ML20041E070
| ML20041E070 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/01/1982 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8203100094 | |
| Download: ML20041E070 (11) | |
Text
.
-- - ' x =.=.= = u. ~ i :.
3,;y92 9'
UNITED STATES OF AXLP.ICA NU7 LEAR REGUIATORY C0tO{ISSIO.M cz p
~
BEFORE TEE ATO(IC SATETY AND LICENSIC BOARD In the Matter of
{
l Docket Nos. 50- M 5 APPLICATION OF TEtAS 17tILITIES l
and 50-446 3 6
GEHERATING CC3(PANY, ET AL. FOR AN l
'~
OPr. RATING LICEESE FOR CCa4ANCHE I
/
PEAK SITAM EIJ:CTRIC STATION l
/
WITS fl AND (2 (CPBES)
J l
't 1
CASE'S EIGHTH SET OF INTERROGATORIES 2
/s
~
TO APPLICANTS AND REQUESTS 'IO PRODUCE
'\\ ;, _// gl[h, N
\\
N
<s COCS NOW CASE (Citizens Association for Sound Energy), hereinafter referred
- c e.s. CASE, Intervenor herein, and files this, its Eighth Set of Interrogatories to Applicants and Requests to Produce.
Pctsuant to 10 CFR 2.7kOb and 2 7kl, please ansver the following interroga-torius in the matuner set forth herewith. 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 say t
portinent information known to their advisors or counsel. Each request to produce c.pplies to pertinent documents which are in the possession, custody or control of Applicants, tneir officers, directors or c=ployees as well as their advisors or cou pel.
Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory; do not ecxabine answers. Please g g t the person providing each answer or restonse.
~
(
Tear,e interro6atories and requests to produce shall be continuing in nature.
l Thus, ccy time Applicants obtain inforn.stien which rerders any previous response DSC)2 2
/
8203100094 820301 l
PDR ADOCK 05000445 O
PDR I
\\
incorrect or irdicates that a response was incorrect when made, Applicants abould supplemont their previous response to the appropriate interrogatory or regaest to proriuce. Applicants should a.lso surfac ant their respectes s,a necesst.ry with respect to identification of each person orpected to be called the bes. ring as an expert witness, the subject matter of his or her testimour, at c,nd the substance of that testimony. The term "doctaments" shall is lude any writicus, drawings, graphs, charts, photographs, reports, studies, ahd other data campilations frces which infonmation can be obtained. We request that at a date or dates to be agreed upon by mutual consent, Applicants ande available for inspection and copying all documents which CASE bas specifically requested or eubject to the requests set forth below. All interrogatories which do not request doctaments should be answered pursuant to 10 CFR 2 7h(b).
CONTENil0N 5:
The Applicants' failure to adhere to the quality assurance /
quality control provisions required by the cons t ruct ion permi ts for Comanche Peak, Units I and 2, and the requirements of Appendix B of 10 CFR Pa rt 50, and the construction practices employed, specifically in regard to concre te work, mortar blocks, s teel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor quall-fications and working conditions (as they may affect QA/QC, and training and organi za t ion of QA/QC pe rsonne l, 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 550.57(a) necessary for issuance of an operat ing license for Comanche Peak.I t
l t
i 0
I 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 Froof of August 29, 1980.
. 2 -
l
INTERROGATORIES AND REQUESTS TO PRODUCE 1.
The following questions and requests to produce concern the ASME Nuclear Survey at CPSES October 12-14, 1981 and Resurvey January 18-22, 1982, and related matters (refer to CASE's 1/L/82 Sixth Set of Interrogatories to Applicants and Requests to Produce, Question 1, and CASE's 2/10/82 Seventh Set of Interrogatories to Applicants and Requests to Produce, Questions 1 and 7) :
(a) As a point of clarification regarding our previous interrogatories and requests to produce (speci fically our 1/4/82 Si xth Se t, Ques tions 1(c) and 1(d), and our 2/10/82 Seventh Set, Questions 1(j),1(r), and 1(u)), we are referring to ASME documents to both Applicants and Brown and Root as well as documents which a re in the possession of Applicants and Brown and Root and any of their agents which have to do with or have bearing on these matters.
(b) With further reference to our 2/10/82 Seventh Set, Question 1(s), page 5:
Srpply the names and addresses of all ASME members and/or personnel who attended the January 11, 1982 meeting referenced in the 12/17/81 ASME letter.
Speci fy whether in attendance or as a speaker or participant.
Supply for inspect ion and copying all ASME documents addressed to or in the possession of Applicants and Brown and Root and any of thei r agents regarding the January 11, 1982 meeting.
(c) Supply for inspect ion and copying all documents addressed to or in the possession of Applicants and/or Brown and Root and any of their agents which are not specifically addressed by the preceding questions but which pertain to or have bearing on the ASME October 12-14, 1981 Survey, the ASME January 18-22, 1982 Resurvey, the January 11, 1982 ASME meeting, and any events leading up to or resul ting from said S u rvey, Re s u rvey an d mee t i ng.
(d) If Applicants and/or Brown and Root and any of their agents are aware of any other ASME or other documents which are not in thei r possession but which pertain to or have bearing on the ASME October 12-14, 1981 Survey, the ASME Janua ry 18-22, 1982 Resurvey, the January 11, 1982 7
ASME meeting, and any events leading up to or resul ting from said Survey, Resurvey and meeting, supply the name, date, and other identi-fying information of such documents and information as to where CASE can obtain said documents.
In short, we want all the information and documents you have or know of regarding this particular matter.
l l.
2.
Supply for copying and inspection the NA and NPT,Certi ficates of Authori-zation (N-2222-2 and N-2223-2) for CPSES.
Supply the certi ficates which evi r ed J.mnary 8.1987. and renewal certi ficates as soon as they are approved by ASML.
3 It is our understanding that a site-specific survey was made prior to ASME's issuing the NA and NPT Certi ficates of Authorization and stamps.
i Regarding this, please supply the folloving information:
i (a) When was this survey made?
i (b) Supply the names and addresses of all personnel and agents of Applicants, Brown and Root, the NRC Staf f, ASME, and all others who participated in or were present during said survey.
Specify organization and title of l
each and indicate extent of participation of each.
(c) Supply for inspection and copying such survey.
i 4.
In the list of audit reports and in the audit reports themselves which Applicants recently supplied to CASE for inspection and copying, the sequentially numbered TCP series of audits skipped from TCP-15 to TCP-17 Please provide for inspection and copying audit report TCP-16.
l 5
5 Wi th further reference to the audi ts di scussed in 4 above, the last audit re port in the TCP series was TCP-29, which referred to deficiencies under date of December 17, 1981, and responses dated February 1 and 2, 1982.
Please provide for inspection and copying all audi t reports since Decembe r 17, 1981.
If responses have not yet been provided, supply the portion of the. reports which detail the deficiencies now and the responses
=
as they become available.
(As with all discovery requests, these are to be continuing in nature and should be supplemented by Applicants in the future as new reports are prepared.)
E 4
I
- 6. We were supplied with audit reports in the TMJ series:
TMJ-1, TMJ-2, and TMJ-3 The most recent date on any of these is April 15, 1977 Does this mean that Applicants (and/or Brown and Root) no longer do business with I
this company and haven't since April 15, 19777' Or haven' t Applicants performed any audits on this company s ince that time? Please explain.
l 7
We we're supplied with audit reports in the TGF series:
TGF-1, TGF-2, and i
TGF-3 The most recent date on any of these is deficiency report of September 15,.1980 and response dated February 18, 1981.
Please explain (in a similar manner to that indicated in 6 above).
8.
Do you anticipate that further audits will be done in the TMJ and/or TGF series?
l 9
We were supplied with one audit re po rt identi fied as TBS-1, which was.
i the only such report wi th the TBS prefix.
The dates on it were March l
26, 1980 for the deficiency report and June 4,1980 for the response.
Please explain (in a similar manner to that indicated in 6 above).
j ?
I a
e f
10.
Please explain briefly the purpose of each of the audit series (TCP, TM). TGF, and TBS), how it is determined when each type,of audit is to be made (whether Jone on.i s cepil.u - b.r.i-at crrtain
,r.h e rlo ! M t irvr. r r s
as problems arise, c'tc.), and the nane and title of the persor, who makes such determination for each audit series.
11.
How many audi ts have been performed by Hart ford Steam Boiler regarding C.omanche Peak?
12.
Please provide for inspection and copying all audits referenced in 11 above.
13 Please supply or provide for inspection and copying a list of all Brown and Root Quality Assurance / Quality Control personnel, including Quality Control i n spe c to rs.
Provide names, date hired, date terminated, reason for terminat ion, area of responsibility, what level (level 1, 2 or 3).
14.
Please refer to CASE's 12/1/80 Second Set of Interrogatories to Applicants and Requests to Produce, Question 15, pages 6 through 21, wh?ch includes a copy of inspection and Enforcement (l&E) Report 79-11.
(a) In Applicants' December 22, 1980 Supplementary Response, Applicants indicated that the report "Fi nal Report on Concrete Evaluation in Dome Roof Section of Comanche Peak Uni t 1, Glen Rose, Texas," Muenoa and Associates, would be made available for inspection and copying.
Please provide it for inspection and copying now.
(We will definitely want a copy of the report, and if it will be helpful to you, please go ahead and make a copy of it for us to pick up the next time we come by for copies, at the agreed upon cost of 15c per page as in the pas t.)
(b) Provide the names, addresses, title and brief job description both now and on January 18, 1979, of a ll B rown and Root and Applicants' personnel who were present at any time during or partici pated in the concrete placement referenced in Allegation 1 of l&E Report 79-11.
(c) Provide for inspection and copying all documents pertaining to the concrete placenent referenced in (b) above, including but not limited to:
DDR or NCR, CAR, repair records, punch lists, and concrete pour package.
Provide the original records rather than copies.
15 P. lease refer to CASE's 12/1/80 Second Set of Interrogatories to Applicants and Reques ts to Produce, Ques ti on 18, pages 22 and 23, which refers to ISE Report 80-08 and "honeycombing" in certain interior walls of the Unit Two containment building.
(a) Provide the names, addresses, title and brief job description both now and at the time of the above-referenced concrete placement of all Brown and Root and Applicants' personnel who were present or participated in the concrete placement re fe renced above..
4 i
4 15.
(b) Provide for Inspection and copying all documents pertaining to the concrete placement and "honeycombing" problem and solution re fe renced in 1&E Report 80-08, including but not limited to:
DDR or NCR, CAR, repair records, p nch lists, and concrete pour packages.
Provide the original records rather than copies.
(c) Provide the following in forma tion about the personnel of Applicants',
Brown and Root, or any other agents of Applicants who can interpret the oscillographic data obtained from the microseismic (sonic) in-ves tigative technique developed by Mr. Meunow and used by Mr. Meunow in evaluating the "honeycombing" problem referenced in l&E Report 80-082:
(1)
The names and addresses of each and every such person.
(2) ' The ti tle, credentials, background, experience, training, etc.
of each such person.
Include specifically the training each such person has received to enable him/her to interpret such data, who provi ded such training, the extent of the training, and the creden-tials in this specific regard of the person (s) providing such training.
16.
Please supplement your answers to the following questions, originally asked in CASE's 12/1/80 Second Set of Interrogatories to Applicants and Requests to Produce:
"21.
Do you intend to call any witness in the upcoming hearing with regard to Contention 57 "22.
If the ' answer to Question 21 above is yes, supply the following in-formation rega rding each such wi tness:
"a.
'Name, address, and telephone number of the witness.
"b.
Company af filiation and t itle.
"c.
A summary of the witness's professional and educational background.
"d.
Any other information bearing on the witness's specific quali-fications to testi fy wi th respect to Contention 5.
"e.
T,he nature of the wi tness's testimony and a brief summary of such tes timony.
List or id' ntify any and all documents which that witness intends "f.
e to rely on in giving thei r testimony.
j 3
l in the third paragraph of item 5, page 7 of l&E Report 80-01 (under cover letter dated 2/15/80), the Resident Reactor inspector (RRI) stated:
"...the micro-seismic (sonic) investigative technique is unique to the consultant, Mr. Meunow, who developed it and is the only known person able to interpret the oscillo-graphic data obtained."
3 5.
ga i
.i 1
- 16. (continued) l "22. (continued)
"g.
State whether or not such witness has conducted any research or made any studies on which such witness will rely.
"h.
If the answer to g. above is yes, state briefly the scope and nature of such research or study.
"I.
Provide copies of the witness 's tes timony.
"J.
Provide for inspection and copying any documents on which the witness relied in such testimony."
17 Please supplement your answer to CASE's 7/7/80 First Set of Interrogatories to Applicants, page 4, Questions 20, 21, 24, and 25:
"20. Are there any audio tapes or video tapes of any of the information referred to in item 197
"(19 Supply copies of all quality control manuals, folders, pamphlets, and any other printed Information regarding quality control, including procedures for quality control, not only current but the originals and all revisions.)
"21. If the answer to item 20 is yes, where are such tapes kept so that we can review them?
"24. Are there any audio tapes or video tapes of any of the information referred to in items 22 and 237
"(22. Supply copies of all quality control specifications manuals, folders, pamphlets, and any other printed information regarding quality control specifications, not only current but the originals and all revisions.)
"(23. Supply copies of all manuals, folders, pamphlets, and any other printed information regarding quality assurance, quality assurance speci fications, and quali ty assurance procedures, not only current but the originals and all revisions.
If this information has been supplied in response to item 19, so state.)
'.'25. If the answer to item 24 is yes, where are such tapes kept so that we can review them?"
- 18. We understand from your previous answers to interrogatories that TUGC0 maintains ultimate control over Quality Assurance / Quality Control at Coman'che Peak and has since October 17, 1.974, concurrent with the issuance of the Limited Work Authorization.
(
However, the FSAR indicates that Brown & Root, Inc. (B&R) as constructor and construction manager, is implenenting the overall Quality Assurance sys tem.
In this regard, please supply the following information:
i
=
7-k
- 18. (continued) :
(a) Has TLGC0 and/or TUSl taken over more direct control of QA/QC from B rown r;d Root than was initially the case a: tne. beginning of the CPSES praject?
(b) If the ansser to (a) above is yes, explain briefly the history of such change (s), the reason for such change (s), and any other pertinent details regarding such change (s).
(c) Provide for inspection and copying any and all documents, including internal memos, handwritten notes, and all otner documents (as defined on page 2 of this pleading) between Applicants and Brown and Root regard-Ing Brown and Root 's performance at CPSES.
19 Please refer to 16E Report 80-25 (under cover letter of November 12, 1980),
in regard to the regional evaluation by NRC of Apolicants' performance as an NRC licensee.
(a) On page 6, i t is stated:
" Licensee Construction and Engineering Management - The NRC personnel stated that i t appears there is a continuing tendency to engineer away construction problems rather than enforce compliance to drawings and specifications.
The licensee stated that he is taking several management a:tions wi th the engineer-ing and construction personnel to alleviate tn i s s i tuation. " (Emphasis added.)
Specifically what management actions with the engineering and con-struction personnel have Applicants' taken to alleviate this situation?
(b) Provide for inspection and copying all written instructions and docu-ments pertaining to your answer to (a) above.
(c) On page 6, it is stated:
" Brown and Root Construction Supervision and Labor Force - The NRC participants indicated that their impression of this area indicated that there is a need to make this group more aware of nuclear power plant construction 1 requirements.
That there is a considerable difference to those of a conventional fossil plant.
,The licensee responded that he has issued instructi6ns to Brown and Root to reduce the labor crew size reporting to foremen and the number of crews reporting to genera l foremen.
The licensee s tated that it j
is expected that this will provide increased control over the quality affecting actions of the labor force."
(Emphasis added.)
Speci fically what instructions have been issued by Applicants to Brown and Root in this regard?
(d) Provide for inspection and copying all written instructions and documents pertaining to your answer to (c) above.
(e) What has been the assessment of Applicants of the effectiveness of the actions referenced in (c) above? Speci fi cally, have the actions taken by Applicants in this regard and Brown and Root's corresponding actions in actuality 'provided increased control over the quality affecting actions of the labor force?
-g-
- w
- 19. (cont inued) :
'l (f) Provide for inspection and copying all docurents assessing the ef fectiveness of the act ions re fe renced in (c) above, as well as all documents us'ed to evaluate such ef fectiveness'.
(g) On page 6, i t is s tated:
"3. Summary of Licensee Pe r fo rman ce.
The Region IV Director, at the conclusion of the necting, emphasizec that the licensee has the principal and legal responsibility for all matters regarding the construction and operations of a nuc' lear power plant as specified in the law and in the Regulations.
Corporate h
management is essential in all phases of the project to assure appro-t priate execution of the licensee 's res ponsibi li ties.
The licensee f
responded that he is aware of his respor.sibilities and that in response to these responsibilities, he continuously increased his involvement
[
in the project during the past three years until he is now essentially in complete cont rol of the project except f or th e i mmed i a te line supe rvis ion of the labor force. The license indicated that as new or addi tional involvement becomes necessary, he will respond accordingly."
(Emphases added.)
Please explain in detail how Applicants have " continuously increased (his) involvement in the project during the past three years."
(h) Explain in detail why Applicants have fel t it necessary to increase thei r involvement in the project during the past three years.
(i) Provide for inspection and copying all documents, including internal memoranda, handwri tten notes, and all other documents 6s defined on page 2 of this pleading) pertaining to your answers to (g) and (h) above.
(if this information has already been provided in whole or in part in answer to Question 18 of this pleading, please so indicate.)
(j) Since this NRC evaluation on October 30, 1980, has new or additional involvement become necessary?
(k) I f the answe r to (j) above is yes, please explain in detail the nature of such involvement, the events. leading up to and necessitating such involvement, and why Applicants felt it necessary to increa$e their involvement.
(1) Provide for ins pection and copying all documents, including internal memoranda, handwritten notes, and all other documents (as defined on I
page 2 of this pleading) pertaining to your answers to (k) above.
[
I 20.
Do Applicants have a study or assessment underway at. this time about the i
work at CPSES, or is such a study or assessment (by whatever name) anti-F cipa ted in the immediate future?
21.
If the answer to 20 above is yes, please give specifics regarding such study or assessment, the terminology by which Applicants refer to such study or assessment, the scope of such study or assessment, and when Applicants anticipate that i t will be conpleted.
_g_
~
..*^
- \\
22.
If the answer to 20 above is yes, please provide such study or assessment for inspection and copying as soon as it is available.
0 23.
Is there an audi t, study or assessment (by whatever name) underway at this U
time about the work at CPSES by or for any of the minor (other than Texas Utilities companies) owners of CPSES, or is such an audit, study or assess-ment anticipated in the immediate future?
24.
If the answer to 23 above is yes, please give specifics regarding such audi t, study, or assessment, the terminology by which such audit, study,
.or assessment will be referred, and when it is anticipated that it will t
be completed.
l l
25.
If the answer to 23 above is yes, please provide such audit, study,or I
f assessment for inspection and copying as soon as it is available.
I 26.
Please be sure to provide the name of the specific person providing each answer or response to these questions, and please go back and provide the
~ ;
names of the specific people providing each answer or response to the questions i
in CASE's 2/10/82 Seventh Set of Interrogatories and Reques ts to Produce (as I
requested on page 1 of that pleading).
27 On all of the documents provided for inspection and copying, and on all documents copied for CASE, please identi fy each document by the specifi c interrogatory or request number it is being provided in answer to.
Due to the time constraints under which we are now working,- we request that Applicants expedite their responses as much as possible, including using express mail.
Respectfully submi t ted,
)
/42'm /
A./
')
s f{Mrs.) Juanita Ellis, President 4' CASE (Citizens Association for Sound Energy) 1426 S. Polk Da l l as, Texas 75224 214/941-1211, work 214/946-9446, home i
e b '
e
-v 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARif f
~~
o In the Matter of I
o y
APPLICATION OF TEXAS UTILITIES I
Docket Nos. 50-44'5 GENERATING COMPANY, ET AL. FOR AN I
and 50-446 CPERATING LICENSE FOR COMANCHE I
PEAK STEAM ELECTRIC STATION I
UNITS #1 AND 82 (CPSES)
I CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies Of CASE's 1/1/82 EIGHTH SET OF INTERROCATORIES TO APPLICANTS AND RF00ESTS TO PRODt!CE have been sent to the names listed below this 1st day of March 1982 by:
Express Mail where indicated by
- and by Fi rs t ' Class Mail otherwise.
Administrative Judge Marshall E. Miller David J. Preister, Esq.
U.
S. Nuclear Regulatory Commission Assistant Attorney General Atomic Safety 'and Lice.nsing Board Panel Environmental Protection Division Wzshington, D.'C.
20555 P.
O.
Box 12548, Capitol Station Austin, TX 78711
- Dr. rwnneth A. McCollom, Dean G. Marshall Gilmore, Esq.
Division of Engineering, Architecture, 1060 W.
Pipeline Road and Technology
!!urs t, Texas 76053 Oklahoma State University Stillwater, Oklahoma 74074
- Dr. Richard Cole, Member Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.
S. Nuclear Regulatory Commissian 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 Regulatory Commission Washington, D. C.
20036 Washington, D. C.
20555
- Marjorie Ulman Rothschild, Esq.
Docketing and Service Section C'f fice of Executive Imgal Director Office of the Secretary O. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission W;shington, D. C.
20555 Washington, D. C.
20555 0 % -.5,
bd b
M'rs. ) Juanita Ellis, President
[ CASE (CITIZENS ASSOCIATICN FOR SOUND ENERGY) 4.