ML20136A661

Interrogatories Re Identification of Mechanisms to Detect Deficiencies & Classes of Persons Using Mechanisms Since 840630.Certificate of Svc Encl.Related Correspondence

ML20136A661
Person / Time
Site:	Comanche Peak
Issue date:	11/15/1985
From:	Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
CON-#485-218 OL-2, NUDOCS 8511200002
Download: ML20136A661 (10)

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f.h Ep BEFOREfTHE ATOMIC SAFETY AND LICENSING &OARD i

NOV Jg A10:gg Gre e-In the Matter of ) UNY7fSEccg7,

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• Ei' TEXAS UTILITIES GENERATING )

COMPANY, et al. ) Docket Nos. 50-445-2

) and 50-446-2 (Comanche Peak Steam Electric )

Station, Units 1 and 2) )

c CASE Interrogatories to Applicants (November 15, 1985)

Pursuant to the Rules.of Practice provide full and complete answers to'the following questions in accordance with the following instructions.

INSTRUCTIONS ,

l. Each interrogatory or document response should ,

i include all pertinent information known to Applicants, their l 1

officers, directors, or employees, their agents, advisors, or j' l

counsel. Employees is to be construed in the broad sense of the j l

word, including specifically, Brown and Root, Gibos & Hill, l l

Ebasco, Cygna, O.B. Cannon, any consultants, sub-contractors, and i l

anyone else performing work or services on behalf of the l l

I Applicants or their agents or sub-contractors.

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2. Each answer should indicate whether it is based on the l personal knowledge of the person attesting to the answer and, if l

not, on whose personal knowledge is it based. l 1

3. The term " documents" shall be construed in the broad I 8511200002 851115 PDR ADOCK 05000445 Q PDR

n-sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, audits, slides, internal memoranda, informal notes, handwritten notes, tape recordings, procedures, specifications, calculations, analyses, and any other data compilations from which information can be obtained.

4. As to each document provided, applicants shall consider that providing the document constitutes an admission of ,

its authenticity or, pursuant to 92.742(b), the basis for refusing to so admit.

5. Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory.

Do not combine answers.

6. These interrogatories and requests for documents shall be continuing in nature, pursuant to 10 CFR 2.740(e) and the past directives of the Licensing Board. Supplementation shall be made at least every two months to avoid resubmittal of these interrogatories.

7. For each item supplied in response to a request for documents, identify it by the specific question number to which it is a response. If the item is excerpted from a document, identify it also by the name of the document.

1 INTERROGATORIES

1. Identify all the mechanisms by which a possible l 1

failure to fully comply with an NRC rule, regulation, or j procedure or any plant procedure (hereinafter collectively '

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identified as " deficiencies" or " deficiency") at CPSES could have been identified since June 30, 1984, whether part of the CPRT or net. In your answer cite with specificity the written procedures, if any, applicable to each mechanism identified.

Also identify each type of written record made with respect to each mechanism.

2. Identify all classes of persons other than full-time' employees of TUGCO or Brown and Root who have used any of these mechanisms since June 30, 1984. " Classes of persons" is intended to allow (but not require) this answer to disregard the name of the particular person but is intended to disclose the name of the organization for which the person worked and the person's or organization's status, i.e., independent contractor, consultant, sub-contractor, etc.

3. Describe the procedure (s) that should have been followed during the period June 30, 1984, to the present if a person, other than a full-time employee of TUGCO or Brown and Root, saw a condition at CPSES which they believed may have been a deficiency.

4. Describe any deviation from the procedure described in question 3. For instance, if a written report was required and some persons made an oral report this should be disclosed.

5. Describe in detail how possible deficiencies identified by any mechanism were handled. In particular describe the step by step process from the original indentification to final disposition including all steps where discretion or judgment could be used, the criteria for such discretion or judgment, the method by which the exercise of discretion or L-

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judgment was documented, the person (s) (or their levels) at which the discretion or judgment was exercised, and any and all written record made from original identification to final disposition.

6. Since June 30, 1984, with whom have Applicants discussed (exclude employees of TUGCO and Brown and Root as of June 30, 1984; contractors, subcontractors, or consultants of Brown and Root or TUGCO as of June 30, 1984; lawyers, ,

legislators, government officials, members of the press, investors, investment advisors (including bankers), and CASE or any of its representatives) any of the following:

a. the extent of previously undetected deficiencies at CPSES;

b. programs for identifying the extent of such deficiencies;

c. programs for identifying the root cause of such deficiencies;

d. programs for dispositioning any such deficiences?

In this answer, if more than one person from a single organization was involved in discussions, just list the organization.

7. Of the persons or organizations identified in the answer to question 6, which ones are currently performing any work on one or more of the four identified categories with respect to CPSES?

8. Of the persons or organizations identified in the answer to question 6 other than those listed in the answer to question 7, which onen are currently doing any work with respect L

I to CPSES? Briefly describe the work they are doing. Exclude any individual who is now an employee of Brown and Root or TUGCO but identify approximately how many persons are in this category.

9. Please describe the current job responsibilities of any of the following persons if they are still doing any work with respect to CPSES, list the organization by whom they are <

employed, the immediate supervisor of the work they are doing and that supervisor's employer: C

a. C. Thomas Brandt

b. Gordon Purdy

c. Greg Bennetzen

d. Chuck Welch

e. J. D. Hicks

f. Mark Welch

g. M. G. Krishner

h. Bill cromeans

1. J. B. Leutwyler

j. Doug Snow

k. K. London

1. Ken Luken

m. Frank Powers

n. J. T. Merritt, Jr.

o. James Wells

p. I. Vogelsang

q. H. Hutchison

r. Bob Siever

s. Ted Blixt

t. Dwight Woodward

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10. What, if any, steps have been taken by TUGCO or Brown and Root to rehire persons who have left the plant since January, 1982, and who have subsequently been witnesses in the licensing proceeding and/or made allegations to the NRC about CPSES? Describe in detail the rehiring efforts made, if any, with respect to each such person.

11. To what extent, if at all, has the fact that some of the allegations of some of the persons referred to in Question 10 have been found to be valid by either the NRC or applicants affected steps taken to rehire these persons?

12. How many persons hired by Applicants since January 1, 1984, are experts hired by Applicants for the purpose of preparation for, or in anticipation of this licensing hearing?

This question does not seek a legal conclusion but a corporate answer using the corporation's opinion of the meaning of the question.

13. How many persons working for consultants, contractors, and subcontractors since January 1, 1984, do Applicants claim are 1) experts hired by Applicants, 2) for the purpose of preparation for, or in anticipation of, this licensing hearing? How many of these persons are included in the answer to question 12?

14. How many of the persons identified in the answer to Question 12 and 13 would have been hired irrespective of the existence of this licensing hearing? List those persons, or if more than one person is employed by the same organization, list the organization and the number of persons employed by it.

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15. At what-time, for how long, and under what circumstances may representatives of CASE conduct inspections of construction at CPSES and documents (QA/QC, engineering and design) at CPSES?

Respectfully submitted, M '

Anthony Z. Rosnyn Billie P. G de v i Trial Lawyers for Public Justice 2000 P Street, NW, #611 Washington, D.C. 20036 (202) 463-8600 t Counsel for CASE

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4 November 15, 1985 R UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE OHE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

TEXAS UTILITIES GENERATING )

COMPANY, et al. ) Docket Nos. 50-445-2

) and 50-446-2 (Comanche Peak Steam Electric ) c Station, Units 1 and 2) )

CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Interrogatories to Applicants (November 15, 1985) have been sent to the names listed below this 15th day of November, 1985, by: Express mail where indicated by *; Hand-delivery where indicated by **; and First Class Mail unless otherwise indicated.

Adudnistrative Judge Peter B.. Bloch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Herbert Grossman i Alternate Chairman l ASLB Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074 ,

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Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Ms. Ellen Ginsberg, Law Clerk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels

& Wooldridge 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Nicholas Reynolds, Esquire ** <

Bishop, Liberman, cook, Purcell & Reynolds 1200 17th Street, N.W.

' Washington, D.C. 20036 Stuart Treby, Esquire Geary S. Mizuno, Esquire Office of Executive Legal Director ,

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S. Polk ,

Dallas, Texas 75224 Mr. W.G. Counsil Executive Vice President Texas Utilities Generating Co.

Skyway Tower, 25th Floor 400 N. Olive Street Dallas, Texas 75201

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Mr. Roy P. Lessy, Jr.

Morgan, Lewis & Bockius 1800 M Street, N.W.

Washington, D.C. 20036 Mr. Thomas G. Dignan, Jr.

Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 l J' "'M

' " ANTFONY RO SMART a 1

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