ML20151Z228

Responses to Eighth Sets of Interrogatories Re QA Program & Request for Production of Documents.W/Certificate of Svc. Related Correspondence

ML20151Z228
Person / Time
Site:	South Texas
Issue date:	02/12/1986
From:	Sinkin L CHRISTIC INSTITUTE, Citizens Concerned About Nuclear Power, INC.
To:	Atomic Safety and Licensing Board Panel
References
CON-#186-072, CON-#186-72 OL, NUDOCS 8602140101
Download: ML20151Z228 (6)

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UNITED STATES OF AMERICA 2/12/86 00cMETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gg RE813 MO:49 In the Matter of (

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HOUSTON LIGHTING AND ( DOCKET NOS. 50-498 OL DOCHETumasfg.g

POWER COMPANY, ET AL. ) 50-499 OL BRANCH (South Texas Project, (

Units 1 and 2) )

CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. (CCANP)

ANSWERS TO APPLICANTS' EIGHTH SET OF INTERROGATORIES AND BEQUESIS EQB EBQDUCIIQN QE QQGUMENIS (1) The Final Safety Analysis Report (FSAR) for the South Texas Project (STP), as amended through Amendment 52 (November 15, 1985) and HL&P's letters to the NRC Staff through Janaury 10, 1986, describe how HL&P's OA program for operation of the STP will meet the requirements of 10 CFR Part 50, Appendix B. Does CCANP contend that ruch QA program will not fully satisfy the requirements of 10 CFR Part 50, Appendix B, and that revisions or additions to such OA program are necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix B?

1. CCANP does not contend that the Quality Assurance Program for the South Texas Nuclear Project, as amended through Amendment 52 (November 15, 1985) and HL&P's letters to the NRC Staff through January 10, 1986, will not fully satisfy the requirements of 10 C.F.R. Part 50, Appendix B or that any revisions or additions to such DA program are necessary in order to satisfy t'h e requirements of 10 C.F.R. Part 50.

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

2. See answer to Interrogatory (1).

(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.

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_ .i (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 particular revision or addition identified by CCANP.

3. See answers to Interrogatories (1) and (2).

(4). In addition to the inf ormation provided in CCANP's answers to Interrogatories (1) and (2), are there any other facts or reasons which- CCANP contends supports a claim that HL&P's OA program for

- operation of the STP will not meet the requirements of 10 CFR Part 50, Appendix B?

4. CCANP contends that HL&P's OA program for operation of the STP will not meet the requirements of 10 C.F.R. Part 50, Appendix B because HL&P lacks the character to properly implement said program.

(5) If the answer to Interrogatory (4) is yes, describe each fact or reason which CCANP contends supports the claim that HL&P's OA program for operation of the STP 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.

5. In mid-October 1985, while preparing CCANP's proposed findings of fact and conclusions of law in Phase II of this proceeding, CCANP's primary representative received an anonymous telephone call which related the following information:

-- that HL&P did conduct an extensive investigation into the use and sale of illegal drugs at the South Texas Nuclear Project;

-- that said investigation involved the use of lie detector tests as a technique for identifying personnel involved in the use and/or sale of illegal drugs at the South Texas Nuclear Project;

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-- that as a result of said investigation numerous personnc1 were considered to be involved in the use and/or sale of illegal drugs at the South Texas Nuclear Project;

-- that members of the Operations Group at the South Texas Nuclear Project were implicated in the use and/or sale of illegal

- drugs at the South Texas Nuclear Project;

-- that many personnel were terminated as a result of said investigation, but that personnel who would have implicated the Operations Group in the use and/or sale of illegal drugs were not terminated in order to protect the Operations Group personnel; and

-- that no action was taken against members of the Operations Group implicated in the use and/or sale of illegal drugs.

This anonymous tel ephone call is the basis for CCANP's 4

contention that HL&P will not implement the QA program.for operation of the South Texas Nuclear Project in a manner designed to meet the requirements of 10 C.F.R. Part 50, Appendix B.

The allegation was provided to the NRC Office of Investigations in November of 1985. As of January 20, 1986, the Office of Investigations informed CCANP that they were too busy to have begun f

investigating this matter.

(6) Produce all documents described, referred to, or relied upon in CCANP's answers to Interrogatories (1) - (5).

6. CCANP did not describe, refer to, or rely upon any documents in answering Interrogatories 1 through 5.

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

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(December 2, 1980)), and state the substance of the testimony of such witness.

7. CCANP has not identified as of this time any expert witness CCANP. intends to have testify on its behalf with respect to Issue F.

(8) Identify each person not identified in response to Interrogatory (7) whom CCANP intends to have testify on its behalf with respect to Issue F, and state the substance of the testimony.of such witnesses.

8. CCANP has not identified as of this time any witnesses CCANP intends to have testify on its behalf with respect to Issue F.

(9) Separately for each answer or portion of an answer to the foregoing interrogatories, identify each person who prepared or assisted in the preparation of such answer and describe the nature and extent of such assistance.

9. CCANP counsel, Lanny Alan Sinkin, is responsible for all answers provided to the foregoing interrogatories.

Respectfully submitted, (A, Qg A Lanny Alan Sinkin Christic Institute 1324 North Capitol Street Washington, D.C. 20002 (202) 797-8106 Counsel for Intervenor, Citizens Concerned About Nuclear Power, Inc.

Dated: February 12, 1986 Washington, D.C.

DISTRICT OF COLUMBIA 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 Nos. I through 9 in Applicants' Eighth Set of Interrogatories and Requests for Production of Documents dated January 29,_ 1986 in his capacity as Attorney for Citizens Concerned About Nuclear Power, Inc. and that all statements contained therein are ,true and correct to the best of his knowledge and belief. >-

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Lanny lan'd2[n__ S kin SUBSCRIBED AND SWORN TO BEFORE ME by the said Lanny Alan Sinkin, on this 12th day of February, 1986.

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UNITED STATES OF AMERICA f NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD pTED CORRESNWM 00LKETED In the Matter of ( USNRC

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HOUSTON' LIGHTING AND ( Docket Nos. 50-498 OL POWER COMPANY, ET AL. ) 50-499 OL 36 FEB 13 40 :49 (South Texas Project, (

Units 1 and 2) ( OFFILE of a v . t j ,, ,

EMETING a ;Egs!ct' BRANCH CEBIIEICAIE DE SEBVICE

'I hereby certify-that copies of CITIZENS CONCERNED ABOUT NUCLEAR' POWER, INC. (CCANP) ANSWERS TO APPLICANTS' EIGHTH SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS were served by messenger (*) or by deposit in the U.S. Mail, first class postaae paid to the f ollowing individuals and entities on the 12th day of Februarv 1906.

Charl es Bechhoef er , Esquire Brian Berwick, Esquire Chairman Asst. Atty. Gen.

Atomic Safety and Licensing Board St ate of Texas U.S. Nu r. l ea r Regulatory Commi ssion Environmtl. Protection Washington, D.C. 20555- P. O. Box 12548, Capitol Sta.

Austin, Texas 78711 Dr. James C. Lamb, III Administrative Judge Oreste Russ Pirfo, Esquire 313.Woodheven Road Office of the Exec. Leo. Dir.

Chapel Hill, North Carolina 27514 U.S. . Nuclear Regulatory Comm.

Washington, D.C. 20555 Frederick J. Shon Administrative Judae Jack R. Newman, Esquire U. S. Nuclear Reaulatory Commission 1615 L Street, NW, Suite 1000 Washington, D. C. 20555 Washington, D.C. 20036 Melbert Schwarc, Esquire Baker and Botts Mrs. Pegav Buchorn 300 One Shell Pl a r e.

Executive Director , C.E.U. Houston, Texas 77002 Route 1, Box 1684 Brazoria, Texas 77422 Atomic Safety and L'ic. Bd.

U.S. Nuclear Reaulator/ Comm.

Diane Curran, Esquire Washington, D.C. 20555 Harmon, Wei ss 5 Jordan 2001 S Street, N.W., Suite 430 Atomic Saf ety and Licensing Washington, D.C. 20009 Appeal Board U.S. Nuclear Regulatory Comm.

Pat Coy Washington, D.C. 20555 5106 Casa Oro Docketing and Service Section San Antonio, Texas 78233 Office of the Secretary Ray Goldstei n U.S. Nuclear Regulatory Comm.

Gray and Becker Washinoton, D.C. 20555 901 Vaughn Bldg.

807 Brazos Austin, lexas 78701 b... _ _ _ . .

Lan%n Sinlin