ML20049J657

Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl

ML20049J657
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/08/1982
From:	Rozzell S BAKER & BOTTS, HOUSTON LIGHTING & POWER CO.
To:	DOHERTY, J.F.
References
NUDOCS 8203190092
Download: ML20049J657 (15)

Text

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. o CT.(EIJD UNITED STATES OF AMERICA 27 17q11 P559 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 5

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HOUSTON LIGHTING & POWER COMPANY Docket No. 5 g

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L C8':ete,s,, W r,m; r7ra~ j; APPLICANT'S ANSWERS TO DOHERTY'S O

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f FIRST SET OF INTERROGATORIES RE QUADREX c),

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In response to a document entitled "Interveno D *'

Doherty's First Set of Interrogatories to Applicant with Regard to' Tex-Pirg Contention 31 and Quadrex Matters",

Applicant answers as set forth below.

Mr. J. H. Goldberg, Vice President-Nuclear Engineering & Construction, will j

testify regarding the pertinence of Quadrex Corporation's review of engineering work at the South Texas Project to the Allen Creek Nuclear Generating Station. Mr. Louis J. Sas, Vice President-Engineering with Ebasco, will testify regard-l Ing Ebasco's engineering organization for the Allens Creek Nuclear Generating Station.

INTERROGATORY NG.J i

Did Mr. Goldberg, HL&P Vice President for Nuclear l

Engineering and Construction suggest the study which was i

eventually to be undertaken by the Quadrex Corp. of Brown &

Root's work at the STNP?

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ANSWER Yes.

JNTERROGATORY NO. 2 When was the study which was undertaken by Quadrex of Brown & Root's work at STNP first suggested?

ANSWER Mr. Goldberg first suggested such a study in November or December of 1980.

INTERROGATORY NO. 3 How was HL&P involved in preparation of the Quadrex Report?

ANSWER HL&P contracted with Quadrex Corporation (Quadrex).

for the study; assisted in the identification of the technical areas to be reviewed and in the formulation of questions; and coordinated and facilitated communications between Quadrex and Brown & Root, Inc. (B&R), including participa-tion in meetings where B&R provided information; members of HL&P's technical staff commented on the B&R answers to questions and the preliminary Quadrex assessments (ulti-mately Volumes 2 and 3 of the Report) and other aspects of the Report; and, at several meetings, HL&P was briefed by Quadrex and discussed the ongoing study.

H&P exercised no editorial control over the contents of the Report.

INTERROGATORY NO. 4 How was Brown'& Root involved in the preparation of the report mentioned in "3"

above, the Quadrex Report on STNP?

ANSWER B&R responded in writing and at meetings to requests for information from Quadrex.

INTERROUATORY NO. 5 If neither HL&P or Brown and Root were involved was that directed by Mr. Goldberg?

ANSWER Mr. Goldberg expressly directed that the evalua-tion was to be independent of HL&P or B&R control.

INTERROGATORY NO. 6 How long had Brown & Root been involved in STNP?

ANSWER The contract for design, engineering and construc-tion of STP between HL&P and B&R was entered into as of the 31st day of October, 1972.

HL&P decided to reallocate design, engineering and construction management responsi-bilities for STP on September 24, 1981.

B&R announced its decision to withdraw as constructor of STP on November 5, 1981.,

INTERROGATORY NO. 7 When did any of the following officers of the company first report they thought Brown & Root lacked the competence to successfully design the STNP?

a.

Manager of QA at STNP?

b.

Project Manager of STNP?

c.

Manager Nuclear Licensing?

d.

Manager Nuclear Services?

e.

Executive Vice-President?

(That is, Mr.

Oprea, see Mr. Oprea's Testimony p. 1, following Tr.18084) f.

Vice President for Nuclear Operations?

ANSWER HL&P is not aware of any such report prepared by any of the individuals holding the positions referenced in Interrogatory No. 7.

INTERROGATORY NO. 8 When was the first member of the NRC informed a consultant had been hired to conduct an independent third party review of design and engineering work at STNP?

Who informed him?

Who was informed?

ANSWER In April 1981, Mr. J. H. Goldberg discussed with Mr. Don Sells, NRC's Licensing Project Manager for STP, that a consultant was conducting a review of selected aspects of STP engineering and that its report would be forthcoming in a couple of weeks.

The subject also may have come up in earlier discussions, but HL&P is not certain this occurred.

INTERROGATOitY NO. 9 When first did HL&P meet with NRC Staff to discuss the Qt.drex Report's findings?

ANSWER Mr. Goldberg discussed the Quadrex Report findings with Mr. Sells late in the week of May 11, 1981.

INTERROGATORY NO. 10 Did HL&P instruct Brown & Root to review the report to determine if any of the findings should be reported pursuant to 10 CFR 50.55(e)?

If so, what did Brown & Root find?

ANSWER Yes.

B&R found that there was one potentially reportable deficiency.

INTERROGATORY NO. 11 How many reportable findings under 10 C.F.R. 50.55(e) were reported to the NRC in May, 1981?

What were the findings?

Who reported the findings? -_.._

ANSWER HL&P's review identified two additional matters which it considered potentially reportable.

On May 8, 1981, HL&P reported by telephone to the Region IV offices that it believed there existed three (3) potentially reportable problems under 10 C.F.R. 5 50.55(e). The matters reported involved (1) inadequate verification of certain computer programs used in STP engineering calculations; (2) inade-quate design of portions of safety-related heating, ventila-tion and air conditioning (HVAC) systems; and (3) inadequate verification of shielding analysis.

The third item was determined to be non-reportable within thirty (30) days and, thus, no written report on this item was made under 10 C.F.R. 9 50.55(e).

INTERROGATORY NO. 12 Did HL&P produce a list of consulting firms for Intervenors in the STNP " Character" hearings, on or about l

May 12, 1981?

Was Quadrex Corp. included among them?

i ANSWER After consultation and agreement with counsel for the intervenor who made the request, HL&P produced in the STP proceeding a list of the consultants to HL&P or the Management Committee on " project management, QA/QC or inspec-l l !

tion of completed work."

Since Quadrex had not been retained as a consultant on those subjects, it was not included in the list.

INTERROGATORY NO. 13 What was the cost of Quadrex report on STNP?

ANSWER The cost of the Quadrex Report for STPN as of mid-January 1982 was $251,934.20.

INTERROGATORY NO. 14 Was Mr. Goldberg questioned by Mr. Reis, Staff Counsel, at the NRC hearings on STNP on May 19, 1981, about

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where HL&P had found Brown & Root lacking in the area of design and engineering?

If so, did he mention the Quadrex report?

Did he mention any problem areas?

(Please make available relevant portions of the transcript.)

ANSWER There were several questions and answers between Mr. Reis and Mr. Goldberg during the May 19, 1981, hearing which involved HL&P's assessment of B&R's design and engineer-ing activities.

Transcript pages 2386-96 and 2403-9 covering these matters are enclosed as Attachment No. 1.

INTERROGATORY NO. 15 No interrogatory...-

INTERROGATORY NO. 16 Has HL&P found that Ebasco engineering on Allens Creek has been deficient in any way?

ANSWER HL&P is not aware of any project that was accom-plished without some deficiencies; however, HL&P has found Ebasco's engineering of ACNGS to meet or exceed applicable requirements.

This is confirmed by Quadrex's re' view of Ebasco's engineering work for ACNGS.

INTERROGATORY NO. 17 When was a copy of the Quadrex report on STNP actually given to the NRC (any Staff member) for perusal?

When does HL&P believe an NRC Staff member actually was given possession (that is actually took possession of a copy for personal control) of a copy of the Quadrex Report on STNP?

ANSWER Mr. Goldberg informed Mr. Sells during their telephone conservation in mid-April 1981 that the Quadrex Report would be available for NRC review at HL&P's offices when received by HL&P.

Mr. Goldberg had a copy of the Report with him during his meeting with Mr. Sells late in the week of May ll, 1981, and believes that Mr. Sells briefly looked at the Report during their meeting.

The NRC's Resident

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Reactor Inspector and other Region IV personnel had access to the Report at the STP site in August 1981.

Copies of the report were transmitted to the NRC in September 1981.

INTERROGATORY NO. 18 Did the Quadrex Report provide the single most significant reason for terminating Brown & Root Co., as architect-Engineer at the STNP?

What branch of HL&P manage-ment was responsible for reviewing the Quadrex Report on STNP?

ANSWER No.

HL&P's management for nuclear engineering has had primary responsibility among HL&P's management for reviewing the Quadrex Report.

INTERROGATORY NO. 19 Is the Bechtel Corporation reviewing the Quadrex report for HL&P at this time?

When is their report expected?

Will they investigate all of the issues at STNP raised by Quadrex corporation?

ANSWER l

Bechtel Corporation is reviewing all findings in l

the Quadrex Report and its analysis and conclusions are currently expected in August 1982.

A preliminary assessment is expected to be available in March.

l INTERROGATORY NO. 20 How will the Staff assigned to Allens Creek bene-fit from the Quadrex report review by Bechtel?

Do you plan to provide them.a copy of the report?

ANSWER HL&P does not know whether the NRC Staff assigned to Allens Creek will benefit from Bechtel's review of the Quadrex Report.

HL&P will provide copies of the Report if they have not been obtained already from the NRC Staff working on STP.

INTERROGATORY NO. 21 Referring to p. 3-3 of the Quadrex report, item (b)(2) refers ~ to calculations with errors being reviewed and verified as correct with a higher frequency than should be encountered?

What rate should be encountered?

How high was the Brown & Root rate?

Did HL&P discover this prior to Quadrex?

(Make available any memos, or the like, where any branch of HL&P's engineering notice this prior to Quadrex.)

ANSWER The Quadrex Report does not indicate the error frequency which the authors considered normal.

Similarly, no error rate was published for B&R's work reviewed by Quadrex.

HL&P has *.ot analyzed the frequency of such errors nor made a comparison to any industry norm.

. l l

INTERROGATORY NO. 22 On page 3-1 of the Quadrex report, how has HL&P interpreted the statement in Sec. 3.l(a), "There is no indi-cation that an effective systems integration and overview function exists within the B&R design process?"

How long had this been the situation at B&R with STNP?

What changes in HL&P management structure are being contemplated to change this?

What has been the result' in design quality at STNP due to this lack of systems integration?

ANSWER HL&P understood this statement to mean that Quadrex had not examined the operation of B&R's System Design Assur-ance group and had not observed other evidence sufficient to conclude that an effective systems integration function existed in the B&R design process.

The B&R System Design Assurance group was created in February 1980 and was respon-sible for system level design reviews.

Systems integration had been the responsibility of the individual system designers and design reviewers within B&R since inception of the project and the System Design Assurance group provided l

l another level of review to ensure effective systems intergra-l-

tion.

No changes in HL&P management are contemplated as a i

l result of this Quadrex finding.

The effect of this finding, I

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if any, on quality of design will be established as part of the complete engineering review being performed by Bechtel.

Respectfully submitted, OF COUNSEL:

J. Gregory Copelandu "

BAKER & BOTTS Scott E. Rozzell 3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, Jack R. Newman REIS & AXELRAD David B. Raskin 1025 Connecticut Ave., N.W.

1025 Connecticut Ave., N.W.

Washington, D.C.

20036 Washington, D.C.

20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY l /

STATE OF TEXAS S

COUNTY OF HARRIS S

BEFORE ME, the undersigned authority, on this day personally appeared J. H. Goldberg, Vice President - Nuclear Engineering & Construction for Houston Lighting & Power Company, who upon his oath stated that the foregoing answers to "Intervenor Doherty's First Set of Interrogatories Re Quadrex" were prepared under his supervision and direction, and that all statements contained therein are true and correct to the best of his knowledge and belief.

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SUBSCRIBED AND SWORN TO BEFORE ME by the said J.

H. Goldberg, on this WM day of March, 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S

S HOUSTON LIGHTING & POWER COMPANY S

Docket No. 50-466 S

(Allens Creek Nuclear Generating S

Station, Unit 1)

S CERTIFICATE OF SERVICE I hereby certify that copies of the Applicant's Answers to Doherty's First Set of Interrogatories Re Quadrex in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 81'- day of M arc 0 1982.

Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C.

20555 Hon. Leroy H. Grebe Dr.

E.

Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O.

Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 Mr. Gustave A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C.

20555 Washington, D. C.

20555 Susan Plettman Richard Black David Preister Staff Counsel Texas Attorney General's Office U.S. Nuclear Regulatory P. O.

Box 12548, Capitol Station Commission Austin, Texas 78711 Washington, D.-C.

20555 l

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Bryan L.

Baker Brenda McCorkle 1118 Montrose 6140 Darnell Houston, Texas 77019 Houston, Texas 77074 J. Morgan Bishop W. Matthew Perrenod 11418 Oak Spring 4070 Merrick Houston, Texas 77043 Houston, Texas 77025 Stephen A.

Doggett Wayne E.

Rentfro P. O. Box 592 P. O. Box 1335 Rosenberg, Texas 77471 Rosenberg, Texas 77471 John F. Doherty William Schuessler 4327 Alconbury 5810 Darnell Houston, Texas 77021 Houston, Texas 77074 Carro Hinderstein James M. Scott 723 Main, Suite 500 13935 Ivy Mount Houston, Texas 77002 Sugar Land, Tcxas 77478 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401

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