ML20050J111
| ML20050J111 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 04/06/1982 |
| From: | Rozzell J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | DOHERTY, J.F. |
| Shared Package | |
| ML20050J046 | List: |
| References | |
| NUDOCS 8204140171 | |
| Download: ML20050J111 (6) | |
Text
_ __
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD
'g2 gu 12 P7 :61 In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear Generating S
Station, United 1)
S HOUSTON LIGHTING & POWER COMPANY'S ANSWERS TO INTERVENOR DOHERTY'S SECOND AND THIRD SETS OF INTERROGATORIES, QUESTIONS 29 AND 8 RESPECTIVELY, RE QUADREX Pursuant to the Board's Order of March 31, 1982 with respect to Mr. Doherty's Motion to Compel Discovery From Applicant, HL&P herein sets forth its answers to certain interrogatories from Doherty Interrogatory Sets Two and Three:
DOHERTY INTERROGATORY SET 2, 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 knew about it?
(b)
Is it set forth in any documents that HL&P is 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.
0204140171 820406 PDR ADOCK 05000466 i
g PDR l
~_
j ANSWER:
29.
With respect to work performed by EDS (a sub-contractor only to Brown & Root at STP), HL&P was aware that Brown & Root determined that EDS had an approved QA Program pursuant to 10 C.F.R. Part 50, Appendix B.
The EDS program I
was reviewed and approved by Brown & Root.
Periodic audits were conducted to document that EDS engineering activities i
^
were in compliance with its QA Program.
With respect to NSSS work activities performed by Westinghouse (a contractor only to HL&P at STP), HL&P determines that Westinghouse has an approved QA Program pursuant to 10 C.F.R. Part 50, Appendix B.
The Westinghouse 4
Program is reviewed by HL&P and periodic audits are con-ducted to document that Westinghouse engineering activities are in compliance with its QA Program.
Safety-related services supplied by other sub-contractors would be subject to the same review process as described above for EDS and Westinghouse.
1 29 (a).
Yes.
29 (b).
No.
29 (c).
See answer to Interrogatory 29 (b).
DOHERTY INTERROGATORY SET 3, INTERROGATORY NO. 8:
In Sec.
- 3. l (g) of the Report, at p.
3-10, it states design manual or individual engineer log-books to record key bases, assumptions or decisions are especially crucial for the first designed plant for an architect-engineer. -.
r (a)
Prior to start of construction, was Applicant informed this would be Applicant's procedure?
(b)
Will this be the procedure at ACNGS?
(c)
Did Applicant ever suggest these manuals or log-books prior to Quadrex?
If so, when, and to what B&R groups?
ANSWER:
8 (a).
No.
8(b).
No.
8 (c).
No.
Respectfully submitted, OF COUNSEL:
P 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 a
'82 T;P? 12 Pi2:00 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 Applicant's Answers to Intervenor Doherty's Second and Third Sets of Interrogatories, Questions 29 and 8 respectively, re Quadrex in the above-captioned proceeding were served on the following by deposit in the United States mail, prepaid, or by hand-delivery this 6th day of April, 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 l
Atomic Safety and Licensing Appeal Board l
Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission l
Washington, D. C.
20555 Washington, D. C.
20555 l
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 i
I t
L
s e
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 1000 Austin Street, Suite C P.
O. Box 1335 Richmond, Texas 77469 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 Ivf Mount Houston, Texas 77002 Sugar Land, Texas 77478 D. Marrack 420 Mulberry Lane
~
Bellaire, Texas 77401
(
Scott E.
Rozzell e
f i
i
STATE OF TEXAS l
COUNTY OF HARRIS l
BEFORE ME, the undersigned authority, on this day per-sonally 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 and Third Sets, 0uestions 29 and 8 Respectively Re Ouadrex" 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.
bh %
~
J. H. Goldberg \\J SUBSCRIBED AND SWORN TO BEFORE ME by the said J.H. Goldberg, on this g f4 day of April, 1982.
0 9
l $ lw, ~[ c.4 i
[# S'.#*(**
My Com.' ssion Expires y// 7 /rg-Notary ~ blic, State'of Texa of*
/\\
j gg i !
pp., / y\\ /o!
%,,7**=.,,,,,,...**
p
'+tif//;fy gpggN.
OF f
i l
L