ML20137P630

Eighth Set of Interrogatories & Requests for Production of Documents Re Adequacy of Existing QA Program Described in FSAR Through 851115 Amend 52 & Util Ltrs Through 860110. Certificate of Svc Encl.Related Correspondence

ML20137P630
Person / Time
Site:	South Texas
Issue date:	01/29/1986
From:	Gutterman A HOUSTON LIGHTING & POWER CO., NEWMAN & HOLTZINGER
To:	Citizens Concerned About Nuclear Power, INC.
References
CON-#186-954 OL, NUDOCS 8602050281
Download: ML20137P630 (6)

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i UNITED STATES OF AMERICA poctrnNG 6 k\ ;s Q S ul{Cy((

NUCLEAR REGULATORY COMMISSION /

BEFORE THE ATOMIC SAFETY AND LICENSING BOA g In the Matter of )

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HOUSTON LIGHTING & POWER COMPANY, ) Docket Nos. 50-498 OL ET AL. ) 50-499 OL

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(South Texas Project, Units 1 )

and 2) )

APPLICANTS' EIGHTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CCANP Pursuant to the Licensing Board's November 18, 1985 Order, and Sections 2.740b and 2.741 of the Nuclear Regula-tory Commission's Rules of Practice, Applicants propound the following Interrogatories and Requests for Production of Documents to Citizens Concerned About Nuclear Power.,

Inc. (CCANP). Applicants incorporate herein the instructions and definitions set forth in their First Set of Interroga-tories and Requests for Production of Documents.

Interrogatories and Requests for Production of Documents

.(1); The Final Safety Analysis Report (FSAR) for the South Texas Project (STP), as amended through Amendment 52 (Noventber 15, 1985) and HL&P's letters to the NRC Staff through January 10, 1986, describe how HL&P's QA program i

for operation of the STP will meet the requirements of l

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k il 10 CFR Part 50, Appendix B. Does CCANP contend that such QA program will not fully satisfy the requirements of 10 CFR Part 50, Appendix B, and that revisions or additions to such QA program are necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix B?

(2) If the answer to Interrogatory (1) is yes, identify and describe each revision or addition to the QA program for operation at STP that CCANP claims is necessary to satisfy the requirements of 10 CFR Part 50, Appendix B.

(3)(a) With respect to each revision or addition identified in CCANP's answer to Interrogatory-(2), describe the bases for CCANP's claim that such revision or addition is necessary to satisfy the requirements of 10 CFR Part 50, Appendix B.

(b) In addition, in each instance:

(i) identify, with page references, all documents which provide support for CCANP's claims; and (ii) identify the specific provisions of 10 CFR Part 50, Appendix B, that CCANP claims require

. such revision or addition and explain how such specific provisions require the particu-lar revision or addition identified by CCANP.

(4) In addition to the information provided in CCANP's enswers to Interrogatories (2) and (3), are there any other facts or reasons which CCANP contends supports a claim

I that HL&P's QA program for operation of the STP will not r;eet the requirements of 10 CFR Part 50, Appendix B?

(5) If the' answer to Interrogatory (4) is yes, describe each fact or reason which CCANP contends supports the claim that HL&P's QA program for operation of the STF will not meet the requirements of 10 CFR Part 50, Appendix B, and, for each such fact or reason:

(a) describe the bases for CCANP's contention that the fact or reason supports such claim, and (b) identify, with page references, all documents which provide support for CCANP's contention.

(6) Produce all documents described, referred to, or relied upon in CCANP's answers to Interrogatories (1)

- (5).

(7) Identify each expert witness whom CCANP intends to have testify on its behalf with respecteto Issue F (as accepted for consideration by the Licensing Board in its Second Prehearing Conference Order (December 2, 1980)),

and state the substance of the testimony of such witness.

-(8) Identify each person not identified in response

, to Interrogatory (7) whom CCANP intends to have testify l'

{ on its behalf with respect to Issue P, and state the sub-l

! stance of the testimony of such witness.

(9) Separately for each answer or portion of an answer to the foregoing interrogatories, identify each person i

I L

I who prepared or assisted in the preparation of such answer and describe the nature and extent of such assistance.

Respectfully submitted, W

. Jack R. Newman Maurice Axelrad Alvin H. Gutterman Donald J. Silverman 1615 L Street, N.W.

Washington, D.C. 20036 Finis E. Cowan, Esq.

3000 One Shell Plaza Houston, Texas 77002 Dated: January 29, 1986 NEWMAN & HOLTZINGER, P.C. ATTORNEYS FOR HOUSTON LIGilTING &

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, Texas 77002 Public Service Board of the City of San Antonio, CENTRAL POWER AND LIGHT COMPANY, and CITY OF AUSTIN, TEXAS e

ED COstgESPONM D

q g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 ((g ;4 g86h ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD su 3 b '

In the Matter of ) o ,

HOUSTON LIGHTING & 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' Eighth Set Of Interrogatories And Requests For Production Of Documents To CCANP" have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, or by arranging for delivery as indicated by asterisk, on this 29th 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 1324 North Capitol Street

,, Washington, D.C. 20002 Mrs.' Peggy suchorn Executive D,1 rector Ray Goldstein, Esq.

Citizeds for Equitable Gray, Allison & Becker Utilities, Inc. 1001 Vaughn Building Route 1, Box 1684 807 Brazos Brazoria, TX 77422 Austin, TX 78701-2553

a 4

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 1/

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