ML20052D271
| ML20052D271 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/03/1982 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8205060424 | |
| Download: ML20052D271 (10) | |
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-May 3, 1982 37 pg -4 M1 :2I UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA
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e In the Matter of
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TEXAS UTILITIES GENERATING
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Docket Nos. 50- 4 and
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50-44
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(Comanche Peak Steam Electric
)
(Application for Station, Units 1 and 2)
)
Operating Licenses)
APPLICANTS' SIXTH SET OF INTERROGATORIES TO CASE AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R.
SS 2.740b and 2.741, Texas Utilities Generating Co., et al.
(" Applicants") hereby serve Applicants' Sixth Set of Interrogatories and Requests to Produce upon Citizens Association for Sound Energy
(" CASE").
Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to CASE, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel.
Each request to produce applies to pertinent documents which are in the possession, custody or control of CASE, its officers, directors or members D503 s
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, as well as its employees, advisors or counsel.
In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceeding each answer or response.
Also, please identify the person providing each answer or response.
These interrogatories and requests shall be continuing in nature.
Thus, any time CASE obtains information which renders any previous response incorrect or indicates that a response was incorrect when made, CASE should supplement its previous response to the appropriate interrogatory or request to produce.
CASE should also supplement its responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony.
The term
" documents" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained, whether prepared by CASE or by another person.
We request that on a date or dates to be agreed upon, CASE make available for inspection and copying, all documents subject to the requests set forth below.
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- APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE Contentien 5.
The Applicants' failure to adhere to the quality assurance / quality control provisions required by the construction l
permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix 3 of 10 C.F.R. Part 50, and the construction practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they nay affect QA/QC), and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy I
of the construction of the facility.
As a result, the Commission cannot make the findings required by 10 C.F.R. 550.57(a) necessary l
l for issuance of an operating license for Comanche Peak.
l l
l-6.-1/ With respect to the I&E Reports on which CASE apparently intends to rely in support of its position on Contention 5, please answer the following questions:
a.
Does CASE contend that any " violations" presented in any of the I&E Reports have not been resolved to the satisfaction of the NRC Staff?
b.
If the response to Interrogatory 1-6.a.
is in the affirmative, please specify the " violations" which you contend have not been resolved.
l c.
For each of the " violations" identified in the response I
to Interrogatory 1-6.b., in what way does CASE contend those matters support its position on Contention 57 i
d.
Does CASE contend that the resolution of any of the
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" violations" raised in I&E Reports has been inadequate?
If so, please specify the specific " violations" which CASE contends have not been satsifactorily resolved.
1/
Applicants have identified these Interrogatories as the Sixth Set to CASE by the hyphen 6 after each number.
. e.
For each of the " violations" identified in the response to Interrogatory 1-6. d., please describe how those
" violations" support CASE's position on Contention 5.
2-6.
With respect to the I&E Reports on hich CASE apparently intends to rely in support of its position on Contention 5, please answer the following questions:
a.
Does CASE contend that the " infractions" presented in any I&E Report have not been resolved to the satisfaction of the NRC Staff?
b.
If the response to Interrogatory 2-6.a.
is in the affirmative, please specify the " infractions" which you contend have not been resolved.
c.
For each of the " infractions" identified in the response to Interrogatory 2-6.b.,
in what way does CASE contend those " infractions" support its position on Contention 5?
d.
Does CASE contend that the resolution of any of the
" infractions" raised in I&E Reports has been inadequate?
If so, please specify the specific " infractions" which CASE contends have not been satisfactorily resolved.
e.
For each of the " infractions" identified in the response to Interrogatory 2-6.d.,
please describe how those support CASE's position on Contention 5.
3-6.
With respect to the I&E Reports on which Case apparently intends to rely in support of its position on Contention 5, please answer the following questions:
a.
Does CASE contend that the " deviations" or " deficiencies" presented in any I&E Report have not been resolved to the satisfaction of the NRC Staff?
b.
If the response to the Interrogatory 3-6.a. is in the affirmative, please specify the " deviations" or
" deficiencies" which you contend have not been resolved.
I c.
For each of the " deviations" or " deficiencies" identified in the response to Interrogatory 3-6.b.,
in what way does CASE contend those matters support its position on Contention 5?
d.
Does CASE contend that the resolution of any of the
" deviations" or " deficiencies" raised in I&E Reports has been inadequate?
If so, please specify the specific
" deviations" or " deficiencies' which CASE contends have not been satisfactorily resolved.
e.
For each of the " deviations" or " deficiencies" identified in the response to Interrogatory 3-6.d.,
please describe how those support CASE's position on Contention 5.
4-6.
Does CASE intend to rely at the hearings on any of the information presented or conclusions made in the March 29, 1982 " Systematic Assessment of Licensee Performance" of the Comanche Peak Project?
5-6.
If the response to Interrogatory 4-6 is in the affirmative, please specify those matters on which CASE intends to rely with respect to that report.
6-6.
Does CASE intend to rely upon any matters raised in Non-conformance Reports ( "NC R' s " ) supplied to CASE?
7-6.
If the response to Interrogatory 6-6 is in the affirmative, please specify those matters on which CASE intends to rely.
Describe the substance of the allegation which CASE intends to support with each NCR.
8-6.
Does CASE intend to rely upon any information contained in Deficiency and Disposition Reports ("DDR's") provided to CASE?
9-6.
If the response to Interrogatory 8-6 is in the affirmative, please specify the particular DDR's on which CASE intends to rely.
Describe the substance of the allegations which CASE intends to support with each DDR.
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10-6.
Does CASE intend to rely upon any Corrective Action Requests ( " CAR' s " ) provided to CASE?
11-6.
If the response to Interrogatory 10-6 is in the affirmative, please specify the particular CAR's which CASE intends to rely upon.
Describe the substance of the allegations which CASE intends to support with those CAR's.
12-6.
Doas CASE intend to rely upon any of the concrete pour information provided to CASE?
13-6.
If the response to Interrogatory 12-6 is in the affirmative, please specify the information on which CASE intends to rely and describe the purpose for which the information will be used.
14-6.
Does CASE intend to rely upon any of the welding information which has been supplied by Applicants?
15-6.
If the response to Interrogatory 14-6 is in the affirmative, please specify the information on which CASE intends to rely and describe the purpose for which the information will be used.
16-6.
Does CASE intend to rely upon any information set forth in the Lobbin Report?
17-6.
If the response to Interrogatory 16-6 is in the affirmative, please specify the information on which CASE intends to rely and describe the purpose for which such information will be used.
18-6.
Does CASE intend to raise any issue with respect to Brown
& Root 's ASME st amps ?
19-6.
If the response to Interrogatory 18-6 is in the affirmative, please specify the information on which CASE intends to rely and describe the purpose for which such information will be used.
a 2
, 20-6.
What are the bases for CASE's responses to Inter.
rogatories 1-6 through 19-6?
Please identify all documents, testimony or oral statements by any person and legal requirements on which you rely in support of your position in those responses.
21-6.
Does CASE possess the " affidavits of workers" re-ferred to on page 25 of CASE's March 15, 1982 An-swers to the NRC Staff's Fourth Set of Interroga-tories?
If so, please produce those affidavits for inspection and copying.
22-6.
Does CASE intend to rely upon any statements made in those " affidavits"?
If so, please specify on what CASE will rely and the purpose for which CASE will use those statements.
23-6.
Does CASE intend to rely upon the " worker" cited at page 28 of CASE's March 15, 1982 Answers to NRC Staff Interrogatories?
24-6.
If the response to Interrogatory 23-6 is in the affirmative, please identify that worker and pro-vide the substance of that person's allegations.
25-6.
Does CASE intend to rely upon the " witnesses" re-ferred to on page 26 of CASE's March 15, 1982 An-swers to NRC Staf f Interrogatories?
26-6.
If the response to Interrogatory 25-6 is in the affirmative, please identify the " witnesses" and describe the substance of their allegations.
27-6.
Does CASE intend to raise any issues regarding pumps manufactured by the Hayward Tyler Pump Company of Burlington, Vermont?
28-6 If the response to Interrogatory 27-6 is in the affirmative, please specify the substance of the allegations which CASE intends to raise in that re-gard and the information on which CASE will-rely in support of its position.
29-6.
What are your bases for the responses to Interroga-tories 21-6 through 28-6?
Please identify all docu-ments, _ testimony or oral statements by any person and legal requirements on which you rely in support i
of your position in those responses.
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30-6.
Does CASE intend to rely upon the " trend analyses" produced by the NRC Staff?
31-6.
If the response to Interrogatory 30-6 is in the affirmative, please specify the information in those trend analyses on which CASE will rely and the purpose for which such information will be used.
32-6.
For each of the NCR's, CAR's and DDR's which CASE has
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copied, what criteria has CASE employed in' selecting those Reports for copying?
For those criteria, what does CASE believe each criterion demonstrates?
33-6.
How does CASE intend to use the NCR's, CAR's and DDR's at the hearing, e.g.,
introduce as exhibits, use for cross-examination, etc.?
34-6.
Does CASE intend to seek subpoenas of any individuals for the hearing.
If so, who does CASE intend to subpoena.
For what purpose will each individual be subpoenaed by CASE?
Respec f ly s bmitted, ll l
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Nichol
/ ) Reynolds 5
Ub hi William A.
Horin DEBEVOISE & LIBERMAN 1200 17th Street, N.W.
Washington, D.C.
20036 Counsel for Applicants May 3, 1982
O J
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 COMPANY, -et al.
)
50-446
)
(Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating License)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing
" Applicants' Sixth Set of Interrogatories To CASE and Requests to Produce," in the above-captioned matter were served upon the following persons by overnight delivery (*)
or by deposit in the United States mail, first class postage prepaid this 3rd day of May, 1982:
Marshall E.
Miller, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Kenneth A.
McCollom Marjorie Ulman Rothschild, Esq.
Dean, Division of Engineering Office of the' Executive Architecture and Technology Legal Director Oklahoma State University U.S.
Nuclear Regulatory Stillwater, Oklahoma 74074 Commission Washington, D.C.
20555 Dr. Richard Cole, Member
%tomic Safety and Licensing David J.
Preister, Esq.
Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C.
20555 P.O.
Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
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- Mrs. Juanita Ellis Mr. Scott W.
Stucky President, CASE Docketing & Service Branch 1426 South Polk Street U.S.
Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20005 d
William A. Horin cc:
Homer C.
Schmidt Spencer C.
Relyea, Esq.
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