ML20049H843
| ML20049H843 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/26/1982 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8203040277 | |
| Download: ML20049H843 (9) | |
Text
y v
T t
9 00 p 14 p
.D February 26, 1982 yg A.
g UNITED STATES OF AMERICA NUCLEAR DIGULATORY COMMISSICN BEFORE THE ATOMIC SAFETY AND LICENSING BOAM I
$82 >
(fliceof theSn l?
/
l!rYt?$'& S*t.
In the Matter of
)
1
,I 9*
-W
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 and COMPANY, et al.
)
50-446
)
(Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating Li e
g ll RECE!VED N
APPLICANTS' THIRD SET OF INTERROGATO IES N3 1902>
TO CASE AND REQUESTS TO PRODUCE l M> n ww
, ua wa.: n
- A C
ji N
g Pursuant to O C.F.R. SS 2. 740b and 2. 741, Texas -Uti-l'hes e
Generating Company, et al.
(" Applicants") hereby serve Applicants ' Third Set of Interrogatorias and Requests to Produce upon Citizens Association for Sound Energy (" CASE").
These interrogatories involve CASE's Contention 5, which contains a general claim that Applicants have failed to adhere to the Quality Assurance / Quality Control requirements for Comanche Peak.
In view of the schedule prescribed by the Board recently, it is now imperative that CASE provide timely and complete responses to each interrogatory so that the issues in controversy may be scoped and clarified.
That result will allow Applicants to prepare meaningful and specific testimony in response to clear and specific issues within the scope of h* g the Contention.
//
8203040277 820226 PDR ADOCK 05000445 4
Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to CASE, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel.
Each request to produce applies to pertinent i
documents which are in the possession, custody or control of CASE, its officers, directors or members as well as its employees, advisors or counsel.
In answering each interroga-tory and in responding to each request, please recite the interrogatory or request preceeding each answer or response.
Also, please identify the person providing each answer or response.
These interrogatories and requests shall be continuing in nature.
Thus, any tine CASE obtains information which a
renders any previous response incorrect or indicates that a response was incorrect when made, CASE should supplement its previous response to the appropriate interrogatory or request to produce.
CASE should also supplement its responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the I
subject matter of his or her testimony, and the substance of that testimony.
Applicants are particularly interested in the l
names and areas of expertise of CASE's witnesses, if any.
t I
s
. Early identification of such witnesses is necessary if Applicants are to be afforded adequate time to depose them.
The term " documents" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained.
We request that at a date or dates to be agreed upon, CASE make available for inspection and copying, all documents subject to the requests set forth below.
APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE Contention 5.
The Applicants' failure to' adhere to the Quality Assurance / Quality Control provisions required by the construc-tion permits for Comanche Peak, Units 1 and 2, and the require-ments of Appendix 3 of 10 CFR Part 50, and the construction practices employed, specifically in regard to concrete work, mortar blocks, steel, facture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifi-cations and working conditions (as they may affect QA/QC), an d 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 S 50.57 (a) necessary for issuance of an operating license for Comanche Peak.
1.
Do you intend to call any witnesses in the upcoming hearing with respect to Contention 5?
If so, please identify the witness including a summary of his or her professional and educational background.
.Also, set forth any other information bearing on that person's qualifications to testify with respect to Contention 5.
l 2.
If you plan to call any witness during the upcoming hearing with respect to Contention 5, please specify the nature and scope of that person's testimony.
Please list or identify any documents which the witness intends to rely on in giving their testimony.
- Also, please state whether that witness has conducted any research or made any studies which such witness intends to rely upon.
Please provide copies of such testimony.
Also, please provide for inspection and copying any documents relied on in such testimony.
3.
What are the specific provisions set forth in the construction permits for Comanche Peak to which CASE contends Applicants have failed to adhere?
4.
What are the specific requirements of Appendix B of 10 CFR Part 50 to which CASE contends Applicants have failed to adhere?
5.
For each of the following construction practices, specify the particular concern of CASE with respect to any inade-quacies alleged regarding such practice.
Specify time of occurrence, location and specific problem alleged for each practice.
a.
concrete work b.
mortar blocks c.
steel d.
fracture toughness testing e.
expansion joints f.
placement of the reactor vessel for Unit 2 g.
welding h.
inspection and testing i.
materials used j.
craft labor qualifications k.
working conditions as they may affect QA/QC l
t i
l
~
. 6.
For each of the following construction practices identify the specific basis (es) on which CASE intends to rely in support of its position on Contention 5.
Answer separately for each such practice with specific references to documents, testimony, interviews, articles, or other material on which CASE intends to rely.
a.
concrete work b.
mortar blocks c.
steel d.
fracture toughness testing e.
cxpansion joints f.
placement of the reactor vessel for Unit 2 g.
welding h.
inspection and testing i.
materials used j.
craft labor qualifications k.
working conditions as they may affect QA/QC 7.
Does CASE intend to challenge the adequacy of Applicants '
" training and organization of QA/QC personnel"?
8.
If the response to Interrogatory 7 is in the affirmative, please specify those aspects of Applicants' training and organization of QA/QC personnel which you intend to challenge and provide the basis for your position.
9.
If CASE has not identified above any specific concerns with respect to any of the construction practices listed in Interrogatories 5 and 6, please answer the following:
a.
Does CASE intend to raise at the hearing any issue concerning any of those construction practices for which it does not have specific concerns?
b.
If CASE does not plan to pursue at the hearings any of the. construction practices identified in Conten-tion 5, please identify those construction practices.
4
, 10.
CASE previously identified several I&E Reports as providing the bases for CASE's position on Contention 5.
See CASE Answers to Applicants First Set of Interrogatories, December 1, 1980.
Does CASE intend to raise any issues other than those dealt with in I&E Reports?
If so, please identify those specific issues and specify the bases for CASE's concern.
11.
Please list all I&E Reports, other than those identified in CASE's December 1, 1980 answers, on which CASE intends to rely for its position on Contention 5.
12.
Does CASE intend to include within its case on Contention 5 subjects raised in I&E Reports cited by CASE which have been resolved to the satisfaction of the NRC Staff?
13.
If the answer to Interrogatory 12 is in the negative, please identify those issues and I&E Reports which CASE does not intend to pursue.
14.
Are there any other I&E Reports previously cited by CASE which CASE no longer intends to rely upon on its case on Contention 5?
If so, please identify each such I&E Report.
15.
Does CASE disagree with the adequacy of any of the procedures identified or set forth in the Quality Assurance / Quality Control Manuals which have been provided to CASE in discovery?
16.
If the answer to Interrogatory 15 is in the affirmative, please identify the specific procedures with which CASE has a concern and describe the nature of and basis for each concern.
17.
Does CASE believe that any of the audits which a
have been provided pursuant to discovery contain any matters which CASE intends to raise in its case on Contention 5?
.~
. 18.
If the response to Interrogatory 17 is in the affirmative, please specify each matter raised in audit reports which CASE intends to rely upon in its case on Contention 5 and specify the particular concern which CASE has with respect to each matter.
19.
Does CISE intend to rely on any other information (including documents) which has been supplied through j
discovery in presenting its case on Contention 5?
20.
If the response to Interrogatory 19 is in the affirmative, specify the information (including documents) on which CASE intends to rely and set forth the particular concern (s) for which CASE intends to use such information or documents to support its case on Contention 5.
n Respectfull submitted,
\\
l ly Nichola S.
Reynolds J
0b William A.
Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202)857-9817 Counsel for Applicants February 26, 1982 C
...s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 and COMPANY, et al.
)
50-446
)
(Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating Licenses)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants '
Third Set of Interrogatories To CASE and Requests to Produce,"
in the above-captioned matter were served upon the following persons by overnight delivery (*) or deposit in the United States mail, first class postage prepaid this 26th day of February, 1982:
Marshall E.
Miller, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Muclear Regulatory U.S. Nuclear Regulatory Commission Commission
~
Washington, D.C.
20555 Washington, D.C.
20555 Marjorie Ulman Rothschild, Es q.,
Dr. Kenneth A. McCollom Office of the Executive Dean, Division of Engineering, Legal Director, Architecture and Technology U.S.
Nuclear Regulatory Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D..C.
20555 Dr. Richard Cole, Member David J.
Preister,?Esq.
Atomic Safety and Licensing Assistant Attorney General
~
Board Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548
~
Washington, D.C.
20555 Capitol Station Austin, Texas 78711 o
Chairman, Atomic Safety and Licensing Board J. Marshall Gilmore, Esq.
U.S. Nuclear Regulatory 1060 W.
Pipeline Road Commission Hurst, Texas 76053
/
l Washington, D.C.
20555
)
.. - r6
-. 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 President, CASE 1426 South Polk Street Dallas, Texas 75224
- K=..,"
p.
/
ki O.drcJ.-
William A.
Horin~
cc:
Homer C.
Schmidt Spencer C. Relyea, Esq.
~.
m c
aa
.~
/.
C "l,'*f k
w: