ML20206J435
| ML20206J435 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/18/1986 |
| From: | Ellis J Citizens Association for Sound Energy, CONSOLIDATED INTERVENORS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#286-724 CPA, NUDOCS 8606270168 | |
| Download: ML20206J435 (15) | |
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. (fi.A}LU GOIIHfSi'ONU M 6/18/86 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS ON-BEFORE THE ATOMIC SAFETY AND LI NSING BOARD 4'
In the Matter of
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JOIh7 IhTERVENORS' 4TH SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS Pursuant to the Rules of Practice and the Board's 6/6/86 Memorandum and Order (Adoption of Discovery Schedule), Joint Intervenors CASE (Citizens Association for Sound Energy) and Meddie Gregory request responses to the questions below and production of the sought-after documents.
We expect receipt of responses to these interrogatories and requests for document production not later than July 3, 1986', as set forth in Attachment A to the Board's 6/6/86 Memorandum and Order (Adoption of Discovery Schedule) g/.
Instructions 1.
Each interrogatory or document request should include all pertinent information known to Applicants, their officers, directors, or employees, their agents, advisors, or counsel. " Employees" is to be construed in the broad sense of the word, including specifically Brown &
g/ The Board's 6/6/86 Memorandum and Order set June 19 as the last date for Phase I discovery and July 3 as the date on which " rae I discovery closes. The Board also stated that all filings are to be delivered by the due date.
8606270168 860618 PDR ADOCK 05000445 G
Root, Gibbs & Hill, Ebasco, Cygna, Stone and Webster, Evaluation Research Corporation, TERA, any consultants, subcontractors, and anyone else performing work or services on behalf of the Applicants or their agents or subcontractors.
2.
Each answer should Indicate whether it is based on the personal knowledge of the person attesting to the answer and, if not, on whose personal knowledge it is based.
3.
The term " documents" shall be construed in the broad 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 Eocument constitutes an admission of its authenticity or, pursuant to 10 CFR paragraph 2.742(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.
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Interrogatories Some of the following interrogatories refer back to questions contained in Joint Intervenors' 6/9/86 2nd Set of Interrogatories and Request for Documente; in those instances, we have abbreviated the reference such as:
- 0. 2-1 (which would refer to question 2-1 of our 6/9/86 2nd set).
4-1.
(a) Have any HVAC or HVAC-related items had potential 50.55(e) reports written against them? If so, specify each item and state what is the number of such items which had potential 50.55(e) reports written against them. What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable?
(b) If this information is not available in this form, how many potential 50.55(e) reports were written against HVAC or HVAC-related items in 1985? In 1986? What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable?
(c) How many of such 50.55(e) reports were written due to potential or actual problems in design of HVAC or HVAC-related items?
Identify the specific report numbers and provide a general description of each problem.
(d) Which of the 50.55(e) reports in (c) above were determined to actually be reportable?
4-2. (a) Was there a potential 50.55(e) report (or reports) written on the design of the control room ceiling?
(b) If so, identify the specific report number (s) and provide a general description of each aspect of the problem (s). If not, why not?
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4-2 (continued):
(c) If so, did Applicants determine that the problem (s) was actually reportable?
(d) Which of the 50.55(e) reports in (c) above were determined to actually be reportable?
4-3.
Please refer to 0. 2-8, 2-13(e), 2-41, 2-47, and 2-48, and to questions 4-1 and 4-2 above, all of which have to do with various aspects of 10 CFR 50.55(e) reportability. In each of the instances in your answers to those questions, also answer the following questions:
(a) Who (name, title, organication, whether or not part of CPRT) discovered each reportable or potentially reportable item?
(b) Explain whether or not (and if so, explain how) each item was or is being fed into the CPRT effort. Please briefly track each item, explaining what steps each goes through, how it will be worked into the CPRT Plan, and how it will be handled by the CPRT.
(c) For each of these items, please explain what has been done to date. Please supplement your response until all work on each item has been completed.
4-4.
(a) Are all of the problems identified by Stone & Webster being fed back into the CPRT effort (or will they be)?
(b) If so, explain specifically which items are or are not being fed back into the CPRT effort (and if so, explain how). Please briefly track each item, explaining what steps each goes through, how it will be worked into the CPRT Plan, and how it will be handled by the CPRT.
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V 4-4 (continued):
(c) For each of these items, please explain what has been done to date. Please supplement your response until all work on each item has been completed.
(d) If the items under review by Stone & Webster are not being fed back into the CPRT ef fort, please explain exactly how such reinspections, audits, trending, determination of root causes and generic implications, etc., will be handled.
4-5.
Q. 2-22 asked questions regarding reinspections by Stone &
Webster. In addition, answer the following questions:
(a) Is Stone & Webster performing a 100% reanalysis of all large bore pipe supports? Of all small bore pipe supports? Please provide complete details.
(b) Include in your answer to 0. 2-22 and (a) above whether or not such reinspections and/or reanalyses apply only to Unit 1, to both, Unit 1 and Unit 2, or explain whatever the case may be.
4-6.
(a) Break down your answers to 0 2-23, 2-24, 2-25, and 2-26 with regard to Unit 1 Unit 2, or explain whatever the case may be.
(b) Break down your answers to 0. 2-23, 2-24, 2-25, and 2-26 with regard to small bore pipe supports and large bore pipe supports.
4-7.
Have there been recent changes in Stone & Webster personnel (in addition to those discussed in your response to 0. 2-32), such as extensive hiring from the Houston area or other areas, or additional hiring due to strikes, etc.? If so, please supply a summary of details regarding this.
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4-7 (continued):
(We are not at this time asking for details as extensive as a listing of the individuals involved, dates employed, etc.)
4-8.
Do Applicants have any kind (including draf ts) of projection, analysis, estimate, schedule, etc., as to how much of the construction that has been performed, is currently being performed, or is anticipated will be performed is attributable to, or related to, design changes? What does Applicants' trending show in this regard? If any such information exists, identify it with reasonable specificity.
4-9.
Q. 2-6, 2-7, 2-23, 2-39, 2-40, 2-43, 2-44, 2-51, 2-56 (and perhaps others) used the word " generic":
(a) In your responses to those questions, include a statement as to whether each was/is generic to the nuclear industry or generic only to Comanche Peak (i.e., is it a unique, novel, or unusual design).
(b) For each of the items in your response to (a) above which are I
designs which are unique, novel, or unusual only to Comanche Peak, where in l
Applicants' PSAR was each such item specified and discussed?
l 4-10.
Q. 2-28 and 2-29 inquire about methodology and procedures which i
are being used by Stone & Webster regarding certain specific aspects of design.
(a) Is Stone & Webster, in its reanalyses and/or reinspection of pipe supports at Comanche Peak, employing methodology and/or procedures which differ from the methodology and/or procedures utilized by Applicants in their previous analyses or reanalyses, and/or inspections or 6
4-10 (continued):
reinspections?
Specifically state whether or not each such different~
methodology or procedure is being utilized for an item which is one of the Walsh/Doyle allegations, and state which specific allegation is involved in j
each instance.
(b) If the answer (s) to (a) above is yes, please provide a brief summary of the differences in each such instance.
Include in your answer i
the reason for the differences in each such Instance.
4 4-11.
(a) Have Applicants (including the minor owners of Comanche Peak) or any of their consultants or agents attempted to ascertain what i
j caused the problems in design at Comanche Peak (including reports, i
l evaluations, or studies by consultants or others, investigations, etc., and including specifically any and all studies, reports, evaluations, etc.,
I performed by or for Southern Engineering, or performed by or for any of the minor owners of Comanche Peak, and all relevant documents filed with the SEC and/or REA by Applicants and/or the minority owners).
(b) If not, why not?
(c) If so, what documents (as defined on page 2, item 3, herein, and including job or performance evaluations, checks of credentials, adequacy of credentials and training, etc.) existed in the past or currently l
exist regarding such attempt (s)? Our question should be answered regarding not only engineering personnel per sji but also regarding anyone who made decisions which impacted design. List all such documents with reasonable specificity, including date, author (name, title, organization), purpose, i
j etc.
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4-11 (continued):
I (d) If any documents which night have been responsive to (a)
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through (c) above existed in the past but no longer exist, please explain with specificity and in detail the exact circumstances regarding each such document.
4 (e) If so, what was/were the result (s) of such reports, evaluations, studies, etc.?
(f) Either during the research for such reports, evaluations, studies, etc., or in any other context, were there ever other individuals 1
I who expressed the same or siallar concerns as the Walsh/Doyle allegations?
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(g) If the answer to (f) above is yes, please provide specific 1
1 details regarding each such individual, including but not limited tot each q
specific concern (s); the individual's name, title, and organization at the i
time; whether or not each such individual is still employed at Comanche Peak, 1
(either onsite or offsite) and, if so, his/her current title and i
organization; if any such individual is no longer employed at Comanche Peak (either onsite or offsite), such individual's last known address and telephone number; the time or time period (s) during which each such concern was raised; to whom each such concern was reported; the response of each 4
such person to whom each such concern was reported; and Applicants' interim and final resolutions of each such concern.
1 (f) What is Applicants' current evaluation of the competence of j
each (please specify by name) of Applicants' witnesses and/or affiants who j
l participated in hearings, evidentiary depositions, and/or affidavits i
regarding motions for summary disposition regarding design matters?-
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4-11 (continued):
(f) What is Applicants' current evaluation of the credibility of each (please specify by name) of Applicants' witnesses and/or affiants who participated in hearings, evidentiary depositions, and/or af fidavits regarding motions for summary disposition regarding design matters?
(g) Is it currently Applicants' belief that any or all (please specify by name) of Applicants' witnesses and/or affiants who participated in hearings, evidentiary depositions, and/or affidavits regarding motions for summary disposition regarding design matters were wrong in their testimony, evaluations,_ analyses, and/or engineering judgement? If so, please give full and complete details regarding each such individual and his/her testimony / depositions / affidavits, along with a listing of relevant documents involved.
(h) Do Applicants have any reason to believe that any or all of the minor owners of Comanche Peak disagree in any way with Applicants' evaluations in (e), (f), and/or (g) preceding? If so, state with reasonable specificity the reason for such belief and provide a listing of all documents relating to such belief.
(1)
If, in any instance, Applicants currently question the competence, credibility, and/or testimony / depositions / affidavits of any of their witnesses or af fiants, specifically what have Applicants done about each such instance? Provide a listing of all documents relating to each such response by Applicants.
(j ) Please review your responses to (a) through (1) above. What is Applicants' current assessment of what your responses mean insofar as Applicants' ability to design, construct, and operate Comanche Peak?
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4-12.
(a) CASE has not received anything to Cygna from Applicants or from Cygna in some time. What has Cygna beea coing in the past 10 or 12 months or so? What is the current status of Cygna's review of Comanche Peak (including any time estimates of completion of reports, etc.)?
(b) Have there been any contacts between Cygna and Applicants for which communications reports or other summaries have not been prepared? Or have there been such reports with which CASE has not been supplied? If the answer to either of these questions is yes, please list all such communications both to Cygna from Applicants and to Applicants or others from Cygna.
(c) Provide a listing of all documents provided to Cygna by Applicants or others regarding Comanche Peak from the time Cygna first began its review of Comanche Peak, including the date on which Cygna received each document (similar to the computerized listing with which CASE was provided a year or so ago by Cygna, but updated).
4-13.
Has any independent organization reviewed the design of the buildings and all appertenances to the buildings? If so, what organization specifically has done so? What were the results of their review?
4-14.
Has the CPRT or any other organization of Applicants or their agents addressed items such as the following which were not specifically identified in the CPRT plan, by the NRC's TRT or Staff, or by external sources (including CASE)? (As one example of the type of thing we're talking about:
Has drainage plumbing been looked at closely? Are P-traps in place (which are above safety-related items which must work properly)?
Has cast iron plumbing been used above safety-related items?)
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r' - av 4-15.
Do you intend to call any witness (either in hearings, in evidentiary deposition, or as an affiant in a written filing) in any portion of the construction permit hearings?
If the answer is yes, supply the following information regarding each such witness:
(a.)
Name, address, and telephone number.
(b.)
Organization, company affiliation, title, and a brief job description.
(c.)
A summary of his/her professional and educational background.
(d.)
Any other information bearing on such individual's specific qualifications to testify with respect to the specific issues regarding which such testimony will be given.
(e.)
Is such individual testifying as an expert witness? If so, in what specific area (s) of expertise?
(f.)
The nature of the witness's testimony and a brief summary of such testimony.
(g.)
List or identify with specificity any and all documents on which such individual intends to rely, or relies, in giving his/her testimony.
(h.)
State whether or not such individual or an organization with which such individual is affiliated has conducted any research or made any studies, calculations, reports, or other documents on which such individual intends to rely, or relles.
(1.)
If the answer to h. above is yes, state briefly the scope and nature of such research or study.
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4-15 (continued):
(J. )
If the answer to h. above is yes, provide details as to who (name, title, organization) requested such research or study.
(k.)
State whether or not such individual or an organization with whi.
uch individual is affiliated has conducted any research or made any studies, calculations, reports, or other documents on which such individual does not intend to rely but which may be relevant to the matters at issue in the construction permit proceedings.
(1.)
Provide for inspection and copying any and all documents 4
referenced in your responses to (a) through (k) above.
(m.)
Provide copies of each witness's testimony at least 14 days prior to hearings / evidentiary deposition (or whatever other time period the i
Board shall order).
(n.)
Provide for inspection and copying at least 14 days prior to hearings / evidentiary deposition (or whatever other time period the Board i
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shall order) any and all documents on which the witness relied in such j
testimony.
Request for Documents Joint Intervenors request that Applicants produce the original or I
copies of all documents in Applicants' (or their agents) custody, possession, or control that refer or relate in any way to documents i
identified in or used for answering the interrogatories in this entire Set of Interrogatories and Request for Documents as set forth in the preceding.
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1 If a document has already been supplied by Applicants to CASE in another proceeding, Applicants can identify with particularity the location of the document or answer by including the name of the document, page and l
line number, in which docket the document was produced, and the date it was l
produced. This does not apply if the answer previously provided was an objection or if the interrogatory has not yet been answered. In that case, Applicants must reassert the objection as applicable to this proceeding or a
answer the interrogatory.
Respectfully submitted, l
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_A gQK'rs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 Co-Counsel for CASE l
Dated: June 18, 1986 1
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1 p f.9 p sg\\Y V surgQ(y UNITED STATES OF AMERI 3 gg@
NUCLEAR REGULATORY COMMI BEFORE THE ATOMIC SAFETY AND LICEN BOARD
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i In the Matter of
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Docket No. 50-445-CPA TEXAS UTILITIES ELECTRIC
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COMPANY, et al.
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(Application for (Comanche Peak Steam Electric
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a Construction Permit)
Station, Units 1 and 2)
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CERTIFICATE OF SERVICE 2
By my signature below, I hereby certify that true and correct copies of i
JOINT INTERVENORS' 4TH SET OF INTERR0GATORIES AND. REQUEST FOR DOCUMENTS i
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have been sent to the names listed below this 18th day of June
,198 6,
by: /MIEMMHX where indicated by
- and First Class Mail elsewhere.
j Federal Express i
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Administrative Judge Peter B. Bloch Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cooh, Purcell Atomic Safety & Licensing Board
& Reynolds l
Washington, D. C.
20555 1200 - 17th St., N. V.
Washington, D.C.
20036 Judge Elizabeth B. Johnson j
Oak Ridge National Laboratory
- Geary S. Mizuno, Esq.
P. O. Box X, Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 Director U. S. Nuclear Regulatory i
Dr. Kenneth A. McCollon Commission j
1107 West Knapp Street Maryland National Bank Bldg.
Stillwater, Oklahoma 74075
- Room 10105 i
7735 Old Georgetown Road i
Dr. Walter H. Jordan Bethesda, Maryland 20814 881 W. Outer Drive Oak Ridge, Tennessee 37830 Chairman, Atomic Safety and Licensing Board Panel
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U. S. Nuclear Regulatory Commission Washington, D. C.
20555 J
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~. - - -. -...... _ - -. _ - - - _.,. _,,.. -_. _.. _. _ _ _-
Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roisman, Esq.
Regional Administrator, Region IV Trial Lawyers for Public Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C.
20036 j
Arlington, Texas 76011 Mr. Herman Alderman Lanny A. Sinkin Staff Engineer Christic Institute Advisory Committee for Reactor j
1324 North Capitol Street Safeguards (MS H-1016) i Washington, D. C.
20002 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. David H. Boltz 2012 S. Polk f
Dallas, Texas 75224 Robert A. Wooldridge, Esq.
Worsham, Forsythe, Sampels William Counsil, Vice President
& Wooldridge i
Texas Utilities Generating Company 2001 Bryan Tower, Suite 3200 j
Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201
- Thomas G. Dignan, Jr., Esq.
Ropes & Gray Docketing and Service Section 225 Franklin Street 1
(3 copies)
Boston, Massachusetts 02110 Office of the Secretary U..S. Nuclear Regulatory Commission Ms. Nancy H. Williams Washington, D. C.
20555 Project Manager Cygna Energy Services Ms. Billie P. Garde 101 California Street, Suite 1000 Government Accountability Project San Francisco, California 1555 Connecticut Avenue, N.W.,
94111-5894 i
Suite 202 Washington, D. C.
20009 Mark D. Nozette, Counselor at Law Roy P. Lessy, Jr.
Heron, Burchette, Ruckert & Rothwell Morgan, Lewis & Bocklus 1025 Thomas Jefferson Street, N. W.,
1800 M Street, N. W.
Suite 700 Suite 700, North Tower Washington, D. C.
20007 Washington, D. C.
20036 21 & 3 h/h )
's.) Juanita Ellis, President ASE (Citizens Association for Sound Energy) 1426 S. Polk I
-Dallas, Texas 75224 214/946-9446 2
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