ML20137A873

Motion to Incorporate Proposed Corrections to Transcript of 851205-06 Hearing

ML20137A873
Person / Time
Site:	South Texas
Issue date:	01/09/1986
From:	Gutterman A HOUSTON LIGHTING & POWER CO.
To:
References
CON-#186-746, CON-#1860746 OL, NUDOCS 8601140567
Download: ML20137A873 (21)

Text

_.

.N UNITED STATES OF AMERICA OdOV-NUCLEAR REGULATORY COMMISSION US ?c BEFORE THE ATOMIC SAFETY AND LICENSING NhAR v4 Ni:69

' ~ ~

In.the Matter of

)

~s

)

HOUSTON LIGHTING & POWER

)

Docket Nos. 50-498-OL COMPANY, ET AL.

)

50-499 OL

)

(South Texas Project, Units 1 )

and 2)

)

APPLICANTS' MOTION TO INCORPORATE TRANSCRIPT CORRECTIONS Applicants have reviewed the transcripts of the hearing on December 5 and 6, 1985 and hereby move that the Board adopt and inc~orporate their proposed transcript corrections, which are appended to this motion as Attachment A.

Respectfully submitted, Y

u kh ;!'tw Jack R.

Newman Maurice Axelrad Alvin H. Gutterman Donald J.

Silverman 1615 L Street, N.W.

Washington, D.C.

20036 Finis E. Cowan 3000 One Shell Plaza Dated:

January 9, 1986 Houston, Texas 77002 NEWMAN & HOLTZINGER, P.C.

ATTORNEYS FOR HOUSTON LIGHTING &

1615 L Street, N.W.

POWER COMPANY, Project Manager Washington, D.C.

20036 of the South Texas Project acting herein on behalf of itself and the other Applicants, BAKER & BOTTS THE CITY OF SAN ANTONIO, TEXAS, 3000 One Shell Plaza

-acting by and through the City Houston, TX 77002 Public Service Board of the City of San Antonio, CENTRAL POWER l

AND LIGHT COMPANY, and CITY OF-AUSTIN, TEXAS Attachment l

B601140567 860109 PDR ADOCK 05000498 3 sos

Attachmsnt A Part I of II Changes to 12/5/85 Transcript 1

Pages 15388 - 15382

}

i Eage Line chance k

15399 12 "dp" to "did" 15400 8

"dp" to "did" 15400 9

" indicated" to " abdicated" 15405 19 "any" to "my" l

15411 14 "unlaterally" to " unilaterally" 15412 16 "I"

to "He" 15414 9

"by" to "of"

{

15421 7

insert " indication" after "some" l

15429 18 insert " Applicants' 83 is" after "82." and

[

"the" to "The" l

15434 24 "whether" to "when" 15437 23 "Galaway" to "Galloway" 15439 5

" mark" to " marked" 15440 12 "83" to "81" I

15441 2

"Stphao" to "Sinkin" f

15441 10 "each in" to "in each" 15442 2

place "3:10 end" in quotes i

15443 13

" recollection to" to " recollections at" 15443 20

" emphasis of" to " emphases or" 15444 2

"take" to "say" a

f i

i r

6.

EAgt Line Chance 15444 7

"integgrated" to " integrated" 15444 17 "that" to "of what" 15444 20 "integgrated" to " integrated" 15444 24 "integgrated" to " integrated" 15445 2

"two owners" to "co-owners" 15445 21 "tthis" to "this" 13447 9

invert "those" and "are" 15447 11

" question." to " question?"

15447 13 "you are" to "your" 15447 14

" yon are reaction" to "your recollection" 15448 13 insert "about," before "in" 15448 15 delete "when" 15448 16 insert "there" after " recorded" 15448 20 "their" to "this" 15449 7

insert "it" after "wanting" 15449 13

- their" to "this" 15450 6

" question" to " questions" 15450 24

" stand still" to " standstill" 15451 6

" restart or" to " restart, or" 15451 7

" days the" to " days, the" 15451 8

"the knawing" to " gnawing" 15451 24 "of" to "in" and "with" to ", what" 15451 25 "of work," to "were, they" 15452 4

"been in" to "been, in" t

i

l -

Eagt Line Chance 15452 20 "anything of" to "that being" 15453 13

" reaction" to " recollection" 15454 6

"one capital" to "one, capital" 15454' 21 delete "to" 15455 11 "out"~to "out,"

15455 12

" meeting was" to " meeting, was" 15455 15

" DEFENDANT" to "AXELRAD" 15456 6

"II-E" to "2.e."

15456 10 insert "the" before "so-called" 15458 7

"810351" to "81051" 15458 8

" "S; April" to " "S: April" 15458 10 insert "that" after " thing" 15458 20 insert "to" after "go" 15459 2*)

"and" to "as" 15459 25 insert "the" after "did" 15462 16

" report" to " record" i

15462 19 "just sure" to "sure just" 15463 20

" inspection of what" to "" inspection of what?" and" 15665 18

" agenda" is" to " agenda," is" 15465 19

" San Antonio who" to " San Antonio, who" 15466 3

" Barker" to " Barker," and delete "was" 15467 4

" items" to " item" 15467 6

"albeit" to "albeit" i

I I

-t I

t M

'+

'"r

'-w--

- Page king Change 15467 22 "Lyebrand" to "Lybrand" 15467 25 "them" to'"him" 15468 1

insert "did" after "or" 15468 2

"of" to "up" and " materials" to " material" 15469 22 "whether" to "whether, when" 15470 1

" asked about" to "asking about my" 15471 13 "the" to "of" 15471 19 "through" to "though" 15471 20 "the" to "their" 15471 25

" tails" to " tales" 15472 19 "by December 4," to "by -- December 4,"

15472 21

" afternoon and" to " afternoon -- ard" 15473 19 "that as" to "that, as" 15474 13 "Lyebrand" to "Lybrand" 15474 18 "where" to "were" and " quarterly, what's" to " quarterly.

What's" 15475 19 "more" to " matter" 15475 20.

" afternoon," to " afternoon and" 15476 2

insert "is" after "that" 15476 15 "why" to "I" and "Quadrex.

I" to "Quadrex the first time I" l

15476 19

" progress. and"'to " progress and" 15477 9

insert "were" after " dates" 15477 14 "the" to "that"

(

15477 21 insert "that" after "or"

. Pace Ling Chanae 15478 20 "in" to "at" j

15479 10 delete "a" 15479 12 "at" to "that" 15480 3

insert "are" after "These" 15480 4

" thing" to " things" 15460 15 "that we" to "of the" 15480 16 "we view" to "to the review that" 15481 18 "and a" to "an" 15482 8

" Exhibit" to " Exhibits" 15484 3

"I-D." to "I-D7" 15484 4& 5 delete these lines 15484 17 insert " heterogeneous" after "this" 15484 18

" party to " project" 15485 6

"was" to "were" 15486 1

" partnership" to " participation" i

15486 17 insert "the" after " effort,"

15487 5

insert "it" after " handling" 15488 1

"was and" to "was, or" and "I-G was" to "I-G, was" 15488 12 delete "was that" 15488 22 "1984" to "1980" i

(

15489 1

"with in" to "within" h

15489 10 insert "had" after "he" 15499 24 "always as" to "always, as" l

i l

5

- Pace Line Chance 15492 1

"has" to "had" 15492 5

insert "or" before production" 15492 8

insert "an" after " problems of" 15492 9

insert " nature" after " construction" i

15492 11 "I believe, 1980, that they" to "of late 1980.

They" 15492 13

" created a" to " created, as a" 15492 16 "they" to "there" 15492 22

" concretes" to " concrete" 15493 2

delete "was" 15493 8

" work particularly" to " work, particularly" 15494 2

"81045 which" to "81045, which" 15494 5

" message," to " message of" 15494 6

" call, I" to " call -- I" 15494 7

"I had feared it" to as "I had feared --

it" 15494 9

"how" to "however" 15494 10 delete "ever" 15495 5

delete one "that" 15495 11 "of" of "if" 15495 12 "as being" to "had been" and " written had" to " written report -- had" 15496 2

"say" to "saying" 15497 7

delete "it" 15497 8

"that without" to "that, without"

' EAgg Line Chanae 15498 5

" meeting, at" to " meeting.

At" 15498 10

" changes in" to " changes, then" 15498 22

" documents" to " statements" 15499 14 insert "of things" after " list" 15499 20 insert "be" aft'er "would" 15502 2

"do",to "to" 15502

.4 & 5

" half of this" to " Applicant's" 15502 16 "at" to "of that,"

15502 19 "whether" to "when" and " quote" to " quotes" 15502 21

" attached to it" to " attached,"

15505 18

" unintentionally" to " intentionally" 15509 23

" character as to" to " character. To" 15509 24 "inordinant" to " inordinate" 15510 3

" performances" to " performance of" 15510 15 insert " Management" after "STP" 15511 20 "IE-E" to "2.e."

15512 5

delete quotation marks 15512 19 "prerequisits" to " prerequisites" 15512 23 "as" to "at" 15513 4

insert "the" after "obtain" 15513 6

insert "would" after "certainly" and "to be" to "and" 15513 11

" knowledgeable to" to " knowledgeably" 15513 21

" confident" to " confidence" f

, ~

. FAgt Ling Chance 15514 23

" order" to " audit" 15514 25'

" parentheses do" to " parentheses. Do" 15517 3

"other" to "another" 15517 22 "do" to."did" 15518-16 "a" to "the" and "to the - " to "not"

-15518 18-insert "the" after "that" 15519 14

" reaction" to " recollection" 15519 21 delete "and" 15521 7

place " questions" in quotes 15521 12 & 13 delete "or engineering" 15521 23 insert "79" after " Exhibit" 15527 24 delete "have had" 45528 23

. delete "as a matters" 15530 25

" review" to " interview" 15531 1

" review" to " interview" 15531 12 "with" to "of" 15531 13 "that's" to "is" 15531 14 "that's" to "that" 15532 24 "and" to "then" 15534 17 "Saltereilli" to "Saltarelli" and "and persuaded Mr. Salterelli" to "Mr.

Saltarelli and he" 15534 20 "Salerelli" to "Saltarelli" 15535 6

"Salterelli" to "Saltarelli" 15335 7

" corporation" to " cooperation" 9

l

9_

Page Line Change 15537 15

" thigh" to "think"-

15538 6

"maybe" to "is" and delete "been" 15540 20

" question." to " question?"

15541 16 delete 2nd "you" 15542 3

" significance" to "significant" 15542 13

" scene" to "seen" 15545 16 "everybody the" to "be in everybody's" 15545 17

" interests of" to " interests -- of"-

15548 18

" blessings it" to " blessings, as it" 15550 14 delete "go" 15551 19 "my" to "me" 15553 20 "litt" to "little" 15555 11 delete " set" 15556 3

" potential" to "potentially" 15556 8

"it" to "I"

15557 18 "imodest" to immodest" and "tgat" to "that" 15558 23 insert "I" after "but" 15558 24 insert "it" after " mind" r

15562 17 "9th" to "19th" 15563 15 "that" to "the" 15564 22 "by" to "my" 15564 23

" contractors to" to " contractor as to" 1

15565 10

" polk" to " poke" P

r

' Eagt Line Chance 15566 4

"own" to "on" 15566 24 "there" to "they" 15570 14 insert "not" after " notes,"

15573 14

" quiet" to "quite" 15575 24 "they" to "I" 15578 2

"Salterelli" to "Saltarelli" 15578 i4

" Concept" to "The. concept" 15580 10 "forth" to " fourth" l

L

~

l

i AttEchm:nt A l

Part II of II 1

l Corrections to 12/06/85 Transcript Pages 15583 - 15710 Pace Line Chance 15588-22 "for to" to "for, to" 15589 1

"are" to "were" 15592 6

Inser't "the" after "of" 15593 1

"This date" to "today" 15593 3

" meetings" to " meeting" 15594 25

" record" to " report" 15596 7

"that some" to "that. Some" 15596 8

"those" to "some" 15596 9

"represnting" to " required" 15596 11 "was the" to "in" 15596 19

" violate" to " violated" 15596 20 "were" to "was" 15596 22

" conflicts" to " conflict" 15599 2

"there's" to "there was" 15599 3

Insert "to" after " regard" 15600 21 Inser't "Mr. Jordan" after " informed" 15601 21 "was" to "were" 15602 11 "the kurth of" to " occurs at" 15602 12 delete " don't" 15602 15 Insert "in"'after " latitude" l

l l

' Eagt Line Change 15602 20 "our" to "or" 15602 21 Insert "said" after "have" 15603 2

"startup" to " restart of construction" 15603 7

Insert "to" after "was" 15603 11 delete "to be" 15604 24 Insert "if" after "know" I

15606 3

"as" to "that" 15606-5 "has" to "had as" 15606 6

Insert " items".after "Those" i

15606 8

Insert "the" after "of" l

15607 11 "came" to "come" and "to" to "with" i

15608 2

delete "with" 15609 12 "inconstistency" to " inconsistency"

)

15610 1

"with in" to "within" l

C 15610 3

Insert " executive"'after " chief" 1

15610 8

" inform" to'" informed" j

15610 14 delete "well" i

15612 20 "Because" to "Or" l

15614 1

"around which this" to "around, which is" i

15615 4

"were" to "was" l

15616 18&l9 "the first, the fact that the had the Hancock report on.Page 2052, of 79" to "first, Hancock's question about Goldberg's November report on Page 2052, exhibit 79" 15616 23&24 place "who has done pipe analysis" in quotes i

i t

m

_3_

Eggt Ling.

Change 15617 3

" reads itself" to " leads" 15617-4 "it" to " engineering"

15617 5

"Although" to "All" 15617 1L Insert "a" before " third" t

15617 13

" meeting" to " reasons" 15619 9

"as" to "at" "straighhs"to" straits" 15621 3

15621 8

"really organized" to "reorganizg,d" i

15621-13

" operation" to " cooperation" 15622 5

" adjourned" to " heard" 15622 8

"that a" to "the" 6

15623 14

" form" to " forum" 15623 22

" taylor made" to " tailor-made" 15625 1

"it in to "it. Is" 15625 4

" pursuing, that" to " pursuing his permis-sion."

15625 5

" initiation" to " initiative" and insert "him" after "providing" i

15625 6

"a yes, its he" to " status. He" 15625 9

"every the" ' tx) "of the very" 15625 16

" Continuing" to "The continuing" 15625 17

" agreed in concert" to " agreed, together,"

l 15625 18

" authorization" to " effort" i

15626-3 "was to "were" 15626 455 "or as far as commitments schedules" to l

" quality assurance or" i

15626 6

"normally follow that response" to " follow l

reportability requirements" l

i f

i

4R

+

Eagt Line Change b

15626 7.

"this" to "them" 15626 11 second "that" to "have" 15628 11 "is" to "was 15629 8

delete "to me" 15630 17 "if" to "the" 15630 20

" indicated that Mr. Poston" to " indicated, Mr. Poston,"

15635 13

" facts" to " fact" 15635 15 "on a" to "per our" and " responsibilities that" to " responsibilities, that" 15636 5

" reported" to " report" 15637 15 "as I" to "as it should be.

I" j

15638 13 "II-E" to "2.e."

15638 14 "II-E" to "2.e."

15639 1

Insert "who" after " people" 15639 4

"and" to "any" i

15641 6

Insert "whether" after "about" 15641 25 delete "a" 15642 16 "there" to "their" 15643 1

"No, more" to "No more" 15643 7

"it to him" to "him here" 15644 8

delete one "had" 15644 12 "needs" to "need" i

15647 1

" belief" to "beleive" l

15648 3

delete "an" l

I t

l l

-.w y,

-,.,-----,-y e

+, -,. <,,,

c e.

4 '

Page Line Chance 15649 24 "can" to "go" 15650 9

"too" to "took" and "I had" to " describe" 15650 24 "want" to " wanted" 15651 18

" cine" to "come" 15652 9

lift" to " list"

~

15652 12

" issue" to " list" and delete " talk" 15653 14 delete second."you" 15654 14 delete "I"

15654 17 "We had, the" to "The" 15654 18 "with our on" to " discussions with our own" 15654 19 Insert "on" before " engineering" 15655 9

"where" to "whether" 15655 13 delete "an" 15656 17 "the what we call" to "what we called" 15657 1

delete

"<-D>"

15657 4

"are" to "were" 15660 20 "I what" to "What" 15661 15 Insert "do" after "What" e

15661 16 Insert "that" after "do" l

15661 24

" engineering" to " engineer" 15662 7

delete "Is" 15662 8

Insert "do" after "what" and "something" to "that is" 15663 21 "was" to "where it" r

i 4

1 l

• E&gt Line Change 15663 22 "was" to "were" 15563 25.

delete "said" 15664 1

" recommend."" to " recommend?""

15664 2

delete "were" I

15664 3

delete "out" 15664 24 Insert "then" after "around" 15664 25

" filling" to " feeling" 15665 16 delete "at --- say at" 15665 18 "an" to "been e" d

15666 1

"the" to "that" 15666 25

" engineering, the" to " engineering.

The" 15669 4

"were" to "where" and " currents" to

" transients" t

15670 12 delete "with" and "were" to "was" 15671 10 delete "that" 15671 18 second "in" to "Mr."

l 15673 6

"the" to "to" 4

15673 8

delete "was" "this meeting" to "its meaning" 15673 20 i

f 15674 18 "later4r" to "later" l

15675 4

"yet from probably" to "yet.

Probably" 15676 7

"In the"'to "End of" i

15676 19 "remmark" to " remark" 15677 8

" delay" to " delaying" f

I

-.. -... ~ - -. - -

_7-Pace Line Chance 15678 11 Insert "and" after " assigned" 15680 17 Insert "I" after " surmise" 15681 8

"her" to "here" 15682 1

"her" to "here" 15682 14 "on" to "own" "do" to."..to" 15682 24 15683 2

delete "is" 15683 3

"in" to "the" 15684 5

"nto" to "into" 15684 7

"you'll" to "you don't" 15686 11

" Yeah" to "Yes" l

15686 14

"[ hear /her/here)" to "here" 15687 6

"he's" to "you're" 15687 22 delete "will" 15689 20 "Is" to "In" r

15689 24 delete "it" s

15692 3

"me" to "mine" 15692 8

delete "her" l

15692 19 "be" to "been" l

f 15692 21 "be" to "been" 15696 6

"18 and" to "l-A in" 15698 25 Insert "it" after "about" i

I i

l 15699 6

"they" to "the" 15700 14 "came" to "gave" i

i f

1 i

f

~ ~ - - -

_8-P.aste Line Change i

15700 18 "li8k1ey".to "likely"-

.15701 18 "pissibilities" " possibilities" l

15702 14 delete-"ever"

~15704 10

" developing with" to " developing the" 15709 4

"that" to "at" 15709 5

"a" to "an" f

l i

F

.m.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING DOARD In the Matter of

)

)

HOUSTONLLIGHTING & POWER

)

Docket Nos. 50-498 OL COMPANY, ET AL.

)

50-499 OL

)

(South Texas Project, Units 1 )

and 2)

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion To Incorporate Transcript Corrections" have been served on the.following individuals and entities by deposit in the United States mail, first class, postage prepaid on this 9th day of January, 1986.

Charles Bechhoefer,.Esq.

Brian Berwick, Esq.

Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing For the State'of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548, Capitol Station Washington, D.C.

20555 Austin, TX 78711 Dr. James C.

Lamb, III Kim Eastman, Co-coordinator Administrative Judge Barbara A. Miller 313 Woodhaven Road Pat Coy Chapel Hill, NC 27514 Citizens Concerned About Nuclear Power Frederick J. Shon 5106 Casa Oro Administrative Judge San Antonio, TX 78233 U.S. Nuclear Regulatory Commission Lanny Alan Sinkin Washington, D.C.

20555 Christic Institute 1324 N' orth Capitol Street Mrs. Peggy Buchorn Washington, D.C.

20002 Executive Director Citizens for Equitable Ray Goldstein, Esq.

Utilities, Inc.

Gray, Allison & Becker Route 1, Box 1684 1001 Vaughn Building Brazoria, TX 77422 807 Brazos Austin, TX 78701-2553

s

'2 --

~Oreste Russ Pirfo, Esq.

, Robert G. Perlis, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Appeal Board.

U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docketing and Service Section Office of the Secretary.

U.S. Nuclear Regulatory Commission Washington, D.C.

20555 f.'vt imtw

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