ML20077P309
| ML20077P309 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/07/1983 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8309130337 | |
| Download: ML20077P309 (11) | |
Text
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j BEIATE COMESPON51 Ext's 1
UNITED STATES OF AMERICA 00cKETED
'SMO J
NUCLEAR REGULATORY COMMISSION
,BEFORE THE ATOMIC SAFETY ~AND LICENSING BOARD In the Matter of
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HOUSTON LIGHTING AND POWER
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Docket Nos. 50-49 Ii sh,f;,('
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50-499 OL "DCf
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(South Texas Project,
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Units 1 and 2)
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CCANP SUPPLEMENTAL ANSWERS TO APPLICANTS' SIXTE SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CCANP I. Introduction In accordance with schedules established by the Board, the
_ Applicants filed their " Sixth Set of Interrogatories and Requests for Production of Documents to CCANP" on March 10, 1983. CCANP submitted its responses and objections to these discovery requests on April 5, 1983 (herein&fter "CCANP Response"). On April 18, 1983,
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the Applicant's submitted a motion to compel CCANP to provide additional responses to their interrogatories and requests for production. The Board gave CCANP until May 31, 1983 to respond to Applicants' motion to compel. CCANP responded to Applicants' motion by reurging the cbjections expressed in the original answers.
The Board granted Applicants' f tion in a Memorandum and Order dated June 22, 1983 (hereinafter " Board Order").
In granting the Applicants' motion, the Board rejected CCANP's objection that the Applicant.s' interrogatories "are extremely burdensome, requiring CCANP to analyze hundreds of findings on
,y multiple issues." CCANP Response at 2. The Board referred to this objection as a " general claim of burden - a claim which clearly is not sufficient." Board Order at 3.
CCANP notes that in Applicants' Answere and Objections to
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tate of Texas's First Set of Interrogatories to Applicants on S
j Quadrex (hereinafter " Applicants' Answers") that Applicants responded u
to a question regarding the notification requirecent for each Quadrex finding, a question very similar to Applicants' questions to CCANP, by N
stating:
w J'b "It is impractical to give detailed reasons for this conclusion [that the Most Serious Findings other than those notified did not require notification] with respect w
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to each of the findings because in the case of most of the findings, there are several of the criteria that were n,ot satisfied; and HL&P has not made a rigorous analysis to 4
identify each of the criteria not satisfi,ed."
Since Applicants consider such a general approach to such questions
.as sufficient, CCANP. assumes Applicants will not object if CCANP
- similarly takes.a general ~ approach to answering Applicants' interrogatories.
In its Memorandum'and~ Order of June 22, 1983, the Board also sets forth the Board's approach to the Phase II' hearings, an
. approach which CCANP finds both disturbing and unwarranted. The Board says:'
"As all parties recognize, the Quadrex Report and the reviews-of that report by Bechtel Corp. and the NRC Staff, respectively, embody an extensive amount of factual information. Much of that information bears on the safety issues in this proceeding,'but other portions _do not - in particular, some information appears to raise economic questions that are beyond the proper scope
'of our review." Board Order at 4.
The character of the Applicants is:a " safety issue." For this reason, the inquiry may well reach beyond what is stricely a safety issue. For example,'the Serious Findings,'which relate to the reliability rather than directly~to the safety.of STNP, may be relevant as showing an I
l abdication of knowledge or a failure to; remain informed so fundamental that~1t violated the internal corporate value system. Specifically, the Applicants failure to be adequtely concerned with whether the plant would l-l' work or not is troof of a far reaching negligent attitude. If Applicants were not protecting their-innediate financial interests, how much less were they protecting the more amorphous public interest?
-The Board says CCANP's task is to' pinpoint those safety issues which "arise from'the.Quadrex Report and have not, in its opinion, been' adequately resolved through the-Bechtel or NRC Staff reviews."
~ Board Order at 4. Once again, the distinction CCANP sought in the p
- earliest stages of this. proceeding - the distinction between past ces ' standing alone and remedial acts - appears to be lost. The j
Board seems to believe that with Brown.and Root gone there is no need-to' dwell on.past failures.
p At the risk of being tiresome -CCANP once again asserts that there is an Issue A in this proceeding and that the Commission itself
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? spoke of past acts as possibly an independent and sufficient basis fordenyinglalicense.FromthevantagepointofIssueA,allacts demonstrating a lack of character or competence, whether remedied or not, are relevant to this proceeding.
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'Furthermore, CCANP asserts the report taken as a whole should i
have been turned over to the Board and NRC Staff. To assess that contention, the reports as a whole must be examined.
As to identifying the issues to be litigated, CCANP made an extensive effort to do so in its Motion for New Contentions filed November 23, 1981.-The Applicants and NRC Staff rejected the CCANP appro'ach and urged that Quadrex be litigated under simply the handling end substance categories of inquiry. The Board accepted that framework for the Quadrex hearings. Now it seems the Board vants CCANP to "take the lead" in separating out more discrete issues. CCANP will make some effort to do so in answering Applicants' interrogatories.
Finally, the Board Order of June 22, 1983 requested the NRC Staff brief various issues. The Board said:
"We desire the Staff to provide further analysis of its determination that most items under the Quadrex Report are not reportable, including the basis for its conclu an that various designs had not been
' released for construction' (within the meaning of 10 CFR Section 50.55(e)(1)(ii)." Board Order at 6.
First_of all, CCANP trusts'that a clear distinction will be made between notification and reporting. 50.55(e) requires notification first and then reporting if the item turns out to be reportable. The question on the handling of Quadrex is very much whether the findings were
" notifiable," if such a word can be coined for this proceeding. The notification decision is made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the discovery c,f the deficiency. The reporting determination can take a long time. For the NRC to address the adequacy of Applicants' compliance with 50.55(e),
l the NRC must assess the notifiability of the findings as well as i
therepotability.-
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l Second, the Board focusses on 50.55(e)(1)(11). In its answers to Applicants' sixth set of interrogatories. CCANP stated:
l "Specifica71y, we challenge the Applicants to even argue, let alone preve, that only three of the hundreds of findings i
represent a breakdown in their quality assurance program."
CCANP Response at 2.
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The CCANP. reference is clearly to 10 C.P.R. Section' 50.55(e)(1)(i).
1The Board request to the NRC Staff could (and hopefully will) be construed to. include.all segments of 50.55(e), but the Board did not specifically:ask the NRC Staff to expl;in why Quadrex items
- wpre not notifiable under 50.55(e)(1)(1). Given the heavy focus
- on the' Quality Assurance Program of Applicants in Phase I and the critical role of tQuality Assurance in deciding the issues in this
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proceeding,;this crucial point needs:to be fully explored. The Board not specifying this item is an indication to CCANP that the I
LBoard may not consider this element as critical'as CCANP does.
' II. Supplemental Answers 1.'Does CCANP contend that HL&P failed to comply with any NRC requirement
- to -report -any information or finding contained in the Design Review of
' Brown and Root Engineering Work for the South Texas Project prepared by
.Quadrex Corporation (the "Quadrex Report")?
t Yes.
2.fIf the answer to. Interrogatory 1 is affirmative state for such CCANP
. contention as follows: '
x(a) If CCANP contends that any.information or. finding contained in the.Quadrex Report was required to be reported by 10 C.F.R. Section 50.55(e),
(i) identify each' separate item which CCANP contends should have' been so
? reported, (ii) forieach such item state.which clauses of 10 CFR 50.55(s)
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'CCANP' contends'to be applicable to'such item and state the factual basis-
-for CCANP's contention that such clauses apply to such item, and (iii)
. identify each expert witness that CCANP expects to testify on its behalf with respect to such item.
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-(b)-If CCANP contends that'HL&P failed to comply with any NRC reporting requirement' other than 10 CFR Section 50.55(e) with respact to any information or~ finding contained inthe Quadrex Report, (i) identify each such separate item which CCANP contends to be applicable, inc16 ding la citation-to the specific NRC regulation or other NRC
. authority.that contains such requirement,.(iii) state the basis for-
'CCANP's. contention that such requirement applies to such item, and L(iv) identify-each expert-witness that CCANP expects to testify on its behalf with respect to such item.
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-Answer 2(a): CCANP contends that all items.in the "Most Serious Findings" category of the Quadrex Report should have been reported.
. to the NRC..By definition,- Quadrex determined these findings posed serious threat 'to licensability; Since the NEC has never denied an operating license, a deficiency in the design and engineering iprocess serious enough to threaten the operating license obviously
?is=of a magnitude requiring notification of the NRC. Quadrex even
-included that such.a finding " addresses a matter of serious concern to the~NRC at this time."
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-Since there were more th'an 100 Most. Serious Findings scattered throughout.the Quadrex Report, the entire report should have been
'given to the NRC, so these findings and their context would be
'available.to the NRC..
.While Applicants may wish to hide behind some restrictive g
I reading of 10 C.F.R. Section-50.55(e), the purpose of 50.55(e) is to -
be!sure the NRC is aware of any serious or potentially serious problem in the design and engineering of a nuclear plant. Applicants Lliandlin's of the Quadrex Report violated the spirit of 50.55(e), frustrated the purpose of 50.55(e), and obstructed the NRC from conducting its l
regul,atory responsibilities.
CCANP further contends that a functioning Quality Assurance
-Program would never have permitted the situation'found by Quadrex 3
in the' Brown and Root design and engineering process. The Most Serious Findings and the report as a whole document a massive breakdown in the Quality. Assurance Program of both Brown and Root and the. Applicants.lThe NRC, therefore, should have been
-notified of.the Most Serious Findings and given the report as a whole pursuant-to 10 C.F.R. Section 50.55(e)(1)(1).
Potential Problem Findings by definition required more study 2
and could turn out to be a Most Serious Finding. Since further study could not be conducted in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, all the Potential l
Problem Findings were notifiable under the same rationale as the Most Serious Findinga.
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Answer 2(b): CCAMP adopts Applicants' objection to the State of
-Texas ~ Interrogatory 27, which in summary says all parties are going to brief reporting obligations in an order of presentation set out l:
.by'the Board with the NRC Staff first.
3..Does CCANP contend, for reasons other than those provided in response. to Interrogatories 1 and 2, that E&P's "comissioning" or '? handling" of the Quadrex Report did not comply with NRC requirements?
, Answer 3: CCANP has nothing to add to its original answer.
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,. If the answer to Interrogatory 3 is affirmative, state the basis p
-for such CCANP contention as follows:
(a) Identify each alledged HL&P action or failure to act in connection with the handling or commissioning of the Quadrex Report l'
which CCANP contends to have been improper.
- (b) For each action or failure to act identified in response to Interrogatory 4(a), identify any E&P officer, employee or agent involved in each such action or failure to act and when such action
.or failure to act occurred.
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U(c) For each action and-failure to act identified in response to Interrogatory 4(a), identify (1)lthe NRC' requirement or other legal requirement {whichCCANPcontendstohavebeenviolatedand(ii)he t
. regulation or other. legal authority which constitutes authority for the existence ofnthe applicable requirement.
(d) For each action _or failurs to act identified in response to Interrogatory 4(a). identify each expert witness that CCANT expects.
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to testify on its behalf with respect to-such action or failure to act.
Answer 4(a) and-4(b):.CCANP has nothing to add to its original answer.
Answer 4(c): See answer 2(b).
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Answer 4(d): CCANP.does not expect to call any expert witnesses.
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~5. Does CCANP contend that any statement, finding, or conclusion in the Quadrex Report reflected that any aspect of the design or engineering of the South Texas Project or of the manner in which such design or engineering was performed failed to satisfy an applicable NRC requirement?
By ' definition, a Most Serious Finding threatened the operatfag license.
To-threaten the operating license such a finding 'imist document a design or engineering item which did not satisfy an applicable NRC requirement.
i By definition, Potential Problem Findingr, could turn out to be Most Serious Findings, so each Potential Problem Finding could be a failure to satisfy an applicable NRC requirement.
6.-If the answer to Interrogatory 5 is affirmative, state the basis for'such CCANP contention as follows:
'(a) Identify each aspect of the design or engineering of the South Texas Project or of the manner in which such design or engineering was performed which CCANP contends failed'to satisfy an' applicable NRC requirement.
(b) For each aspect identified in response to Interrogatory 6(a),
(1) ' identify the NRC requirement which CCANF contends was ~ not satisfied, (ii) state:how the design or engineering or the manner in which the design or_ engineering was performed failed to satisfy such requirement, nand (iii) identify each' expert witness that-CCANP expects to testify on its behalf with respect to such aspects.
. Answer 6(a): By reading the Most Serious Findings.and Potential Problem Findings, Applicants can answer this question for themselves.
b l Answer 6(b):-See Answer 2(b).
- 17. Does CCANP contend that there are any significant errors, ommissions, i-for. improper conclusions.in the Bechtel report entitled " Final Work-Package
'jorworkpackageEN-619.:ReviewoftheQuadrexReport" (EN-619)?
Yes.
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E8.'If the answer to Interrogatory 7 is affirmative, identify each such error, omission or improper conclusion, state the basis for CCANP's contention that each' constitutes an error, omnission or is improper, explain why each is significant, and identify each expert witness that
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CCANP expects to testify on its behalf with respect to such error, omission orLimproper conclusion.
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- TAnswer 8: The'Bechtel report'EN-619 only addresses certain parts of many
..s Quadrex. findings. It is impractical to give detailed reasons for this conclusion with respect to each of the findings because in many' ~ ases, c
I there are several Quadrex points not addressed by Lechtel or merely answered'by al"Bechtel does not to it that way" disposition; and CCANP f
h'as not;made a rigorous analysis to identify each Quadrex concern s
.Bechtel did not address.:(See-Applicants' Answersiat 24-25.)
9.Does CCANP contend that Bechtel's analysis of the Quadrex Report, as' reflected in EN-619 fails to properly address any significant
? concern contained in the Quadrex Report? If so, identify each such concern, state _the basis for the contention that such concern is
.not properly resolved, state the. resolution'which CCANP contends to
- be-appropriate, and the. factual basis-for such resolution'and identify
'each expert witness that CCANP expects to testify on its behalf with
-respect to such concern.
Anaver 9::Since so much of the Bechtel response to: Quadrex is nothing
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I more than mere promises and since only Region IV is available to ensure
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-those promises are met, CCANP has little confidence in Bechtel truly b
fixing'the mess Brown and. Root-left behind, assuming that it is possible J
for Bechtel to even discover all the flaws built in~by Brown and Root.
Unfortunately, unless.the project is cancelled or. the NRC denies thel operating license, we will have.to wait until STNP is turned on to
-kn'ow for sure how peorly Brown and Root.and Bechtel perform under HL&P's direction (or non-direction as the case may be).
See also Answer-8.
- 10. Other than the information provided in response to Interrogatories 8 and 9 does CCANP disagree with'any significant statement,' finding or i,
conclusion contained in EN-6197..If so,'. identify each such statement,
. finding, or conclusica with which CCANP disagrees, state the basis for such disagreement, and identify each expert witness that CCANP expects g
.to testify.on-its behalf with respect to such statement.
-Answer 10: See Answers-8 and 9. CCANP does not have any expert witnesses
[i CCANP can afford to call.
jll. Does'CCANP. contend that there are significant' errors or omissions in the NRC Staff Investigation Report 82-02 (I&E Report 82-02), concerning the handling of the Quadrex~ Report or that I&E Report 82-02 fails to roperly address:any significant concern regarding the handling of the
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drex Report..
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' Answer 11: Yes.
- 12.-~If the answer to Interrogatory 11 is affirmative, ident'fy each i
.such error, omission, or unaddressed concern, state the basis for
.CCANP's contention'that each constitutes an error, omission, or unaddressed concern, explain why each is significant, and identify
~each expert witness that CCANP expects to testify on its. behalf with respect.'to such error, omission or unaddressed concern.
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Answer 12: See; original Answer 11'[ sic).-
- 13. Other than the information provided in response to Interrogatories 11.and:12, does'CCANP disagree with any statement, finding or conclusion I
contained. in I&E Report 82-027 If so, identify each statement, finding and conclusion with which CCANP disagrees, state the basis for such t
disagreement and identify each expert witness that CCANP expects to
-bestify-on'its behalf with respect to such statement, finding or
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conclusion.
JAnswer 13': Not at this time.
- 14. Does CCANP contend that there are significant errors or omissions in NRC Inspection Report 82-12, related to the review of the Quadrex
-Report (I&E Report 82-12), or that I&E Report 81-12 fails to properly address.any significant concern contained in the Quadrex Report?
Answer-14: Yes.
~15.:If;the. answer to-Interrogatory 14 is affirmative, identify each such' error. omission, and unaddressed concern, state the basis-for CCANP's contention that each constitutes an error, omission, or
. unaddressed concern, explain why each is significant, and identify
'each-expert, witness that CCANP expects'to testify on its behalf with
. respect toisuch statement.. finding, or conclusion.
Answe'r'15: The NRC Inspection Report 82-12 is a masterpiece of NRC obfuscation. The~ distortions of the.Quadrex Report are multiple. The tortuing of the En'glish language (resolved meaning incomplete or not even started; NUREG 0948.at 26) is epidemic. The anxious affirmation of Bechtel is unseemly for a regulatory agency. The Labsence of any enforcement action is perhaps.a classic even by
- NRC standards of non-regulation (though perhaps not for Region IV).
- It is impractical to give a detailed response to this question as the NRC distortions,-omissions, and error permeate NUREG 0948; and
.CCANP. has not made a rigorous analysis to identify all such errors, omissions, and unaddressed concerns. (See Applicants' Answers at 24-25.)
16.~0ther that the information provided in response to Interrogatories-
=14:and 15, does:CCANP disagree with any statement, finding, or' conclusion contained in I&E Report 82-12. If so, identify each statement, finding
.and conclusion with which CCANP disagrees, state the basis for such disagreement, and identify each expert-witness that CCANP expects to testify on its behalf with respect-to such statement, finding or conclusion.,
Not at this time.
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'17. Identify each person'CCANP. intends to call as an expert witness at the Phase II hearing, for whom CCANP has-not provided an identification
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and summary of' testimony in response to Interrogatories 1-16, and state the' substance of the testimony of such witnesses.
- Answer 17:'CCANP does not have-the resources to provide experts.
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_9 118.: Identify each person not identified in response to the Interrogatories
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F 1-17 whom CQANP intends to call'as a witness at the Phase II hearing and 2
state the substance of the testimony of such witness.
I Answer 18:.CCANP is providing a listing of witnesses CCANP expectc to
" testify. Some of these witnesses may well be called by another party.
to-the proceeding. Some of the witnesses are identified generically E
~ since their: names-are not yet known.
-Don Jordan - to testify concerning his role in the monitoring of
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Brown and Root's. design and engineering process at STNP, his perceptions of that processyin the 1977 to 1981' period, any actions he took regarding that process (e.g. to reform or terminate it).his role in the' consdssioning(of, the' conduct. of, the handling of, and the response to
- the Quadrex Report, his role in the ultimate decision to terminate Brown i:
L and Root as architect-engineer.
1-George Oprea - same as Don Jordan except for the time period
-Dr. J. R. Sumpter - same as Don Jordan except for the time period e
Cloin Robertson - same as Don Jordan except for the time period Jack R.,Newman - to explain his role in the decision not to deliver lthe Quadrax Report to the NRC' Staff and ASLB prior to September 1981, his role in the ultimate release of the Qua'drex Report.and his
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-representations to the Board and parties regarding the Quadrex Report.
Bechtel personnel - to testify concerning the Task Force Study and EN-619.
Quadrex personnel - to testify concerning the_Quadrex Report.
Richard Herr and Shannon Phillips - to testify concerning the investigation in which the Quadrex Report was finally read by NRC.
personnel.
William J. Dircks - to testify regarding the NRC inquiry into Lthe' handling of the Quadrex Report conducted by Washington, D.C.
[NRCandregardinghisevaluationof,theQuadrexReport.
f Mr. DeYoung - To testify regcrding his role in the NRC headquarters S
inquiry into the handling of the Quadrex Reporc and his findings.
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' Mr. James Liebr. an - to -testify regarding the NRC enforcement policies as they apply to the facts of the Quadrex handling.
Don Sells - to testify regarding his interactions with HL&P i
regarding the Quadrex study and report.
Mr. Hale (NRC Region IV) - to testify regarding his knowledge of the Quadrex Report findings and other problems in the STNP design n -..
and engineering process, his interactions with HL&P regarding the Quadrex Report, and his representations to the. Region IV office-of the NRC concerning the Quadrex Report.
- 19. Identify and produce each document upon which CCANP relies as support-for its contentions or positions as stated in its response t'o this sixth set of interrogatories.
Answer 19: CCANP has nothing to add to its original answer.
- 20. For each interrogatory herein, identify each person who participated in the preparation of CCANP's response.
Answer 20: Lanny Alan Sinkin
= Dated: September 7, 1983 Resp tfull s bmitted.
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Lanny kin Counse for Intervenor Citizens Concerned About Nuclear Power, Inc.
2207 D Nueces Austin, Texas 78705 STATE OF TEXAS COUNTY OF TRAVIS #
BEFORE ME, the undersigned authority, on this day personally appeared LANNY ALAN SINKIN, who upon his oath stated that he has answered the foregoing interrogatories in Applicants' Sixth Set of Interrogatories and Requests for Production of Documents to CCANP in his capacity as counsel for citizens Concerned About Nuclear Power,-Inc. and that all statements contained 4
therein are true and correct to the best of his knowledge and belief.
LANNY p SINKIN SUBSCRIBED AND -SWORN TO BEFORE ME by the said LANNY ALAN SINKIN on this 7th day of September 1983.
derf
/cd Notary Public in and for Travis County, Texas
}pt Commission expires:
BARBARA A. BENJAMIN t
MY COMMISSION E*XPIRES 102946 ff)-ch-
UNITED STATES OF AMERICA NUCLEAR REGULATORY' COMMISSION
,BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'83 EP 12 All :14 CERTIFICATE OF SERVICE I hereby certify that copies of CCANP SUPPLEMENTAL ANSWE MPLICANTS' SIITH SET OF INTERROGATORIES AND REQUESTS FOR PROD OF SECxt rAr -
Of DOCUMENTS TO CCANP was' served by deposit in the United States hC.
first class postage paid to the following individuals and entities on the 7th day of September 1983.
Charles Bechhoef er, Esq.
William S. Jordan, Esq.
Chief Administrative Judge Harmqn and W'iss e
Atomic Safety and Licensing 1725 I Street, NW Board Panel Suite 506 U. S.-Nuclear Regulatory Commission Washington, D.C. 20006 Washington, D.C. 20550 Jack R. Newman, Esq.
~Dr. James C. Lamb, III Lowenstein, Newman, Reis &
Administrative Judge Axelrad 313.Woodhaven Road 1025 Connecticut Avenue, NW Chapel Hill,-NC 27514 Washington, D.C. 20036
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Ernest E. Hil.1 Robert G. Perlis Administrative Judge office of the Executive Lawrence Livermore Laboratory Legal Director University of California U.S. Nuclear Regulatory Commissio2
-P.
O.-Box 808, L-123 Washington, D.C.
20555 Livermore, CA 94550
- Mrs. Peggy Buchorn Atomic Safety and Licensing Board Executive Director U. S. Nuclea r Regul atory ~Cumm.
Citizens for Equitable Wa s hington, D.C. ~10555 Utilities Route 1 Box 1684 Atomic Safety and Licensing
.Brazoria, Texas 77411 Appeal Board U. S. Nuclear Regulatory Comm.
Brian Berwick, Esq.
Washington, D.C. 20555 Assistant Attorney General for the State.of Texas Docketing and Service Section Environmental Prote'ction Office of the Secretary
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Division U. S. Nuclear Regulatory Comm.
P.O. Box 12548, Capitol Station Washington, D.C.
20555 Austin, Texas 78711 Helhlrt Schwarz Bake'r and Botts Lanny/'Sinkin One Shell Plaza Houston, Texas 77002 A