ML20050C408
| ML20050C408 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/31/1982 |
| From: | Rozzell S BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | DOHERTY, J.F. |
| References | |
| NUDOCS 8204080477 | |
| Download: ML20050C408 (17) | |
Text
,
cn W M) Cop e,q ,,,,g O G 00'ETi.D <'
s 9-v '-
~ Ryp
~ ~;
llqD
~ APQ7 UNITED STATES OLAMERICA rtl 90 %8 D i JGi 0
NUCLEAR REGULATORY COMMISSION A g
%el}$?"r ti /
BEFORE THE ATOMIC SAFETY &' LICENSING EOARD s 4 9 w
In the Matter of 5 5
HOUSTON LIGHTING & POWER COMPANY $ Docket No. S0-466 (Allens Creek Nuclear Generating $
Station, Unit 1) f HOUSTON LIGHTING & POWER COMPANY'S ANSWERS AND OBJECTIONS TO DOHERTY'S FIFTH SET OF INTERROGATORIES In response to a document entitled "Intervenor Doherty's Fifth Set of. Interrogatories to Applicant With 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 Corporation's review of engineering work at the South Texas Nuclear Project l
l to the Allens Creek Nuclear Generating Station. Mr. Louis J.
Sas, Vice President - Engineering with Ebasco, will testif-y regarding Ebasco's engineering organization for the Allens l Creek Nuclear Generating Station.
l Initially Applicant notes that it has objected to a number of the interrogatories in this Fifth Set because they are irrelevant to the limited issue to be heard in the
$h6e i 204080477 820331 1
[
V
- ^
r 1
. reopened proceeding pursuant to the Board's Order of January 28, 1982. For example, many of Mr. Doherty's interrogatories i 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 Quadrr.x Report, and specifically the matters labelled (A) through (0) 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 such interrogatories, it has also answered s'ome interrogatories of questionable relevance.
Applicant's decision 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 interrogatories contained in the seven sets of interrogatories
4 .
thus' far received'frem Mr. Doherty are not relevantito the reopened Allens Creek proceeding. Moreover, in answering any questions hereinafter, Applicant does not admit the accuracy or relevance of any assumptions made by Mr. Doherty in posing such questions.
INTERROGATORY NO. 1 Referring to Question C/M-8 of the Report, whad 3
was CP-225 uced for?
(a) When did the " glitch" incident referred to in this Question occur? .
~
(b) Did Applicant.ever approve of only reguiring reverification for "significant" changes in~ codes, as in Sections 3.5.a and 3.5.b of STP-DC-Ol7-C?-
s (c). Was Applicant aware of this.. practice by B&R 1,
l prior to the Quadrex Report? If so, when did' Applicant -
l l first become aware'of it? ,
ANSWER
- 1. Applicant. objects to this interrogatory en 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 Additiona'l Evidence on TexPirg Additional Contention 31).
s
9
. ,/ . .
c N
\~ < >
i s,- 5
'""- 1(a). ',Same objection as Interrogatory 1.
/ / .
1(b). Same objection as Interrogatory 1.
'l(c). Same objection as Interrogatory 1. !
INTERROGATORY NO. 2 e
Did HL&P believe, prior to Quadrex, that after a computer program error had been discovered, it wou,ld be transmf-tynd " upward"? (Report; Question C/M-15)
(a) Had HL&P been aware of the lack of " upward"
, transmission, prior to the Quadrex finding?
ANSWER
, 2. Applicant objects to this interrogatory on the ground that the information sought is not< relevant to the t- '
limited issues in this reopened proceeding as identified in i, the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motien For Additional Evidence on TexPibg" Additional Contention 31). $-
2(a). Same objection as Interrogatory 2.
INTERROGATORY NO. 3 Was' Applicant aware that," guidelines for certifying the appropriateness of computer code applications do (did) not now exist", prior to the Quadrex report? (Refer to Sec.
4.2.2.4(h) and Question C/M-7)
(a) What'are the consequences of an inappropriate code?
1
)
1 1
l ANSWER
- 3. Applicant objects to this interrogatory on the j ground that the information sought is not relevant to the limited issues in this reopened preceeding 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).
3(a). Same objection as Interrogatory 3. Moreover, ,
Applicant objects to this interrogatory on the grounds that it is unduly vague and Applicant cannot determine what information is sought.
INTERROCATORY NO. 4 Other than R. Jacobi, how many persons were in Applicant's " licensing division"?
(a) How many of these were registered profes-sional engineers?
ANSWER
- 4. Currently, there are seventeen persons in Applicant's " licensing division", of which nine are engineers.
4(a). There are three registered professional engineers currently in Applicant's " licensing division."
INTRROGATORY NO. 5 Did Applicant believe B&R had guidelines on how to select benchmark problems and a basis or guidelines for
- determining when a program was properly benchmarked, (See
Question C/M-13, and C/M-12) prior to Quadrex?
(a) If so, what Applicant procedure was used to check on this from time to time?
(b) Will Applicant use the same procedure with Ebasco at ACNGS?
ANSWER
- 5. 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).
5(a). Same objection as Interrogatory S.
5(b). HL&P's contracts with Ebasco and General Electric require the use of appropriate design and engineering practices consistent with regulatory requirements. HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that requirements are met. In addition, HL&P reviews
.the acceptability and applicability of analysis methodology including computer codes as part of its regulatory activities.
INTERROGATORY NO. 6 Did HL&P assist in the identification of the In-service Inspection (ISI) area as one to be reviewed by Quadrex?
l
(a) Who was " processing" the exceptions to the access engineering criteria mentioned in the third sentence of the second paragraph of Sec. 4.9.1 of the Report.
(b) When was the contract for an ISI piping boundary table first signed by Southwest Research Institute (SWRI)?
(c) When, if ever, did SWRI visit the STNP site on this contract's work ?
(d) Were any questions submitted to B&R on ISI, in Quadrex's review?
(e) SWRI reviewed a " Brown & Root Inservice In-spection Manual, Doc. No. UO10NM093-A, (See: Attach-ment A). Was this the same as TRD 4UO10PQOO7-A, which Quadrex viewed? .
ANSWER
- 6. 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).
6(a). Same objection as Interrogatory 6.
6(b). Same objection as Interrogatory 6.
6(c). Same objection as Interrogatory 6.
6(d). Same objection as Interrogatory 6.
6(e). Same objection as Interrogatory 6.
INTERROGATORY NO. 7 In what structure and part of what system are:
(a) Line 8" AF-1006 and (b) Line 30" MS-1003, both of which are mentioned on p. 4-93 of the Repert, Sec. 4.9.l(b).
ANSWER 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. 8 Was Applicant aware prior to Quadrex that overhead space for the RHR heat exchangers had been reduced "as the design progressed?" If so, please indicate when Applicant became aware, if Applicant brought any protest or inquiry to B&R at'ut it, and the date and identity of any note, memo, etc. showing either of these on the part of HL&P. (See: p.
4-94, Report)
ANSWER
- 8. 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. 9 What function does valve RH-060B on line 12" RC-1212 BBI perform? Can in-service inspection be performed on this valve without dismantling the operator of the valve or removal of structural restraints as mentioned on pp. 4-94
. and 4-95 of the Report?
ANSWER
- 9. 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. 10 When did Applicant do a Quality Assurance audit of B&R in-service inspection engineering?
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).
INTERROGATORY NO. 11 What was the date of the Quality Assurance audit of B&R which led to the SWRI contract to review the B&R Inservice Inspection Manual?
ANSWER
- 11. 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. 12 Was Applicant aware that the first 93 of the 97 pages of the B&R Inservice Inspection Manual, UO10NM093-A were retypes of ASME Section XI, prior to the SWRI contract report, mentioned in Sec. 4.9.1 of the Report?
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 Did Quadrex ever mention in its ISI review any welds requiring ultrasonic examination located in the reactor shield wall penetration holes?
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 If not, was Applicant aware of any such welds at STNP prior to Quadrex?
ANSWER
- 14. 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. 15 Was July 1979, the first month HL&P learned B&R inspection manual had not been revised since 1976? (See:
Attachment B)
ANSWER
- 15. 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. M For how long prior to July 1979, had the FSAR to ST" in Sec. 6.6.8, stated: "An augmented ISI program, to in..ude all high-energy piping greater than 1-in. diameter that penetrates the primary containment, will be conducted?"
(See Attachment C)
(a) What will Applicant do in its ACNGS organiza-tion to prevent differences between FSAR commitments and actual practice from occurring such as this at the ACNGS site?
i ANSWER
- 16. Applicant objects to this interrogatory on c'he 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).
16(a). Ebasco and General Electric provide HL&P with the pertinent PSAR provisions and the updates thereto.
i HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications as well as SAR changes. As stated in PSAR Section 17.1.16A HL&P QA audits Ebasco and General Electric activities to verify compliance with the QA Program.
INTERROGATORY NO. 17 Did B&R first agree to issue as a Technical Reference Document (TRD) its ISI manual in July 7.979?
(a) Referring to Sec. 4.9.1 of the Report, was this TRD still only in draft form on Feb. 6, 1981?
(b) Was the TRD completed prior to B&R's departure from the STNP project?
ANSWER
- 17. Applicant objects to this interrogatory on the ground that the information sought is not relevant to
r 1 1
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).
17(a). Same objection as Interrogatory 17.
17(b). Same objection as Interrogatory 17.
Respectfully submitted, OF COUNSEL:
J. Gregory Copeland ~~
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 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 HOUSTON LIGHTING & POWER COMPANY STATE OF TEXAS 1 COUNTY OF HARRIS l BEFORE ME, the undersigned authority, on this day personally appeared J. H. Goldberg, Vice President - Nuclear Engineering & Construc-tion for Houston Lighting & Power Company, who upon his oath stated that the foregoing answers to "Intervenor Doherty's Fifth Set of Interroga-tories Re Quadrex," were prepared under his suparvision-and direction, and that all statements contained therein are true and correct to the best of his knowledge and belief.
N. M" J. H. Goldberg SUBSCRIBED AND SWORN TO BEFORE ME by the said J. H. Goldberg, on this Di ayd of March,1982.
wonentri,
$0/ \ct h Phh ) Y NotarpfPublic,StateofTexasg j JN j j My Cognission Expires 2/f y 7 fr
%e A co E
$1mUmt .;
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 Doherty's Fifth Set of Interrogatories in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 3f E 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 P. O. Box 12548, Capitol Station Commission Austin, Texas 78711 Washington, D. C. 20555
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 C .
N Scott E. Rozzell
.