ML20040G685

Seventh Set of Interrogatories & Requests to Produce. Certificate of Svc Encl.Related Correspondence

ML20040G685
Person / Time
Site:	Comanche Peak
Issue date:	02/10/1982
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8202160366
Download: ML20040G685 (9)

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UNITED STATES OF AMERICA NoCLEAR REcu m oRY C mxIsSIOn 72 FS 11 p A :i5 BEFORE THE AT WIC 8AFrrY AND LICENSIF, BOARD --

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In the Matter of l l Docket Nos. 50-kk5 APPLICATION OF TEIAS IffILIMES l a'ad7 50;446x GENERATING COMPANY, ET AL, FOR AM OPERATDK3 LICEESE FOR COMANCHE l

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PEAK STEAM EI2CTRIC STATION l ,

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.. Q CASE'S SEVENIE SET OF INTERROGATORIES k TO APPLICAFFS AND REQUESTS TO PRODUCE h (, ( ' ,

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COG 8 NOW CASE (Citizens Association for Sound Energy), here r referred to as CASE, Intervenor herein, and files this, itsSeventh Set of Interrogatories to Applicants and Requests to Produce.

Pursuant to 10 CFR 2.7kOb and 2 741, please answer the fol. lowing interroga-tories in the manner set forth berewith, Each interrogatory should be answered fully in writing, under oath or affirmation, and include all pertinent informa-tion known to Applicants, their officers,* directors or employees as well as any pertinent information known to their advisors or counsel. -_Each request to produce applies to pertinent documents which are in the possession, custody or control of Applicants, their officers, directors or e:nployees as well as their advisors or counsel. Answer each interrogatory in the order in which it is asked, numbered to correspond to the nu:ndr of the interrogatory; do not ecambine ansvers. Please identify the per son providing each answer or response.

These interrogatories and requests to produce shall be continuing in nature.

i Thus, any time Applicants obtain information_.which renders sny preiious response go3 r

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inccrrect er indicatos that a rospouce vao incerrect whon mado, Applicants should supplsenent their previous response to the appropriate interro6atory or request to produce. Applicants should also supplement their responses a4 -

necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testianouy, cod the ' substance of that testimony. The term " documents" shall includa aay  :

vritings , drawings, graphs , charts, photographs , reports, studies, sai other data ecuspilations trous which information can be obtained. We request that at l c date or dates to be agreed upon by mutual consent, Applicants make arallable  !

for inspection and copying all documenta which CASE has specifically requested or subject to the requests set forth below. All interrogatories which do not request documents should be answered pursuant to 10 CFR 2 7h(b).

CONTENTION 5: The Applicants' fallure to adhere to the quality assurance /

quality control provisions required by the construction permits for Comanche Peak, Units I and 2, and the requirements of Appendix B of 10 CFR Pa rt 50, and the construction practices employed, speci fically in rega rd to concrete work, mortar blocks , s teel, f racture toughness testing, expansion joints, placement of the reactor vessel for Unit

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2, welding, inspection and testing, materials used, craft labor quall-fications and working conditions (as they may af fect QA/QC, and training and organi za tion of QA/QC pe rsonnel , have raised substantial questiods as to the adequacy of the construction of the f aci l l.t y . As a result, the Commission cannot make the findings required by 10 CFR 550.57(a) necessary for issuance of an opera t ing l i c e n *,e for Comanche Peak.I In its 10/31/80 rulings , the Board const rued Contention 5 to cover the inspection and Enforcement Reports identified by ACORN in i ts Of fer of .

Prcof of Augus t 29, 1980.

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INTERROGATORIES AND REQUESTS FOR DOCUMENTS

1. The following have to do with the ASME'(American Society of Mechanical Engineers) Nuclear Survey conducted October 12-14, 1981, ASME's request for the return of the Code Symbol Stamps NA & NPT and expiration of NA & NPT Certificates of Authoriza-tion on January 8,1982, and reaudit by ASM{ January 18-22, 1982, and related documents and activities (a) Did Applicants inform the Atomic Safety and Licensing Boa rd of the certification problems?

(b) If the answer to (a) above is yes, provide for inspection and copying all documents pertaining to such notification by Applicants and response by the Board. If verbal communi-cation was made, give specifics.

(c) If the answer to (a) above is no, please explain why Appli-cants do not believe such certification problems come within the Board's Order to Applicants to keep the Board advised of significant events in these proceedings.

(d) Did Applicants inform the NRC Staff of the certification problems?

(e) If the answer to (d) above is yes, provide for inspection and copying all documents pertaining to such notification by Applicants and response (s) by the NRC Staff. If verbal communication was made, give specifics.

(f) Were members of the NRC Staff present during the October 12-14, 1981, ASME audit?

(g) If the answer to (f) above is yes, supply the names of all NRC Staff personnel who were present.

(h) Were members of the NRC Staff present during the January 18-22, 1982, reaudit by ASME?

l CASE's 1/4/82 Sixth Set of Interrogatories to Applicants and Requests to Prdduce, and Applicants ' 1/25/81 Answers to CASE's Sixth Set of Interrogatories.

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(i) If the answer to (h) above is yes, supply the names of all NRC Staff personnel who were present.

(j ) Provide for copying and inspection all documents provided by the ASME and all answers thereto by Texas Utilities and Brown and Root regarding the reinspection by the ASME team January 18-22, 1982.

(k) Provide the names and addresses of all Texas Utilities per-sonnel who were present and/or involved in any discussions with the ASME team regarding th,e.0ctober 12-14, 1981, ASME inspection. Specify the personnel who were actually present during the inspection.

(1) Provide the names and addresses of all Brown and Root per-sonnel who were present and/or involved in any discussions with the ASME team regarding the October 12-14, 1981, ASME inspection. Specify the personnel who were actually present during the inspection. -

(m) Provide the names and addresses of all Texas Utilities per-sonnel who were present and/or involved in any discussions with the ASME team regarding the January 18-22, 1982, ASME reaudit. Specify the personnel who were actually present during the reaudit.

(n) Provide the names and addresses of all Brown and Root per-sonnel who were present and/or involved in any discussions with the ASME team regarding the January 18-22, 1982, ASME re-inspection. Specify the personnel who were actually present during the inspection. ,

(o) Provide for inspection and copying all documents by Texas Utilities and Brown and Root regarding both the October 12-14, 1981, and January 18-22, 1982, inspections by ASME.

Include (in addition to documents defined on page 2 of d11s pleading) all work papers, internal memoranda, news-releases, and any other pertinent data or information.

(p) Provide the names and addresses of all ASME personnel who were present and/or involved in the October 12-14, 1981,

, and/or the January 18-22, 1982, audit and reaudit by ASME.

Specify the personnel who were actually present during the audit and reaudit.

(q) Provide for inspection and copying all documents by the NRC Staff regarding both the October 12-14, 1981, and January 18-22, 1982, inspections by ASME.

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1. (continued): -

(r) In the December 17, 1981, letter from Arlene A. Spa'dafino, Director, Accreditation, ASME, to R. J . Vurpillat, :QA Mgr., Brown & Root, it is stated: ". . .the subj ect Cer-tificates are being extended by separate letter." .(Emphasis added.)

Was there such a letter? If so, why was it not supplied -

to CASE in response to Question 1.d. of our Sixth Set of Interrogatories and Requests to Produce? If so, please provide it immediately for copying and inspection..

(s) In the same December 17, 1981, letter referenced in (r) above, it is stated that Brown & Root and/or its repre-sentatives could appear before, or present a written report for consideration at, the ASME Subcommittee on Nuclear Accreditation (SC-NA) Meeting on January 11, 1982.

Did Brown & Root and/or Texas Utilities representatives appear at the January 11, 1982, meeting? Did Brown & Root and/or Texas Utilities representatives present written report (s) or information at the meeting? If so, supply the names of all representatives who attended the meeting and the names of all representatives who appeared to speak at the meeting (specify whether in attendance or as a speaker). If so, suppl such written report (s) ory for copying and information and inspection all all work papers, internal memoranda, and other documents related to such report (s) or information. Was a transcript made of the meeting?

(t) Why wasn ' t the December 17, 1981, l'tter referenced in (r) above included in the list of documents which Appli-cants stated they would provide for inspection and copying in their Response to CASE's Sixth Set of Requests for Production of Documents and Clarification of Responses to Certain Interrogatories (February 8, 1982)?

(u) If Applicants and/or Brown & Root have any correspondence or dealings with the ASME or receive any correspondence or communications (including verbal or telephone) from ASi4E prior to the "recommendatio'n concerning renewal of the certificates (which) will be consideged by the ASME Accreditation Subcommittee in early March," please so advise CASE immediately. Supply details in writing of all verbal or telephone communications and supply for copying and inspection all written documents.

Appli'cants' February 8, 1982 Response to CASE's Sixth Set of Requests for Production of Documents and Clarification of Responses to Certain Interrogatories, Response 1.d., page 2.

1. (continued) : .

(v) On the second page of the November 23, 1981 letter from ASME to R. J. Vurpillat, Brown & Root, on page 2, II.(C)(1) there is handwritten in the left-hand margin what appears to be "NV4 200." Explain the meaning of this term and its significance.

(w) On the third page of the November 23, 1981 letter referenced in (v) above, item (F), there is a discussion about component supports. Does this refer to pipe support and hanger problems which have been experienced at CPSES?

(x) Did the ASME Nuclear Survey conducted October 12-14, 1981 at CPSES have any bearing or contribute in any way to the announcement 10/26/81 by Applicants of the delay and/or cost increases for CPSES?

If the answer is yes, explain in detail what bearing this audit had and how it contributed to such announcement.

2. Does TUGCO now have complete control over Quality Assurance /

Quality Control at CPSES? If not, explain how such control is shared, with whom it is shared, and exactly how much con-trol TUGCO does have and how much control TUSI has. Explain how the various organizations which.have' control interface with one another. (If this information is contained in any of the manuals which are being made available for inspection and copying, specify where it is contained.)

3. If TUGC0 (and/or other Texas Utilities organizations) does have complete or primary control over Quality Assurance / Quality Control at CPSES, when did such organization (s) take over such control? ,

4. Who had such control prior to TUGC0 (and/or other Texas Utilities organizations) taking it over? Explain how the previous con-troller interfaced with the Texas Utilities organizations.

5. Why was the decision made to change control over to TUGC0 (and/or other Texas Utilities organizations) from the prior controller?

Describe briefly the decision-making process which led to such decision.

6. Supply for copying and inspection all documents, including internal memoranda, work papers, etc., involved in such decision.

. Include all documents, internal memoranda, work papers, etc.

between Texas Utilities organization (s) and Brown and Root.'

7. Does ASME deal with Brown and Root or with Texas Utilities organization (s) ? (It appears from the documents supplied to CASE in response to its Sixth Set, Response 1.d, that ASME was dealing direct with Brown and Root rather than Texas Utilities organization (s).) Please explain in detail.

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8. The following questions deal with TUGC0 Corporate Quality Procedures / Instructions Manual (Rev. 0, ' 11/6 /81) , CQI-CS-4. 3 Vendor QA Program Evaluation System.

(a) Have any audits been performed or scheduled as the result of two consecutive release inspections resulting in unacceptable Vendor Evaluations indicating an adverse trend?

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(b) If the answer to (a) above is yes, list the audits by number.

(c). When were the procedures set forth in this manual first completed in written form?

(d) If such procedures were completed in written form prior to 11/6/81', provide for inspection and copying all previous such procedures.

l 9. The following questions deal with the Brown and Root Quality Assurance Manual, CPSES.

(a) When were the procedures set forth in this manual firs t completed in written form?

(b) The manual shown CASE on 2/8/82 in response to our interrogatories and requests to produce shows dates of 9/81 or later. If such procedures were completed in' written form prior to 9/81, provide for inspection and copying all previous such procedures.

10. Have any audits been performed by or for any of the minor (other than Texas Utilities companies) owners of CPSES?

11. If so, provide for inspection and copying all such audits.

12. If not, why not? .

13. How many additional employees have been hired to work on the pipe hanger / pipe support problems referenced in Applicants' 10/26/81 news release about the cost increases and delays in construction completion of CPSES?

Of these, how many have worked in the past at the South Texas Nuclear Project?

Provide a breakdown by the number of engineers, inspectors, etc. (specify) which have been hired.

14. Provide the names and addresses of all employees reference 13 above who have previously worked at the South Texas Nuclear Project.

15. It has been reported in the newspapers that about 5'00 engineers are working in an area about the size of a basketball court to solve the pipe hanger / pipe support problem at CPSES.

How many engineers are actually working on the problem or have been working on the problem?

How many other (than engineers) employees are working on '

the problem'or have been working on the problem?

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16. What is the current status of the pipe hanger / pipe support problem at CPSES? Please give specific details.

Due to the time constraints under which we are now working, wr request that Applicants expedite their responses as much as i

possible, including using express mail.

Respectfully submitted, U- {Ah 44rs.) Juanita Ellis, President pCASE(CITIZENS-ASSOCIATIONFOR

SOUND ENERGY) 1426 S. Polk .

Dallas,. Texas 75224 214/941-1211, work l 214/946-9446 NOTE: Copies of the 11/23/81 letter from ASME.to R. J. Vurpillat, Brown & Root; the 11/25/81 letter from ASME to R. J.

Vurpillat, Brown & Root; and the 12/17/81 letter from ASME to R ; J . Vurpillat, Brown & Root, are attached to j CASE 's First Set of Interrogatories to NRC Staff, which is being filed on the same date as this pleading.

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RELATED CON'ESPONDENCE.. .

UNITED STATES OF AMERICA -

p 4 *.16 NUCLEAR REGULATORY COMMISSIO$ Id BEFORE THE ATOMIC SAFETY AND LICENSING BOARD, Y hCb '- C'f In the Matter of I I

APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 .

GENERATING COMPANY, ET AL. FOR AN I and 50-446 OPERATING LICENSE FOR COMANCHE I PEAK STEAM ELECTRIC STATION I .

UNITS #1 AND #2 (CPSES) I CERTIFICATE OF SERVICE By my signature below, I hereby certify that true'and correct copies of CASE's Seventh Set of Interrogatories to Appliants and Requests To Produce have been sent to the names listed below this 10th day of February 1982, by: Express Mail where indicated by

• and oy rirst Class nad otherwise.

• Administrative Judge Marshall E. Miller David J. Preister, Esq.

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

• Dr. Kenneth A. McCollom, Dean ,

G. Marshall Gilmore, Esq.

Division of Engineering, Architecture, 1060 W. Pipeline Road ,

and Technology Hurst, Texas 76053 .

Oklahoma State University Stillwater, Oklahoma 74074

• Dr. Richard Cole , Member ,

Atomic Safety and Llcensing Atomic Safety and Licensing Board Board Panel ,

U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C, 20555 washington, D. C. 20555

• Nicholas S. Reynolds , Esq. Atomic Safety and Licensing Debevoise & Liberman Appeal Panel 1200 - 17th St., N. W. U. S. Nuclear Pegulatory Commission Washington, D. C. 20036 Washington, D. C. 20555

• Marjorie Ulman Rothschild, Esq.

• Docketing and Service Section .

Office of Executive Iegal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555

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()ffs'.) Juanita Ellis, President CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)