ML20049K094
| ML20049K094 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/23/1982 |
| From: | Rozzell S BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | DOHERTY, J.F. |
| References | |
| NUDOCS 8203290401 | |
| Download: ML20049K094 (55) | |
Text
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'82 m 25 mo:36 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION a
BEFORE THE ATOMIC SAFETY & LICENSING BOARD" i
In the Matter of 5
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5 HOUSTON LIGHTING & POWER COMPANY 5
Docket No. 50-466 Q[
(Allens Creek Nuclear Generating S
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Station, Unit 1 5
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~i HOUSTON LIGHTING & POWER COMPANY'S
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ANSWERS AND OBJECTIONS TO DOHERTY'S y n,.
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SECOND SET OF INTERROGATORIES
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In response to a document entitled "Intervenor Doherty's Second Set of Interrogatories to Applicant With ~
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Regard to TexPirg Contention 31 and Quadrex Matters", Applicant answers and objects as set forth below.
As stated in response to Mr. Doherty's First Set of Interrogatories, Mr.
J.
H."
Goldberg, Vice President - Nuclear Engineering and Construction, will testify regarding the pertinence of Quadrex Corpordtion's review of engineering work at the South Texas Nuclear Project to the Allens Creek Nuclear Generating Station.
Mr. Louis J.
Sas, Vice President - Engineering with Ebasco, will testify regarding Ebasco's engineering organization for the Allens Creek Nuclear Generating Station.
5 Initially Applicant notes that it has objected to a number of the interrogatories in this Second Set because they are irrelevant to the limited issue to be heard in the g503 5
/ /
9203290401 820323 PDRADOCK05000ggg Q
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s reopened proceeding pursuant to the Board's Order of January 28,
~
1982.
For example, many of Mr. Doherty's interrogatories are directed at exploring either the details of design of the STP or the Quadrex evaluation of specific Brown & Root engineering practices -- matters which are beyond the scope of the Board's Order.
Questions concerning whether the STP is being safely designed and constructed are before the STP.
Board, which has deferred consideration of all Quadrex related issues until ongoing reviews of the Quadrex Report by the Applicant and the NRC Staff are completed late this year.
The Board's Order did not admit these STP-specific matters for litigation in this proceeding.
Rather, the limited issue to be explored in this reopened proceeding is how the Quadrex Report, and specifically the matters labelled (A) through (O) in Doherty's. December 7, 1981 motion, reflect upon the technical qualifications of HL&P to oversee the design and construction of the ACNGS.
While Applicant has objected to a number of Mr.
l Doherty's interrogatories, it has also answered some inter-rogatories of questionable relevance.
Applicant's decision l
l to answer such interrogatories should not be taken as conceding their relevance to this reopened proceeding.
On the contrary, Applicant maintains that the vast majority of the hundreds of obscure and pointless ;nterrogatories contained in the.
y
3 six sets of interrogatories thus far received from Mr.
Doherty are not relevant to the reopened Allens Creek proceed-ing.
Moreover, in answering any questions hereinafter Applicant does not admit the accuracy or relevance of any assumption made by Mr. Doherty in posing such questions.
INTERROGATORY NO. 1 Has Applicant discussed the results of the Quadrex Report with the Quadrex company at any time after the report was presented in final form?
If so, give the dates, durations, and who among Applicant participated in the meeting for:
a.
Civil / Structural; b. Computer codes; c. Electrical /I&C; d.
HVAC;
- e. Mechanical; f: Nuclear; g.
Piping and Support; h.
Radiological; i. In-service inspection.
ANSWER 1.
Yes. Mr.
J.
Sumpter of HL&P discussed the Report with Mr. Stanley of Quadrex at various times during the l
summer of 1981.
The exact dates or duration of such meetings is not known.
On October 12, 1981, Mr. Jerome Goldberg of HL&P met for approximately one hour with Mr. S.
Naymark and Mr.
L. Wray of Quadrex to discuss the Report.
On November 3, 1981 Messrs. Cloin Robertson, J.
White and J.
Sumpter of HL&P discussed the Report with Mr.
L.
Stanley of Quadrex.
The length of that disucssion is unknown.
On November 5 and 6,
1981, Mr. Cloin Robertson, Mr.
J.
Blau and Mr. Steve Dew
t attended a meeting held in San Francisco between Bechtel and Quadrex.
HL&P personnel acted as obs*rvers in.this meeting and did not actively participate in its discussions.
There were a number of miscellaneous telephone discussions in 1981 between Quadrex personnel and various HL&P enginee'rs.
However, the dates and durations of such discussions and the identicy of the parties who may have been involved are not known.
INTERROGATORY NO. 2
.With regard to finding (a) under Sec. 3.1 "Most Serious Generic Findings" of the Quadrex Report (hereinafter:
Report), did Quadrex mean that there had never been an
" effective systems integration and overview function" through Brown & Root'a (B&R) entirety of association with the STNP until the report?
ANSWER 2.
Quadrex gave no further explanation beyond that which is contained in its report.
l INTERROGATORY NO. 3 l
l What action (if any) did HL&P take with regard to lack of effective systems integration and overview function ihb at the STNP site on the part of B&R prior to the hiring of l
Quadrex?
Make available any documents or correspondence between HL&P and B&R with regard to this if there were s
actions on the part of HL&P on these deficiencies by indi-cating same in your answer to this interrogatory.
(a)
What division within HL&P's organization was responsible for systems integration and overview by B&R at STNP?
(b')
Having seen the criticism by Quadrex on systems integration and overview by B&R, what steps will HL&P take to prevent the reoccurrence of this at ACNGS?
ANSWER 3.
HL&P has not determined that there was a lack of e'fective systems integration and overview.
f 3(a)
Project Engineering.
3(b)
The ACNGS Nuclear Engineering Team of both HL&P and Ebasco are organized to perform a systems engineering function.
Ebasco provides an effective systems integration and overview function as detailed in Ebasco Topical Report,
(
ETR-1001 (Ebasco QA Program for ACNGS), and System Design l
Descriptions.
1 i
INTERROGATORY NO. 4 Referring to Interrogatory #2, (Supra.), if the answer is "no", for what duration does Quadrex believe the deficiency had been current at the STNP site?._
o 4
ANSWER:
4.
Quadrex gave no further explanation beyond that which is contained in the report.
INTERROGATORY NO. 5 Has Quadrex supplied any explanation for this general deficiency to HL&P management, and a recommendation as to how to prevent it in the future?
ANSWER:
1 5.
Quadrex gave no explanation and made no recommenda-tion beyond what is contained in the report.
INTERROGATORY NO. 5 What is Applicant's current belief as to the meaning of the sentence:
"The technical disciplines are
~
organized very tightly.", on p. 3-2 of the Report?
(a)
What significance is this to the problem of a working interface relationship among the disciplines?
(b)
Referring to Report, p. 3-2, when was an i
assigned responsibility for systems engineering developed l
at STNP?
(c)
Is a systems engineering function planned for Applicant in its work of interfacing with Ebasco at ACNGS?
(Report, p. 3-2)?
If so, what is the title of that department, or sub-area?
l l
l 1
-A-
v s
ANSWER:
5.
See the second sentence of the second paragraph on page 3-2 of the Quadrex Report for Quadrex's amplification.
5(a). Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what informa' tion is sought.
5(b). The answer to this interrogatory is stated in answer to Interrogatory No. 6 in Doherty's First Set of Interrogatories.
5(c). Yes, Project Engineering.
INTERROGATORY NO. 6 Assuming personnel turnover does not decrease in frequency at ACNGS from what it was at STNP, what steps will HL&P take to assure internal consistency among various design documents and the maintenance of that consistency?
(Report, p. 3-2).
ANSWER:
6.
HL&P does not expect excessive Ebasco engineering personnel turnover.
Nonetheless, Ebasco procedures are designed to assure internal consistency among design documents whether or not there is a large turnover rate among Ebasco personnel. -
s INTERROGATORY NO. 7 Has HL&P had experience with high personnel turnover problems at other construction projects?
(a)
Has HL&P drawn on the experience of any other utilities with this problem?
(b)
If the answer to 7(a) is "yes", which utili-ties, and at which nuclear construction projects?
(c)
Will dealing with this problem be a respon-sibility of Mr. Goldberg?
ANSWER 7.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
7(a). Applicant objecdh to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
7(b). Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought. _
t 7(c). If there were a turnover problem at Allens Creek, dealing with it would be the responsibility of the Vice
~
President, Nuclear Engineering and Construction.
INTERROGATORY NO. 8 Was Brown & Root terminated on September 24, 1981?
(a)
Referring to Exhibit "A" attached, what is the basis for the " confidence" meraioned on the 3rd page of Exhibit "A"?
ANSWER 8.
See answer to Interrogatory No. 6 of Doherty's First Set of Interrogatories.
8(a). HL&P objects to this interrogatory on the grounds that questions related to the continuation of construction activities at STP, as discussed in the letter attached as Exhibit "A",
are not relevant to this proceeding.
INTERROGATORY NO. 9 What provisions wall be made to confirm that all disciplines at the ACNGS site will use the same interpretation of various criteria, such as " single failure criteria", that were not provisions at the STNP site?
(a)
What provisions were there at the STNP site?
ANSWER 9.
The provisions for control of design and engineering are described in PSAR, Section 17.1.3A and Ebasco Topical
_9_
s Report-1001.
It has not been established that similar provisions were not utilized at STP.
9(a). In addition to the ordinary and routine management, and supervision of Brown & Root personnel, Brown & Root issued a Project Design Manual that included design criteria to be used a't STP.
Other design criteria were addressed.in Technical Reference Documents and other project documents.
INTERROGATORY NO. 10 (See Report. p. 3-3,); in what form will input data to technical groups be given at ACNGS?
(a)
Is this the same form as at STNP?
(b)
Does HL&P agree with Quadrex that such input data was not " consistently reviewed" for reasonableness prior to use at STNP?
(c)
Were the technical groups required to indicate to the source of such. data that it had completed a review of it prior to use?
(d)
In the Report, p.
3-3, Sec. 3.1(b)(1) does the technical group refer only to B&R?
(e)
If the answer to (d) above is "yes", was HL&P a recipient of output data?
(f)
To how many different contractors (or groups of other status) did this output data go to?
s (g)
In Sec. 3.l(b)(1), item M-28 of the report is referred to as showing an instance where figures should have been checked for reasonableness but were not.
Does HL&P agree with Quadrex that Question M-28 shows this omission?
(h)
If (g) is "yes",
was the use of W plant design events what concerned Quadrex?
If so, was B&R using data for a W plant that differed from STNP?
(i)
Who or what group at HL&P provided oversight over the Mechanical group at B&R?
(j)
Had HL&P noticed this prior to Quadrex?
If so, when did they notice, and what steps did they take, if any?
ANSWER 10.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed. Motion For Additional Evidence on TexPirg Additional Contention 31).
Moreover, Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.. _ _ _
s c
10(a).
Applicant objects for the reasons stated in the objection to Interrogatory 10.
10(b).
Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in this interrogatory.
10(c).
Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.
10(d).
Quadrex provided no explanation beyond that which is contained in its report.
10(e).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Moreover, Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.
10(f).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the L
s i
limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Moreover, Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.
10(g).
Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in this interrogatory.
10(h).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
10(1).
Project Engineering Group.
10(j).
Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.
Applicant further objects to this interrogatory on the ground that the effort and expense l
i required to search HL&P files for such information and to otherwise search for the informtition sought would constitute an undue and unwarranted burden on Applicant.
INTERROGATORY NO. 11 (Referring to Question H-3 of the Report); does HL&P believe the Quadrex assessment that heat load calcula-tions were not reviewed for off-normal conditions by the HVAC department of Brown & Root?
How will HL&P management be certain heat load calculations for off-normal conditions will be reviewed by Ebasco at STNP?
ANSWER 11.
First Question:
Applicant objects to this interroga-tory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Second Question:
It is not expected that Ebasco will review STP' heat load calculations.
INTERROGATORY NO. 12 On November 18, 1981, did Mr. Goldberg travel to San Antonio, Texas, at HL&P expense to attend a meeting where he talked about the STNP?,
ANSWER 12.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 13 Referring to item 3.l(b)(1) of the Report, what data was not checked for reasonableness prior to use in relation to question H-27 on air supply rate for the battery room venti ~1ation system?
ANSWER 13.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 14 l
Referring to item 3.l(b)(1) of the Report, what items did Quadrex site [ sic] to HL&P as showing that technical groups do not consistently check to see that their output i
data is used correctly?
l ANSWER 14.
Quadrex provided no explanation beyond that which is contained in its report.
INTERROGATORY NO. 15 How doe; HL&P plan to reduce the number of calcula-tions containing errors being reviewed and found correct by Ebasco when they begin work at the ACNGS site, in civil / structural work?
(See Report, Sec. 3.l(b)(2)).
ANSWER 15.
Calculational errors are minimized by the design review process described in PSAR Sections 17.1.3A, 17.1.5A and 17.1.6A.
Audits performed by HL&P in accordance with QA Procedure SDQAP 18.1 will further minimize the possibility of such errors.
INTERROGATORY NO. 16 Referring to question N-1, how did the "...large temperature error in the main steam line break analysis" get accepted into the'PSAR without notice?
Has Applicant deter-Mined whose responsibility that was?
(a)
What division of HL&P monitored the work of the nuclear analysis branch of B&R?
(b)
What are the technical qualifications of the leader of that division of HL&P?.
ANSWE_R "largetemper$kureerror"refe.encedinthis 16.
The question is a conservative overestimate of 126 F.
HL&P was aware that this value was conservative prior to its placement in the PSAR.
As clearly identified in Question N-1, "NUS analysis of MS used for PSAR had a large (126* F) and obvious conser-vative error, but was approved to meet PSAR deadline".
This
" error" relates to a preliminary conservative value to be used in the PSAR stage of licensing.
No identifiable safety hazard results from using this conservative value for this parameter.
16(a). HL&P Project Engineering.
16(b). See resume of Steven Dew attached hereto as Attach-ment 1.
INTERROGATORY NO. 17 No Interrogatory.
INTERROGATORY NO. 18 What are the persor.r.1 qualifications of R. Uffer of Quadrex Corp?
ANSWER 18.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the.
limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 19 Does HT,&P agree that as calculated by B&R, and as stated by Quadrex on page N-17, simultaneous orderly shutdown of both STNP plants would have violated Technical Specifica-tions of Essential Cooling Pond temperatures?
(a)
Does HL&P agree that re-examinati.on of these calculations at this time is "not timely"?
(b)
What part of HL&P was delegated to examine B&R's effort on this calculation, if any?
(c)
Had HL&P noted this problem previously and taken steps to change it?
ANSWER 19.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31)..
19(a).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granti.g The Doherty Renewed Motion For Additional Evidence on TexPirg A'dditional Contention 31).
19(b).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
19(c).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 20 l
Was B&R originally retained by Applicant for what is typically called (loosely) a " cost-plus contract"?
l l
I l.
(a)
Was the particular contract one that called for costs plus $12 million dollars for STNP?
(b)
Was the decision to make that offer based on advise from HL&P engineering people in any way?
ANSWER 20.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
20(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
20(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).,
i INTERROGATORY NO. 21 Is there documented criteria governing the evalua-tion process for vendor reports for the ACNGS?
ANSWER 21.
Ebasco Engineering Procedure AC-1 documents criteria use'd in evaluating vendor reports.
Vendor reports are also compared with the design parameters specified by the design engineer.
INTERROGATORY NO. 22 Does Applicant agree with Quadrex that there was no documented criteria existing governing the evaluation process for vendor reports at STNP?
(a)
Was it the responsibility of HL&P QA/QC to be certain such criteria were used at STNP?
(b)
If this was a QA/QC function, how does HL&P QA/QC differ for ACNGS, than it did for STNP at the time of Quadrex?
(c)
Had any division or group at HL&P noticed the item numbered 3.l(b)(3), on p. 3-3 of the Report, and if so was anything tried to alleviate lack of criteria?
ANSWER 22.
Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is l
1 l.
l t
I
waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in this interrogatory.
22(a). No.
22(b). See answer to 22(a).
22(c). HL&P understood that vendor reports were reviewed for compliance with applicable technical requirements.
INTERROGATORY NO. 23 With regard to the Report, p. M-41:
(a)
Is the Refueling Water Storage Tank (RWST) the sole source of ECCS water dur'ing an accident?
(b)
Was it the Applicant.'.s responsibility to make sure B&R had verified the design;of the tank?
(c)
By March 27, 1981, had the tank been purchased?
(d)
In Question M-41, the Report states, "Page 14 -
The calculation of hydrodynamic mass appears incorrect".
Have you or Bechtel determined that this calculation is definitely correct or incorrect, and if so, which?
(e)
Are the component cooling water heat exchangers (CCWHE) of any safety system?
(f)
Are these analogous to BWR residual heat removal system heat exchangers?
I l
l i
(g)
Had any HL&P personnel noticed prior to the Quadrex Report that:
(1) weight calculations for the CCWHE ignored the fluid weight in the tubes?
(2) hydro-dynamic mass effects in the calculation of the tube sheet natural frequency had been ignored?
(h')
What are the personal qualifications of D.
Munson, of Quadrex, Inc.?
(i)
What organizational changes have been made by Applicant in response to lack of documented criteria documenting the evaluation process for vendor reports used by the mechanical engineering branch of the STNP architect-engineer?
Will these or any other be carried over to the architect-engineer at ACNGS?
ANSWER 23(a). Applicant objects to this interrogatory on the grc6nd that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
23(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
23(c). Applicant objects to this intbrrogatory on the ground that the information sought is not relevant to the limited issu'es in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
23(d). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
23(e). Applicant objects to this interrogatory on the i
ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence l
I on TexPirg Additional Contention 31).
23(f). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the. _ _
limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
}
23(g). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further a
objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information s
and to otherwise search for the information sought would s
constitute an undue and unwarranted burden on Applicant.
2 23(h). Applicant objects to this interrogatory on the ground'that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
23(1). None.
No organizational changes are planned to be carried over to Ebasco.
INTERROGATORY NO. 24
]
Referring to Question M-52, did Quadrex state what it was they had in mind when they stated, "The licensing acceptability of analysis done to demonstrate pump operability under normal and accident service conditions is questionable?"
(a)
Was the " accident" the Designed based LOCA?'
(b)
How will the licensing acceptability of pumps be determined for ACNGS?
(c)
What role will Applicant play?
(d)
Will Applicant review all pumps, or audit?
ANSWER 24.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to'the limited issues in this reopened proceeding as identified in,
the Licensing Board's January 28, 1982 Memorandum and Order 1,
(Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
24(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
1 1 r
+
.n.
24(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Ord,er (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
r
~
24(c). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the, limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
24(d). Applicant objects to this interrogatory on the ground that the information sought is not relevant to~the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence l
on TexPirg Additional Contention 31).
INTERROGATORY NO. 25 In question N-1, NUS (a corporation) is mentioned in the Quadrex assessment portion.
Is NUS a completely separate company from B&R?
(a)
How did they become chosen to work on the STNP?
4 m.
ANSWER 25.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
25(a). Applicant objects to this interrogatory on the s
ground that the information sought is not relevant to'the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motien For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 26 On the third page of Question N-1, it states:
There are many values of maximum containment temperature being utilized.
(See Figure N-1) B&R is using saturation temperatures (TA) rather than actual vapor temperatures for defining equipment environments (e.g. compliance to IEEE 323-1974) without performing analyses to determine if equipment can respond to superheat
... c
(a)
Is figure N-1 actually figure N-1-E,
" Main Steam Line Break", the first figure after the text of N-1?
(b)
Was the value for maximum containment tem-perature using a saturation temperature T used in :
A
~(1)
Determining the containment stress?
(2)
Suitable containment materials?
(3)
Containment welding procedures?
(4)
Was the containment shell completed before the Quadrex report for STNP-I as far as welding the plates, but excluding penetrations or doorways?
(c)
Did HL&P ever notice the error Quadrex men-tions on the third page of N-1, and if so, what was done about it?
i l
l (d), Were any HL&P personnel aware that, "The use of saturation rather than actual vapor temperature is not necessarily conservative for equipment and has been justified by analysis.", with regard to design basis event containment temperature?
(1)
If so, what will be done on the ACNGS site to prevent the. misuse of saturation tempera-ture from continuing until equipment is actually purchased?
(See last text page of N-1, Report) 1
(
e
b ANSWER:
26(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting Th'e Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
26(b). Applicant objects to this interrogatory on the
- ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in, the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
26(c). Applicant objects to this interrogatory on the w
r ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing lloard's January 28, 1982 Memorandum and Order-l (Granting The Doherty Renewed Motion For Additional Evidence l
on TexPirg Additional Contention 31).
Applicant further l
objects to this interrogatory on the ground that the effort i
and expense required to search HL&P files for such information and to otherwise search for the information sought would l
constitute an undue and unwarranted burden on Applicant.
l l
30-
,_J
-y
s 26(d). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg A'dditional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
73(d)(1).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Gr ' ting The Doherty Renewed Motion For Additional Evidence on fexPirg Additional Contention 31).
INTERROGATORY NO. 27:
What has Applicant done in the case of STNP, and in the case of ACNGS to verify that a controlled plan to develop environmental conditions for component qualification i
will be done?
(See N-1, 4th page Text, Reoort)
ANSWER:
With respect to STP, Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
With respect to ACNGS, the Allens Creek Equipment Qualification Program will assure that environmental conditions that may affect equipment are properly considered.
As described in PSAR Section 17.1.3A, HL&P Project Engineering provides programmatic direc' ion and overview of Ebasco c
engineering activities to ensure that such activities are conducted in accordance with approved engineering procedures.
HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are met.
As stated in PSAR Section 17.1.18A HL&P QA audits Ebasco activities to verify compliance with the QA Program.
In addition, the HL&P Engineering Assurance Department i
will review selected elements of the design for technical l
l l
adequacy.
l l,
v-w
z
_ INTERROGATORY NO. 28:
Is HL&P aware of any plans used for STNP borrowed or otherwise taken from the Commanche Peak Station?
ANSWER:
28.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY'NO. 29:
Prior to the Quadrex report, was Applicant aware that B&R.had a continuing policy of assuming work performed by suppliers such as EDS Nuclear and Westinghouse could be assumed correct?
(See:
Report p. 3-3)
(a)
Did Applicant agree with this policy if they i
knew about it?
l (b)
Is it set forth in any documents that HL&P is
[
l opposed to this policy prior to the Quadrex report?
(c)
If there are documents as requested in (b) above, please list them and make them available to this Intervenor.
ANSWER:
l 29.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
29(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
29(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
29(c). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in.
l the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such informa-tion and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
INTERROGATORY NO. 30:
Referring to Sec. 4.3.2.1 of the Report, does Applicant agree with the statement in sub-part 4.3.2.1 (a),
that the common instrument air line, as depicted in FSAR drawing 9.4.2-2 attached to R-6, does not meet the single failure ci terion required by IEEE 279-1971 and 10 CFR 50?
If not, why not?
(a)
If Applicant regards this as a deficiency, has it determined what it should have done to detect the defect prior to Quadrex's investigation?
(b)
In what way has Applicant a superior organi-l zation for the ACNGS site, so that this type of problem l
will be caught?
(c)
Has Applicant considered the significance of this concern raised by Quadrex as part of R-6?
(d)
If Applicant filed a report on this under 10 CFR 50.55(e), on what date did it do so? t
(e)
If Applicant has not, is this because Applicant does not believe it is reportable?
(f)
Who within HL&P decides if a problem, etc.,
is reportable under 10 CFR 50.55(e) at STNP?
(g)
Will that be the same person as the one who will make 10 CFR 50.55(e) reports for ACNGS?
ANSWER:
30.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and. Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
30(a). As a result of Bechtel's preliminary assessment issued on March 15, 1982, HL&P notified the NRC on that date that this matter was potentially reportable under 10 CFR 6 50.55(e).
HL&P has not reached any definitive judgment as to this matter pending completion of its review.
30(b). Applicant has employed Ebasco Inc., a firm with extensive experience in nuclear engineering, to act l
as architect / engineer at ACNGS.
In addition, HL&P has l
hired Mr. Goldberg, with his experience in the design and construction of nuclear plants, to head HL&P efforts in those areas.
Moreover, HL&P has added additional experienced t l
. ~
1 personnel to its staff and has established an Engineering Assurance Department to provide an enhanced engineering review capability.
30(c). See response to Interrogatory 30(a).
30(d). See response to Interrogatory 30(a).
30(e). See response to Interrogatory 30(a).
30(f). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
30(g). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence l
on TexPirg Additional Contention 31).
INTERROGATORY NO. 31:
l With regard to the statement on p.
3-11 of the Report:
The absence of specific reliability requirements l
l in both mechanical and electrical equipment specifications, i
l I l
T e
and the inability to produce a standard checklist of postu-lated failures to be considered casts doubt on the rigor of the safety-related evaluation process.
(a)
Has Applicant discussed this finding with Quadrex?
~
(b)
Has Applicant agreement with Quadrex that the finding is accurate?
(c)
If the answer to (b), supra, is negative, what does Applicant believe correct?
(d)
Has Applicant's technical personnel reviewed the finding and reported this under 10 CFR 50.55(e), as not in incompliance with 10 CFR 50, App.
B, Criterion II?
ANSWER:
31(a). Yes.
31(b). Bechtel Power Corporation'is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in l
this interrogatory.
31(c). Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to l
reaching a definitive judgment on the matter questioned in this interrogatory.
31(d). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 32:
With regard to the statement on p. 3-2 of the Report:
A working interface relationship among the disciples is not routine particularly regarding follow-through at the discipline input-output interface.
(a)
Has Applicant discussed this finding with Quadrex?
(b)
If so, with whom at Quadrex did Applicant discuss it?
(c)
Does Applicant agree with Quadrex on this?
(d)
If the answer to (c), supra, is negative, what does Applicant believe?
(e)
Has Applicant's personnel reviewed the find-ing and reported this under 10 CFR 50.55(e), as a deficiency under 10 CFR 50, App.
B, Criterion III?
(f)
If not, what is the technical basis for believing it is not reportable?
.)
ANSWER:
32(a). Yes.
32(b).
L.
Stanley.
32(c). Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in this interrogatory.
32(d). Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in this interrogatory.
32(e). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
32(f). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order
- D e
(Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 33:
Referring to Interrogatory 31 above, if Applicant did not report the Quadrex finding on specification and checklist absence, what was or is the technical basis for believing it is not reportable under 10 CFR 50.55(e)?
ANSWER:
33.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
l INTERROGATORY NO. 34:
With regard to the statement on p.
3-8 of the Report:
"In a number of areas the FSAR is out of date."
and the statement on p. 3-8 of the Report:
"There is little evidence of a well thought out and consistent basis for design" and the statement in Sec. 3.1(c), p.
3-4 of the Report:
i i
i 1 l
Design criteria provided in issued System Design Descriptions (SDDs) and Technical Reference Documents (TRDs) appear to adequately reflect industry issues for the 1973-1975 time frame; however, they do not adequately address more recent developments (without consideration
~
of TMI-2 considerations) such as loss of offsite power, environmental conditions in specific plant area, postu-lated failure modes, and anticipated operating condi-tions, degraded from a normal, full-power, all equip-ment operable initial assumption.
(a)
Has Applicant discussed all of these findings with Quadrex Corp.?
(b)
Does Applicant agree with Quadrex on each of these findings?
(c)
If there are any findings above that Applicant does not believe correct, please state Applicant's reasons.
(d)
Does Applicant believe Quadrex Corp. is qualified fully to make such conclusions with regard to B&R at STNP?
(e)
Did Applicant report any of these findings to the NRC under 10 CFR 50.55(e) prior to December 1981?
(f)
Has Applicant reported any of these findings to the NRC under 10 CFR SO.55(e)(1)(ii)?.
(g)
If none of the above Quadrex findings were reported under 10 CFR 50.55(e)(1)(ii) prior to December, 1981, what was the technical basis for believing them unreportable?
(h)
If none of the above Quadrex findings has been reported under 10 CFR 50.55(e)(1)(ii) what is the technical basis for believing them unreportable?
ANSWER:
34(a). Yes.
34(b). Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching.a definitive judgment on the matter questioned in this interrogatory.
34(c). Bechtel Power Corporation is conducting a detailed review of the South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in l
l this interrogatory.
(
34(d). Applicant objects to this interrogatory on the l
ground that the information sought is not relevant to the l
limited issues in this reopened proceeding as identified in l
l the Licensing Board's January 28, 1982 Memorandum and Order 1
(Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention' 31).
34(e). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
34(f). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
34(g). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
34(h). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in.
0 o
the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 35:
With regard to the statement on p.
3-8, Sec. 3.1(f) of the Report:
A consistent and documented B&R position regarding Code and Standards interpretations was not evident.
These interpretations are left to individuals or to vendor suppliers.
The ASME Code interpretation area appears to be particularly weak (see Question M-30).
and a Quadrex Assessment on Question M-30 which states:
Five specifications were examined, and all had deficiencies.
Some of these deficiencies are poten-tially serious.
and, M-30 continued:
That a systematic review (should) be provided for all NRC and industry revised requirements to determine their impact on procured equipment.
(a)
Has Applicant discussed the finding with Quadrex?
(b)
Does Applicant accept the Quadrex finding?
(c)
Has Applicant filed a report with the NRC under 10 CFR 50.55(e)(iii) on this finding with regard to its architect-engineer, B&R? -.
e (d)
What is the technical basis for believing a filing under 10 CFR 50.55(e)(iii) is not needed?
j ANSWER:
35(a). Yes.
35(b). Bechtel Power Corporation is conducting a detailed review of th'e South Texas Project design.
Applicant is waiting for the completion of the Bechtel review prior to reaching a definitive judgment on the matter questioned in this interrogatory.
35(c). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
35(d). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence j
on TexPirg Additional Contention 31).
INTERROGATORY NO. 36:
l Referring to Sec. 4.9.1 of the Report, is it true l
the "In Se~Jice Inspection" TRD was in draft form and there
)
- I
was no other document Brown & Root was using for design for ISI later than 1973 in creation?
(a)
Was Applicant aware of the lack of ISI docu-ments during this eight-year period?
(b)
What did Applicant attempt to do prior to 1979 with regard te ISI at STNP, if it knew B&R was using a 1973 document?
(c)
Did Applicant believe that the use by B&R of,
a 1973 guidance document was satisfactory?
(d)
When did Applicant first document access design problems at STNP?
(e)
Did HL&P QA ever attempt a stop work order due.to access engineering failures?
(f)
If so, was the QA group successful immediately in getting the order issued?
(g)
When was it issued?
(h)
If the answer to (f) is "no",
what does Applicant believe was the reason?
(i)
What part of the Applicant's organization monitored access engineering or ISI at STNP?
(j)
In what ways will that part of Applicant's organization be different at ACNGS?
(k)
Has Applicant been satisfied with ISI Access Engineering at the ACNGS? _ _. _
i (1)
If not, has Applicant attempted to bring this to the attention of Ebasco Services?
ANSWER:
36(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issit'es in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
36(b). Same objection as Interrogatory 36(a).
36(c). Same objection as Interrogatory 36(a).
36(d). Same objection as Interrogatory 36(a).
36(e). Same objection as Interrogatory 36(a) 36(f). Same objection as Interrogatory 36(a).
36(g). Same objection as Interrogatory 36(a).
36(h). Same objection as Interrogatory 36(a).
36(i). Same objection as Interrogatory 36(a).
36(j). Same objection as Interrogatory 36(a).
36(k). Same objection as Interrogatory 36(a).
36(1). Same objection as Interrogatory 36(a).
INTERROGATORY NO. 37:
Has Applicant required Ebasco Services to improve on 'ts ISI engineering management at ACNGS?
Why did they have to?
ANSWER:
37.
See objection to Interrogatory 36(a).
INTERROGATORY NO. 38:
What part of Applicant's QA/QC was responsible for monitoring Computer Program Verification of B&R in-house computer programs having heavy usage?
(See Report, 4-14)
(a)
Had Applicant assessed computer codes used on STNP prior to the assessment mentioned in Mr. Oprea's June 5, 1981 letter (ST-HL-AE678, SEN: V-0530) to Mr. Seyfrit, NRC, Region IV?
ANSWER:
38.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
38(a). See objection to Interrogatory 38.
Applicant further objects to this interrogatory on the ground that the effort and expense require'd to search HL&P files for such information and to otherwise search for the information sought would con-stitute an undue and unwarranted burden on Applicant.
1
)
INTERROGATORY NO. 39:
In Sec. 4.2.2.l(b) of the Report, it states, "The basis used by B&R for de'cermination of safety-related is not sufficient."
(a)
Did Applicant provide this " basis"?
~
(b)
Did Applicant ever expressly approv'e "the basis used by B&R" with awareness it would be used to determine which computer codes would be " safety-related verified" or not?
ANSWER:
39(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
39(b). Same objection as Interrogatory 39(a).
Respectfully submitted, (RD(
l OF COUNSEL:
c W
_ol %
J 7 regory Copelan'd' BAKER & BOTTS Scott E.
Rozzell I
3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, Jack R. Newman REIS & AXELRAD Alvin H. Gutterman 1025 Connecticut Ave.,
N.W.
David B. Raskin Washington, D.C.
20036 1025 Connecticut Ave., N.W.
Washington, D.C. 20036 ATTORNEYS FOR APPLICANT i
HOUSTON LIGHTING & POWER COMPANY - _.
STATE OF TEXAS 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 Second 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.
k.
J.
H.
Goldberg SUBSCRIBED AND SWORN TO BEFORE ME by the said J. H. Goldberg, on this A3w day of March, 1982.
but o
tary Public, State of Texas Commission Expires 6-5 W l
l i
i i
l r
l
i t
STP FSAR 1968 - 1969 - Todd Shipyards Corporation 24 As Nuclear Engineer, Mr. Barker performed analysis and
)
calculations in reactor physics, shielding thermal hydraulics, mechanical design and vibrations in support of the NS Savannah program.
Mr. Barker was later assigned as Project Engineer for the NS Savannah Core II where he was responsible for supervising and coordinating the efforts of engineers, technicians, subcontractors and vendors involved in evaluation of the nuclear and mechanical adequacy of the NS Savannah Core II.
1969 - 1972 - H. B. Zachry Company l24 Quality Assurance Supervisor assisting in the establishment of the company's QA program.
Mr. Barker l
wrote sections of the Company Quality Assurance Manual, 15 performed vendor audits and construction planning.
1972 - 1977 - Houston Lighting & Power Company Joined HL&P as a Nuclear Engineer and in March 1973 was appointed Manager of the Quality Assurance Department.
0 1977 - 1978 Named Power Plant Construction Manager with the responsibility of administration, scheduling and coordination of the construction phase of all power plants.
1978 - Present Named Manager, South Texas Project, assuming total responsibility for all aspects of STP.
5.
South Texas Project, Engineerind Manager Name:
Stephen M. Dew Formal Education:
l l
1968 BSCE - University of Missouri at Columbia Experience:
24 l
l l
1968 - 1972 - Babcock & Wilcox Company l
Fossil and Nuclear start-up engineer; Mr. Dew was instrumental in the development of Babcock & Wilcox's PWR test program; supervised the shipment and receipt of B&W's first nuclear fuel shipment to the Oconee Nuclear Station; had considerable involvement with the testing program on fossil and nuclear plants totaling 4300 Mwe.
13.1-14 Amendment 24
1972 - 1974 - Babcock & Wilcox Three Mile Island
(
Established the B&W startup office and continued as startup engineer following B&W Systems through all stages of testing and power escalation on THI Unit I.
1974 - 1980 - Stone & Webster Engineering Corporation Mr. Dew was Assistant Project Engineer in charge of the Beaver' Valley Site Engineering Office; developed the site project office and procedures which ensure control and responsive support of construction with minimum offsite coordination.
1980 - 1981 - Brown & Root, Inc.
Assistant Engineering Project Manager in charge of the Systems and Equipment Design Group.
1981 - Present - Houston Lighting & Power Company Manager, Engineering, South Texas Project, responsible for all engineering activities on STP.
6.
Manager, Engineering Assurance Name:
R. A. Frazar 1
Tormal Education:
24 1968 BSCE - Lamar University
(
Experience:
1968 - 1972 - Monsanto Company Corrosion Engineer in the Material Technology Section -
responsible for conducting corrosion studies and field investigations in support of chemical operations.
1972 - 1973 Manufacturing Department - supervised the operation of a pressurized reaction copolymer resin unit.
1973 - 1974 - Houston Lighting & Power Company Metallurgical Engineer in Quality Assurance.
1974 - 1975 Supervising Engineer for South Texas Project Quality Assurance Program.
1975 - 1977 Project Quality Assurance Manager for South Texas Project 1977 to 1981 Manager of Quality Assurance Department - responsible for all HL&P activities related to quality assurance in both the nuclear and fossil plants.
13.1-15 Amendment 24
c 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 Second 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 23rd 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 Susan Plettman Richard Black David Preister Staff Counsel Texas Attorney General's Office U.S. Nuclear Regulatory i
P. O.
Box 12548, Capitcal Station Commission l
Austin, Texas 78711 Washington, D. C.
20555 i
l l
I 1
I l
y, 1
s a
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 F
Sc M. Rozzell l
l 1
l i
_ _ _.,. = _
._