F.R. S 2. 741(d) .

I. SCOPE OF INTERROGATORIES CASE identifies these interrogatories as concerning Contention 5. In its December 18, 19 81 " Order Subsequent to Prehearing Conference of December 1, 1981," the Board severed the consolidation of CASE and CFUR for purposes of discovery ph

$f l1 1/ .The date on the first page of CASE's interrogatories is December 4: 1982. In addition, the attached " Certificate of Service" identifies the interrogatories as " CASE's 12/4/82 Sixth Set." The Certificate does, however, indicate that i the Interrogatories were served January 4, 1982.

8201270540 810125 PDR ADOCK 05000445 G PDR

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and cross-examination on Contention 5. CFUR had previously been designated lead-party Intervenor, for all purposes, on Contention 5.

II. ANSWERS TO INTERROGATORIES Each answer is identified by the number of the corresponding interrogatory as set forth in CASE's Sixth Set of Interrogatories.

1. a. Yes.

b. ASME did conduct a reaudit January 18-22, 1982. ASME does not direct its communications to Texas Utilities since the audit concerns Brown & Root activities.

c. Yes.

d. Applicants will respond to this request for production of documents pursuant to and on the schedule provided for in 10 C.F.R. S 2. 741(d) .

e. Not applicable.

f. Not applicable.

2. a. See Section 17.1.18 of the FSAR.

b. Section 17.1.18.

c. Applicants will respond to this request for production of documents pursuant to and on the schedule provided for in 10 C.F.R. S 2. 741(d) .

d. COI-CS-4.5 and CQI-CS-4.6.

e. See response to Interrogatory 2.d.

f. Applicants will respond to this request for production of documents pursuant .to and on the schedule provided for in 10' C. F. R. S 2. 741(d) .

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g. Applicants will respond to this request for production of documents pureuant to and on the schedule provided for in 10 C.F.R. S. 2. 741(d) .

h. The NRC conducts audits according to their own procedures.

This question is best directed to the NRC.

i. See response to Interrogatory 2.h.

j. In preparing for an audit, past audits which were conducted in the same area are reviewed. During an audit we look to . see if each deficiency is an isolated incident or a generic problem. Trends are detected by review of combined past and present information.

k. Applicants will respond to this. request for production of documents pursuant to and on the schedule provided for in 10 2.F.R. S 2.741(d) .

1. Auditing is not a Station (site) responsibility. That responsibility belongs to TUGCO Quality Assurance Division, located in Dallas, Texas.

m. Not applicable.

3. These reports are a matter of public record and are available in the Public Document Room.

4. Applicants are not sure what CASE means by the term " internal."

However, in order to expedite the ddscovery process, Applicants respond without making any_ distinction between the type of

-audits conducted.

Through February, 1978 Applicants performed eight (8) audits of Brown & Root. Since February, 1978 Applicants have conducted audits at the site on an activity basis rather than on an organizational basis. Brown & Root activities are included in these audits.

5. Of the eight (8) audits of Brown & Root conducted through February,1978, four (4) were conducted in Houston and four (4) were conducted at Comanche Peak. Since February,1978, audits were performed as described in the response to Interrogatory 4.

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6. The eight (8) audits of the Brown & Root organization conducted through February, 1978', have already been provided. Site activity audits will be made available for inspection and copying pursuant to and on the schedule provided for in 10 C.F.R. S 2.741(d).

7. a. -See Section 17.1.17 of the FSAR.

b. Section 17.1.17.

c. The information for the computerized records of concrete pours is taken from the concrete pour cards.

d. Applicants will respond to this request for production of documents pursuant to and on the schedule provided for in 10 C.F.R. S 2.741(d).

e. Applicants will respond to this request for production of documents. pursuant to and on the schedule provided for in 10 C.F.R. S 2.741(d).

Respect ul submitted, j

Nichol. S/ Reynolds 9 6.M William A. Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 l (202)857-9817 Counsel for Applicants l

I January 25, 1982

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s STATE OF TEXAS )

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'OlbTY OF DALLAS) c Homer C. Schmidt, being duly sworn, deposes ~ and says:

That he is Manager, Nuclear Services, Texas Utilities Services Inc., and knows the contents of the foregoing Applicants' Answers to CFUR's sixth Set of Interrogatories; that the same is true of his own knowledge except as to matters thertain stated on infomation and ,

belief, and as to that, he believes them to be true.

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Homer C. Schsidt Ida day of January 1982.

Subscribed and sworn to before re this OS W

Notary l . -?

This document is a telecopy. Applicants will furnish the original by separate cover.

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a UNITED STATES OF AMERICA 9f[f NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'82 JAN 26 A10 :05 In the Matter of )

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h ggg URANCH TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al.

) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing

" Applicants' Answer to CASE's Sixth Set of Interrogatories",

in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 25rd day of January, 1982:

. Marshall E. Miller, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commiasion Washington, D.C. 20555 Washington, D.C. 20555 Dr. Kenneth A. McCollom Marjorie Ulman Rothschild, Esq.

Dean, Division of Engineering Office of the Executive Architecture and Technology Legal Director Oklahoma State University U.S. Nuclear Regulatory Stillwater, Oklahoma 74074 Commission Washington, D.C. 20555 Dr. Richard Cole, Member Atomic Safety and Licensing David J. Preister, Esq.

Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C. 20555 P.O. Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory J. Marshall Gilmore, Esq.

Commission 1060 W. Pipeline Road Washington, D.C. 20555 Hurst, Texas 76053

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Mr. Richard Fouke Mr. Chase R. Stephens 1669-B Carter Drive Docketing & Service Branch Arlington, Texas 76010 U.S. Nuclear Regulatory Commission Mrs. Juanita Ellis Washington, D.C. 20005 ~

President, CASE 1426 South Polk Street Dallas, Texas 75224 William A. Horin cc: Homer C. Schmidt Spencer C. Relyea, Esq.

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