ML20049K080
| ML20049K080 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/25/1982 |
| From: | Copeland J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | DOGGETT, S.A., INTERVENORS CONN, CUMMINGS, DOGGETT, GRIFFITH, JOHNSTON |
| References | |
| NUDOCS 8203290384 | |
| Download: ML20049K080 (8) | |
Text
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biarch 23, 1982 UNITED STATES OF AMERICAn9 g g g go
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NUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY & LICENSING' BOARD In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 5
(Allens Creek Nuclear Generating S
Station, Unit 1 S
HOUSTON LIGHTING & POWER COMPANY'S ANSWERS AND OBJECTIONS TO INTERROGATORIES OF DOGGETT, ET AL.
INTERROGATORY NO. 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("fj_b^t.
</(b documents.
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,;.g ANSWER i
(a)
None.
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(b)
- None, h
IT[b \\s cu INTERROGATORY NO. 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 factual basis for each conclusion or ((#
opinion each such witness expects to present or draw in such S
expert's testimony.
//
B203290384 820325 PDR ADOCK 05000466 0
(e)
Identify all documents prepared by, for, or under the supervision of each such expert witness, or re-viewed or relied upon by such expert in formulating the expert's opinions and conclusions, including work papers, preliminary outlines and memoranda, and communications between such expert and Intervenor.
Provide copies of any such documents.
ANSWER (a)
J. H. Goldberg and Louis Sas.
(b)
Mr. Goldberg's qualifications have already been provided in connection with his prior testimony in this proceeding.
A copy of Mr. Sas' resume will be attached to his testimony.
(c)
Since its testimony will be filed within two days from the date of these answers, Applicant objects to this interrogatory as being unduly burdensome.
(d)
This information will be contained in the testimony.
See response 2(c).
(e)
The documents relied upon are identified in the testimony.
The documents will be tendered upon request for inspection and copying at intervenor's request.
INTERROGATORY NO. 3 l
l Describe in detail what information or documents lead Mr. Goldberg, HL&P Vice President for Nuclear Engineering l
and Construction, to commission the Quadrex Review.
For such information and documents identify:
(a) its source or author (b) its date (c) whether it is a memoranda, report, letter, or other written document (d) the date or dates when Mr. Goldberg reviewed it.
ANSWER.
Mr. Goldberg's decision to initiate the Quadrex review was based on his knowledge, his professional experience and his observations of the South Texas Project.
No specific documents provided the basis for Mr. Goldberg's decision.
INTERROGATORY NO. 4 Please produce for inspection any documents referenced in question 3.
ANSWER See answer to Interrogatory 3.
INTERROGATORY NO. 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.
ANSWER Mr. Goldberg's decision was based upon his impres-sions developed in part from continuous conversations and reports from a number of employees under his supervision.
It wc1.ld be impossible to recall all such conversations or their substance.
The decision to employ Quadrex was reached by Mr. Goldberg in consultation with Messrs. D. D. Jordan and G. W.
Oprea, Jr. of HL&P.
INTERROGATORY NO. 6 l
Please produce any internal memoranda cr documenta-tion generated as a result of Mr. Goldberg's review and the decision making process which led to Quadrex.
ANSWER See answer to Interrogatory No.
3.
INTERROGATORY NO. 7 Who was present on or about May 7, 1981 at a joint meeting, if any, between HL&P and Brown & Root at which Mr.
Goldberg instructed Brown & Root to conduct a review of Quadrex to determine if any of the findings should be reported to the NRC?
ANSWER Applicant objects to this interrogatory on the grounds that information relating to whether any findings in the Quadrex Report should have been reported to the NRC is beyond the scope of the issues raised in Mr. Doherty's pleading of December 7, 1981, and is not reasonably calculated to lead to admissible evidence.
INTERROGATORY NO. 8 Produce any written memoranda which reflect the substance of this meeting and the persons attending.
ANSWER Applicant objects to this interrogatory for the reasons stated in the response to Interrogatory 7.
INTERROGATORY NO. 9 When did Brown & Root make the report to HL&P of its review of Quadrex referred to in question 87 Who made the report?
If in writing, please produce.
ANSWER Applicant objects to this interrogatory for the reasons stated in the response to Interrogatory 7.
INTERROGATORY NO. 10 Who at HL&P was responsible for further analysis of Quadrex after May 7, 1981?
Produce any memoranda or written policy documents concerning this further view.
ANSWER Applicant objects to this interrogatory on the e
grounds of vagueness.
It is not known what is meant by the term " analysis" nor is it clear that such term is limited in scope to the issues raised in this proceeding.
INTERROGATORY NO. 11 i
Produce any memoranda of the conversation between Mr. Don Sells, and Mr. Goldberg ccncerning Quadrex which occurred:the week of May 11, 1981.
ANSWER Applicant objects to searching for or producing such documents on the grounds that the referenced conversation is not relevant to the issues before the Licensing Board,
+
nor could such information lead to admissible evidence.
INTERROGATORY NO. 12 Produce a copy of the December 3, 1981 letter to the Licensing Board sent by HL&P attorneys in the STNP licensing proceedings.
t ANSWER A copy of the letter will be produced for inspection l
l and copying at intervenor's request.
Respectfully submf M,td,
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OF COUNSEL:
J.
Gregor Lc. peal-
[ cotthE[ ozzell BAKER & BOTTS 3000 One Shell Plaza 000 On Shell Plaza l
Houston, Texas 77002 UHouston, Texas 77002 LOWENSTEIN, NEWMAN, REIS &
Jack R.
Newman 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
STATE OF TEXAS l
COUNTY OF HARRIS l
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 "First Set of Interrogatories and Request for Production of Documents Regarding TexPirg Contention 31 from Intervenors Dogget, Conn, Cumings, Lemmer, and Johnston," 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.
s so
. H. Goldberg y f SUBSCRIBED AND SWORN TO BEFORE ME by the said J. H. Goldberg, on thisd.3 day of March,1982.
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NotaryPublic,StateofTexa[s My Commission Expires a/2 /J '
i BRENDA REED l
Notary Publi:, State c x
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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 Houston Lighting &
Power Company's Answers and Objections to Interrogatories of Doggett, et al in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery thisJ6ds day of March, 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 l
Susan Plettman Richard Black j
D' avid 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 i
l
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, Texas 77478 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401 i
VM&w W
J ~ Gr Cop 61and I
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