ML20040G672

Forwards Citizens Association for Sound Energy First Set of Interrogatories & Requests to Produce.Related Correspondence

ML20040G672
Person / Time
Site:	Comanche Peak
Issue date:	02/10/1982
From:	Ellis J Citizens Association for Sound Energy
To:	Cole R, Mccollom K, Mark Miller Atomic Safety and Licensing Board Panel
Shared Package
ML20040G673	List: ML20040G672 ML20040G679
References
NUDOCS 8202160357
Download: ML20040G672 (3)

Text

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• tunna conansro:mmes5 Vfh5 2/10/82 UNITED STATES OF AMERICA' 'B2 N NUCLEAR REGULATORY COMMISSION - , _ . .

.....-r BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ,

I APPLICATION OF TEXAS UTILITIES Docket Hos. 50-445 GENERATING COMPANY, ET AL. FOR and 50-446 AN OPERATING LICENSE FOR I

COMANCHE PEAK STEAM ELECTRIC <

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Administrative Judge Marshall E. Miller

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Washington, D. C. 20555 '

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Dr. Kenneth A. McCollom, Dean Dr. Richard Cole, Member Q3 ['

Division of Engineering, Atomic Safety & Licensing Board Architecture, and Technology U. S. Nuclear Regulatory Commission Oklahoma State University Washington, D. C. 20555 Stillwater, Oklahoma 74074 Subj ec t: CASE's First Set of Interrogatories s and Requests to Produce to NRC Staff l ~ ..

Pursuant to 10 CFR 2.720(h)(2.)(ii) and 2.720(h)(3),' CASE herewith files the attached First Set of Interrogatories and Requests to Produce to NRC Staff, .

In support thereof, we would show the following:

(1) All of the interrogatories deal directly with matters in controversy in these proceedings under Contention 5, which states:

The Applicants' failure to adhere to the quality assurance /

quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the require-ments of Appendix B of 10 CFR Part 50, and the construction go3

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practices employed, specifically in regard to concrete work, mortar blocks,' steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect QA/QC, and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility. As a result, the Commission cannot make the findings required by 10 CFR 50.57(a) necessa{y for issuance of an operating license for Comanche Peak.

Therefore, these interrogatories and requests to produce are entirely relevant and necessary to a proper decision in this proceeding.

(2) The answers to these interrogatories are not reasonably obtainable from any other source.

CASE spoke by phone with Marjorie Rothschild of the NRC Staff the week of February 1, 1982 (my note regarding

.the exact date is not readily available)at the time of this writing) and advised that we would be requesting the information in question 1, since Applicants had advised that our interrogatory to them regarding this should be answered by the NRC Staff. See Applicants' January 25, 1982 (erroneously dated January 25, 1981 in the upper right-hand corner of page 1 but correctly dated on the certificate of Service) Answers to CASE's Sixth Set of Interrogatories and Applicants' February 8, 1982 Response to CASE's Sixth Set of Requests for Production of Documents 1

In its 10/31/80 rulings, the Board construed Contention 5 to cover the Inspection and Enforcement Reports identified by ACORN in its Offer of Proof of August 29, 1980.

and Clarification of Responses to Certain Interrogatories, response to Questions 2.h. and 2.1., pages 3 and 4, respectively.

Question 2 pertains to NRC Staff witnesses and can only be answered by the NRC. Depending on the individuals the Staff plans to call as witnesses and the Staff's recponses to Questions 1 and 3, CASE may need t.o request chat-additional witnesses be called. .

We cannot make this determination without the information requested in Question 2.

Question 3 pertains to audits and reaudits and the withdrawal by ASME of the Certification Stamps and the Certificates of Authorization at Comanche Peak. CASE believes this is of great importance to these proceedings and that these questions must be answered to assure a proper decision in these proceedings. These particular questions can only be answered by the NRC Staff.

For these reasons, CASE requests that the Board direct the NRC Staff to expeditiously answer our questions and provide the documents requested.

Respectfully submitted, o- E f/A D g{Mrs.) Juanita Ellis, Presiaent CASE (Citizens Association for Sound Energy) 1426 S. Polk, Dallas, TX 75224 214/941-1211, work 214/946-9446, home

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