ML20041E107

First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl

ML20041E107
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/05/1982
From:	Doggett S DOGGETT, S.A., INTERVENORS CONN, CUMMINGS, DOGGETT, GRIFFITH, JOHNSTON
To:	HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8203100153
Download: ML20041E107 (6)

Text

r QNfD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 g.g _g g BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD p ' AQj In the Matter of 5.

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ll0USIW LIGITING & POWER 5

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t Docket No. 50-466' g[Qjllw%ig 2S COMPANY

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(Allens Creek Nuclear 5

'M; Gaierating Station, Unit S

No. 1)

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y, en FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DDOUMERIS REGARDING TEXP!RO COMTENTION 31 FROM IRiERVENOR$ DOGGETT, CONN, CUMINGS LEMMER, AND JOHNSTON TO:

HOUSTON LIGHTING AND POWER Preface Pursuant to Sections 2,740b and 2.741 of the Commission's Rules of Practice, Intervenors DOGGETT, CONN, CUMINGS, GRIFFITH, LEMMER, and JOHNSTON propound the following Interrogatories and Requests for Production of Documents to HOUSTON LIGHTING AND POWER COMPANY (hereinafter "HLP").

Each interrogatory should be answered separately i

and fully in writing under oath or affirmation by the person or persons making them no later than fourteen (14) days after service of these Interrogatories and Requests for Production, and each document requested should be produced no later than thirty (30) days after service of these Interrogatories and p3 s

Requests for Production.

I; 8203100153 020305 l

PDR ADOCK 05000466 G

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Interrogatories 1.

(a)

Identify each witness, other than an expert witness, who HL & P may call in this proceeding. to present additional testimony on TexPirg Contention 31, and provide a summary of the testimony which each such witness is expected to offer.

(b)

Identify all' documents upon which each such witness may rely in any way, and provide copies of any such documents.

2.

(a)

Identify each expert witness who HL & P expects to call in this proceeding to present additional testimony on TexPirg Contention 31.

(b)

State the qualifications and credentials of each such expert witness.

(c)

Provide a summary of the testimony which each such witness is expected to offer.

(d)

State the factural basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

(e)

Identify all documents prepared by, for, or under the supervision of each such expert witness, or reviewed or relied upon by u ch expert in formulating the expert's

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l opinions and conclusions, including work appers, preliminary outlines and memoranda, and communications between such expert and Intervenor.

Provide copies of any such documents.

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3.

Describe in detail what information or documents lead Mr. Goldberg, H L & P Vice President for Nuclear Engineering and Construction, to commission the Quadrex Review.

For such information and documents identity:

(a) its source or author (b) its date (c) whe*aer it is a memoranda, report, letter, or other written document (d) the dates or dates when Mr. Goldberg reviewed it.

4.

Please produce for inspection any documents, referenced in question 3 5.

Please list by name and job title any and all persons whom Mr. Goldberg relied upon for input or consulted with on deciding to commission Quadrex and give a brief description.

of the nature of the information supplied to Mr. Goldberg by each such person.

6.

Please produce any internal memoranda or documentation generated as a result of Mr. Goldberg's review and the decision making process which led to Quadrex.

7.

Who was present on or about May 7,1981 at a joint meeting, if any, between HL & P and Brown & Root at which j

Mr. Goldberg instructed Brown & Root to conduct a review of Quadrex to determine if any of the findings should be reported to the NRC?

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Produce any written memoranda which reflect the substance of this meeting and the persons attending.

9.

When did Brown & Root make the report to HL & P of its review of Quadrex referred to in question 8? Who made the report?

If in writing, please produce.

10.

Who at HL & P was responsible for further analysis of Qxxkex af ter May 7,1981.

Produce any memoranda or written policy documents concerning this further review.

11.

Produce any memoranda of the conversation between seits Mr. Don Sills, and Mr. Goldberg concerning Quadrex which occurred the week of May 11, 1981.

12.

Produce a copy of the December 3, 1981 letter to the Licensing Board sent by HL & P attorneys in the STNP licensing proceedings.

Respectfully submitted,

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STEPHEN A.DOGGETT, Pro Se and As Attorney for Intervenors, Conn, Cumings, Griffith, Lemmer, and Johnston 1000 Austin - Suite C Richmond, Texas 77469 Telephone:

(713) 342-3242 State Bar Co. 05945700 l

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LNITt'.D STATES OF ATJl. 'A NUCEAR REGUIATORY CGHISSION beluu:; THE AlmIC SAFEIY AND LICENSING DOARD In The Matter of S

S HOUSTW LIGirING AND PGER S

CWPNW Docket No. 50-466 S

(Allens Creek Nuclear S

Genernting Station, Unit 5

No. 1)

S CERTIFICATE OF SER/ ICE I hereby certify that copies of the foregoing First Set of In-terrogatories and Requests for Production of Docments Regarding Texpirg Contention 31 frm Intervenors Doggett, Com, Ceings, Lener, and Johnston.to Houston Lighting and Power Cmpany.in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this Sci day of 17}Alc/v 1982.

Susan Plettman Sheldon J. Wolfe, Esq., Chairman

' David Preister Atomic Safety and Licensing Board Texas Attorney General's Panel

Office U.S. Nuclear Regulatory Comission P. O. Box 12548 Washington, D.C.

20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. 01arles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atmic Safety and Licensing Board Panel Hon.Leroy H. Grebe U. S. Nuclear Regulatory Cm mission County Iudge, Austin County Washington, D.C.

20555 P. O. Box 99 Bellville, Texas 77418 Mr. Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Cmmission U.S. Nuclear Regulatory Cmmission U.S. Nuclear Regulatory Cm mission Washington, D.C.

20555 Washington, D.C.

20555 Atcnic Safety and Licensing J. Gregory Copeland Board Panel Scott E. Rozzell U.S. Nuclear Regulatory Ca mission 3000 One Shell Plaza Washington, D.C.

20'i55 Housten, Texas 77002

P Richard Black Esq.

D. Marrack Staff Counsel 420 Mulberry Lane U.S. Nuclear Regulatory Ca mission Bellaire, Texas 77401 Washington, D.C.

20555 Mr. J. Morgan Bishop Mr. Bryan L. Baker 11418 Oak Spring 1118 Montrose Houston, Texas 77043 Houston, Texas 77019 Mr. John F. Doherty Willian Schuessler 4327 Alconbury 5810 Darnell.

Houston, Texas 77021 Houston, Texas 77074 Ms. Brenda McCorkle 6140 Darnell Mr. W. Matthew Perrenod Houston, Texas 77074 4070 Merrick Houston, Texas 77025 Mr. Wayne E. Pentfro P. O. Box 1335 Mr. Janes M. Scott Roseberg, Texas 77471 13935 Ivy Mount Sugar Land, Texas 77478 Mr. F.H. Potthoff 7200 Shady Villa, No. 110 Carro Hinderstein Houston, Texas 77080 723 Main, Suite-500 Houston, Texas 77002

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