ML20206P936

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Interrogatories & Request for Production of Documents within 30 Days of Receipt of Request.Related Correspondence
ML20206P936
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 05/15/1986
From: Roisman A
GREGORY, M., TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20206P929 List:
References
CPA, NUDOCS 8607020300
Download: ML20206P936 (5)
v • d • e


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T14Y 15 '86 15:55 BLCP-P 202-857-9900 PME . 07 SEFORE THE i UNITED STATES j NUCLEAR REGULATORY COMMISSION l 1

l Before the Atomic Safety and Licensing Board 1 In the Matter of )

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TEXAS UTILITIES GENERATING COMPANY, ) Dkt. Nos. 50-445-CPA et al. )

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(Comanche Peak Steam Electric )

Station, Units 1 and 2 )

INTERROGATORIES AND REQUEST FOR DOCUMENTS Pursuant to the Rules of Practice, Meddie Gregory requests responses to the questions below and production of the sought after documents.

We expect responses to these interrogatories and/or requests for document production not later than 30 days after receipt of this request.

l Instructions 1

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 & Root, Gibbs & Hill, Ebasco, Cygna,

Stone and Webs ter, Evaluation Research Corporation, TERA, any 1

consultants, subcontractors, and anyone else performing work or services on behalf of the Applicants or their agentna or subcontractors.

i 8607020300 860630 1 PDR ADOCK 05000445 G PDR

MAY 15 '86 15:55 BLCP-R 202-857-3500 PAGE.03 l

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 document constitutes an admission of its authenticity or, pursuant to 32.742(b), the basis for refusing 1

to so admit.

l 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.

l l 6. These interrogatories and requests for documents shall be continuing in nature, pursuant to 10 CPR $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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i MAY 19 '36 15:55 BLCP-R 202-557-3800 P 43 E . 0 9 1

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Interrogatories i

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1. Identify all documents upon which Applicants intend to ,

i rely to demonstrate that there was a " good cause" for the delay ,

in completion of construction of Unit 1.

2. Identify all documents and all other information which provided the basis for the statement by Applicants in their l Current Management Views and case Management Proposal (June 29, 1985), at 7, that the plant was not licensable at that time.
3. Identify all audits, reviews, diagnoses, evaluations, j consultant reports, in-house audits, or other reports which Applicants received from the beginning of construction to the present assessing, analyzing, commenting on, discussing, or i offering an opinion on the plant's construction, procedures, compliance with industry or agency standards, or management style or competence. (This should include all source documents listed in Appendix a to CASE's Request for Imposition of Fine, suspension of Construction Activities, and Hearing on Application to Renew Construction Permit, 1/31/86.)

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4. When did App 1icants first receive notice of the issues identified by the NRC's TRT reports and SSERs, and in what form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.).
5. For each item identified in Interrog. 4, identify what response was taken to the problem and by whom.
6. If the answer to Interrog. 5 is that no action was taken, explain the reason that no action was taken. If that reason is because Applicants relied on a "second opinion,"

s ._ - .-- . - - , . - - ~ . ..--m, - _ , _ _ , . _ . . - , - - _ _ . . - _ . - , . . - - - _ , - . - , . - _ _ . - . - _ _ . . - - - . . - _ , - - - - . - . . - - . . - -

f1 A Y 19 *66 15:56 BLCP-P 202-957-3300 PAGE.10

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identify the individuals or organizations who provided that judgment.

7. Identify how each " finding" identified in Interrog. 4 was integrated into consideration of the subsequent findings by others. (For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC)?)
8. state your position on the following, including all evidence and reasoning upon which you rely with respect to each positions
a. What delayed completion of construction of Unit 1 past August 1, 19857
b. Why did that delay occur?
c. Who was responsible for that delay? .
d. Do you believe you had a valid business purpose for the delay and, if so, what was it?
e. Identify each, person who participated in the decision-making process that led to the delay and describe in detail their role.

l Request for Documents CASE requests that Applicant produce the original or copies of all documents in TUEC's custody, possession, or control that refer or relate in any way to documents identified in or used for answering Interrogatories 1 through 7 above.

If a document has already been supplied by TUEC to CASE in l

l another procoeeding, TUEC can identify with particularity the location of the document or answer by including the name of the

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nm( tc *56 15:56 BLOP-F 202-557-5500 p .:. 3 E , t ;

document, page and line number, in which docket the document was produced, and the date it was produced. This does not apply if the answer'previously provided was an objection. In that case, TUEC must reassert the objection as applicable to this proceeding. .

Respectfully submitted,

b. WW ANTHONY.4. ROISMAN "

BIILIE P. GARDE Trial Lawyers for Public Justice 2000 P Street, NW, 9611 Washington, D.C. 20036 (202) 463-8600 Counsel for Meddie Gregory Dated: May 15, 1986

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6/9/86 UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LI YNSING BOARD In the Matter of }{

}{ Docket No. 50-445-CPA TEXAS UTILITIES ELECTRIC }{

COMPANY, et al. }{ (Application for a (Comanche Peak Steam Electric }{ Construction Permit)

Station, Units 1 and 2) }{

JOINI INTERVENORS' 2ND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS Pursuant to the Rules of Practice, Joint Intervanors CASE (Citizens Association for Sound Energy) and Meddie Gregory request responses to the questions below and production of the sought-after documents /1/.

We expect responses to these interrogatories and/or requests for document production not later than 30 days after receipt of this request.

, Instructions I

j 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 &

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l /1/ In Intervenors' 5/15/86 Proposed Discovery Plan (page 3), to which our initial set of Interrogatories and Request for Documents was attached, Joint Intervenors voluntarily committed to filing a second set of interrogatories and request for documents by June 2, 1986. However, we were unable to complete our filing by that time and on 6/2/86 left word for the Board Chairman (who was not available) that we would like to l file our second set on or before 6/9/86 and requested that he advise if j this was not satisfactory. We were unable to contact counsel for i Applicants or NRC Staff on 6/2/86, but on 6/3/86 both indicated that they had no objectJ.onsa

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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, i

calculations, analyses, and any other data compilations from which information can be obtained.

4. As to each document provided, Applicants shall consider that i i providing the document 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 l

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 ites is excerpted from a document, 1/.entify it also by the name of the document.

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Interrogatories 2-1. Identify all listings, reviews, diagnoses, evaluations, consultant reports, in-house audits, handwritten notes, or other documents which list, itemize, and/or summarize what have come to be commonly known as the Walsh/Doyle Allegations. Also identify the document which Applicants consider to be the document which identifies all of the Walsh/Doyle allegations and the document which best summarizes them (if these are not the same document, please no state and identify both specifically).

i 2-2. What was the source of each item listed in response to question 2-1 above, and who was the author of each (give name, title, company organization, and date at the time each was authored or revised)?

i 2-3. For each ites listed in your response to question 2-1, to what organization and/or individuals (identify name, title, organization) involved in the reinspection effort was each item given? Include specifically in your answer: (a) whether or not each was given to Stone &

Webster, Gibbs & Hill, TERA /TENERA,. ERC, and/or other organizations working within or with the CPRT; and (b) what was the extent of the information with which each organization or individual was provided (were they given only the summary document itself; were they given the underlying transcripts of hearings, documents, pleadings, Board Orders; etc.; if they were given more than just the summary document itself, what other documents were they given).

2-4. How was the scope of each organization's and/or individual's review determined, and who (name, ritle, organization) made the determination in each case?

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2-5. When did Applicants first receive notice of each of the issues covered by the Walsh/Doyle allegations? In what format was such notification made (a specific document, verbal communication between specific individuals, etc.); identify specifically for each Walsh/Doyle issue.

2-6. What generic problems have been identified regarding pipe -

supports during the period of the Stone & Webster reinspection (by Stone &

Webster or by others) which Applicants consider might be associated with the Walsh/Doyle, allegations?

2-7. What other generic problems regarding pipe supports have been identified during the period of the Stone & Webster reinspection (by Stone &

Webster or others) which Applicants consider to be unassociated with the Walsh/Doyle allegations?

2-8. In view of Applicants' current position, what issues contained in the Walsh/Doyle testimony or allegations would now be considered by

! Applicants to be (or to have been) reportable potentially reportable under 50.55(e)? Of those items listed in your response, which of them did Applicants consider to be actually reportable under 50.55(e) and (if different) which of them did Applicants actually report under 50.55(e).

2-9. Have any new procedures been introduced for consideration in the analysis of integral attachments to pipe runs (as used in anchors, for example)? Provide complete and specific details.

2-10. Have any of the reanlyses of pipe runs introduced support loads which, although less than the previous loads, still would require redesign of the supports? Why? Provide complete and specific details.

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2-11. What, if any, new methodology and/or procedures are being used by Stone & Webster for the Richmond anchor / tube assembly analysis that were not used originally? Has there been an introduction of new bolt material for any of th( Richmond threaded rods (or is all of the material still A307 or A36 steel)? What is the justification for this? Provide complete and specific details.

2-12. What, if any, generic type (s) of supports have Applicants requested be redesigned without further attempts at qualification (for example, have Applicants told Stone & Webster on cinched-up U-bolts, replace them all; or on unstable box frames, replace them all; i.e., don't try to go through and analyze them or anything, just replace them)? In each such instance, what was the reason or justification for this? Provide complete and specific details.

2-13. Please refer to the attached 5/19/86 DALLAS MORNING NEWS article and answer the following questions:

(a) Is it correct that in the first 3-1/2 months of 1986, Applicants reported 31 potentially serious safety problems, compared with 54 reported for all of 19857 If this statement is incorrect, please correct l and clarify it. Were these all potentially reportable items under 10 CFR I

l 50.55(e)? If not, please explain.

(b) Is it correct that Applicants flied 5,207 nonconformance reports (NCR's) in the first three months of 1986, compared to a total of 7,669 for the entire twelve month period of 19857 If this is not correct, please correct and clarify it. Please explain the reason for the relatively large number of NCR's so far in 1986.

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(c) Please estimate the percentage of NCR's filed during 1985 and during 1986 which resulted from problems identified by the CPRT and/or Stone

& Webster reinspection efforts, as opposed to the percentage which resulted from efforts by others.

(d) (1) What is the number of pipe supports on which NCR's were i

written in 1985? In 19867

(11) If this information is not available in this form, how many NCR.'s were written on pipe supports in 19857 in 19867 (iii) How many of such NCR's were written due to potential or actual problems in design?

(e) (1) What is the number of pipe supports 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?

(ii) If this information is not available in this form, how many potential 50.55(e) reports were written on pipe supports in 1985? in 19867 What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable?

(iii) How many of such 50.55(e) reports were written due to potential or actual problems in design of pipe supports? Identify the specific report numbers and provide a general description of the problem.

(iv) Which of the 50.55(e) reports in (iii) above were I

determined to actually be reportable?

2-14. What is the percentage complete of Unit 1 of Comanche Peak?

What is the percentage complete of Unit 2? Please explain exactly what you mean by the percentage complete.

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2-15. How many individuals (including workers, inspectors, consultants, etc.) are currently working onsite at Comanche Peak? How many individuals (including workers, inspectors, consultants, etc.) are currently working offsite (such at at Gibbs & Hill's offices in New York, etc.) on Comanche Peak?

2-16. What is the total estimated cost per day for Comanche Peak at this time (including labor, interest on money borrowed, insurance, etc.)?

2-17. How many large bore (4" and over) pipe supports are in Unit 1 of Comanche Peak? Of this total, how many are (a) Class 1, (b) Class 2, (c)  !

Class 3, (d) Class 57 2-18. How many small bore (under 4") pipe supports are in Unit 1 of Comanche Peak? Of this total, how many are (a) Class 1, (b) Class 2, (c)

Class 3, (d) Class 57 2-19. How many large bore (4" and over) pipe supports are in Unit 2 of Comanche Peak? Of this total, how many are (a) Class 1, (b) Class 2, (c)

Class 3, (d) Class 57 2-20. How many small bore (under 4") pipe supports are in Unit 2 of Comanche Peak? Of this total, how many are (a) Class 1, (b) Class 2, (c)

Class 3, (d) Class 5?

2-21. The attached 5/19/86 DMN article states that:

"The latest estimate released by the utility (of pipe supports in Unit I which would have to be removed or modified at Comanche Peak] indicates 3,700 supports -- more than 40 percent -- will be affected. Utility officials said 1,000 supports need minor work, 1,700 pipe supports must be re-designed and modified, and another 1,000 supports must be torn down."

Are these statements correct? If not, please correct and clarify the ,

statements. What quantity and what percentage are in Unit 1, and what 7

quantity and what percentage are in Unit 2? What is the breakdown of the 4,700 (or whatever the correct number 1s) pipe supports as to class (for example, Class 1: so many minor, so many redesigned, and so many rip out; Class 2, the same; Class 3, the same; Class 5, the same). In your response, also identify which are large bore and which are small bore.

2-22. Is Stone & Webster performing a 100% reinspection of all large bore pipe supports? Of all small bore pipe supports? Please provide complete details.

2-23. ,In Stone & Webster's reinspection and/or reanalyses, have they discovered any generic or potentially generic problees in addition to those covered by the Walsh/Doyle allegations? If so, provide specific and complete details.

2~24.

In Stone & Webster's reinspection and/or reanalyses, have they discovered information and/or documentation which confirms any of the Walsh/Doyle allegations? If so, provide specific and complete details.

2-25. Is Stone & Webster specifically addressing each of the Walsh/Doyle allegations? If not, what is the justification for not doing so? If so, specifically how is Stone & Webster addressing each of the Walsh/Doyle allegations? Exactly what is Stone & Webster's mandate: Does it include addressing only the Walsh/Doyle allegations specifically? Are they supposed to just tear out whatever is questionable and put up what is already known and acceptable in the industry, but without ever addressing specifically whether or not the Walsh/Doyle allegations were correct or the root causes and generic implications of same? Please provide specific details.

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4 2-26. .Have Applicants or any of their consultants come across anything that is going to necessitate a change in their FSAR cosmicaents? Have Applicants deviated, or requested or received permission to deviate, from current industry codes and NRC regulations. If so, specifically in what way (what have they asked for, do they know of any that they're going to have to ask for)? Provide specific details.

2-27. Please provide a brief history of what Applicants' conclusions were as to the adequacy of the pipe supports at Comanche Peak and the validity of,the Walsh/Doyle allegations. Specifically include in your answer:

(a) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Mark Walsh as of August 1982 (following the testimony of CASE Witness Mark Walsh in July 1982)?-

(b) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the Walsh/Doyle allegations as of October 1982 (following the deposition / testimony of CASE Witness Jack l Doyle in September 1982)?

l (c) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the Walsh/Doyle allegations as of June 1983 (following hearings in May 1983)? '

(c) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the Walsh/Doyle allegations as of September 1983 (following the filing of Proposed Findings of Fact by the parties)?

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2-27 (continued):

(d) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle after receipt of the Licensing Board's 12/28/83 Memorandum and Order (Quality Assurance for Design)?

(e) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle after receipt of the Licensing Board's 2/8/84 Memorandum and Order (Reconsideration Concerning Quality Assurance for. Design)?

(f) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle following the April 1984 hearings on pipe support issues?

(g) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle following receipt of CASE's responses to Applicants' Motions for Summary Disposition which were flied in mid-19847 (h) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of 1

l Walsh/Doyle following receipt of Cygna's 2/19/85 letter in which it changed its position on stability of pipe supports?

(i) What are Applicants' current conclusions as to the adequacy of Comanche Peak pipe supports and the validity _of_the_ allegations of Walsh/Doyle (not the conclusions which Applicants expect to arrive at in the future, but your current conclusions)?

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f 2-27 (continued):

(j ) Have Applicants finally realized that they have problems witu the adequacy of the pipe supports at Comanche Peak? If so, when and how did Applicants finally realize they actually did have such problems?

(k) Who (name, title, organization) made the determinations discussed in your responses to (a) through (j) preceding?

2-28. What methodology and procedures are being used by Stone &

Webster for analysis of multiple struts and snubbers at pipe support points?

Provide specific details.

2-29. What methodology and procedures are being employed by Stone &

Webster to address variations of actual vs. generic stiffness for pipe supports? Provide specific detalIs.

2-30. Is there any portion of the NRC Staff's SIT Report with which Applicants had previously agreed but no longer believe is accurate or correct? If so, please identify each such portion and give specific details.

2-31. How many individuals with Stone & Webster are working on the pipe support effort
(a) in total; (b) onsite; (c) offsite?

2-32. (a) How many individuals who are currently or were employed by Stone & Webster during the period August 1985_through June 1986 were former employees of NPS Industries, ITT Grinnell, Texas Utilities Electric Company or one of its affiliated companies, Gibbs & Rill, or any other of Applicants or their agents, and worked at any time previously on the Comanche Peak project (either onsite or offsite)?

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2-32 (continued):

(b) Provide a listing of all such individuals, along with details l

regarding the dates they originally worked for the companies in question, the dates they were hired by Stone & Webster for their assignment to the reinspection / reanalysis effort at Comanche Peak, their current j ob title and status, and if they are no longer employed at Comanche Peak, their last known address and telephone number.

2-33. (a) What engineering changes have Applicants made to assure i

that the same individuals who were responsible for design errors are not still at Comanche Peak and are not still making design errors? Give complete and specific details.

(b) How many engineering management personnel who were working in t

any engineering management positions during 1982 through 1985 have been replaced and no longer work at Comanche Peak in any capacity? Provide the names of all such engineering management personnel, and their last known address and telephone number.

(c) How many engineering personnel who were employed at Comanche Peak during 1982 through 1985 have been switched from one engineering position to another (such as from working on pipe supports to working on cable tray supports)? Provide complete and specific details, including each individual's name, past job position and duties, and present job position and duties.

(d) Provide the name of each of the individuals identified in your response to (c) above who have been, or are currently, working on the reinspection effort; also state (if not already stated in (c) above) the specific nature of each individual's duries regarding the reinspection.

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2-34. (a) Which organization and/or individuals in the reinspection effort are addressing Walsh/Doyle allegations other than pipe supports (such as the design of the upper lateral support)?

I (b) What have been the results of their efforts to date?

Provide complete and specific details.

2-35. Provide answers to each interrogatory and document request contained in the following pleadings in the Comanche Peak operating license proceedings (Docket 50-445 and 50-446): CASE's 1/17/85 First Set of Interrogatories Re: Credibility; CASE's 2/4/85 Second Set of Interrogatories -

Re: Credibility; CASE's 2/25/85 Third Set of Interrogatories Re:

1 Credibility; CASE's 2/25/85 Fourth Set of Interrogatories Re: Credibility; and CASE's 3/4/85 Fifth Set of Interrogatories Re: Credibility. (See clarifying statement under Request for Documents which follows.)

2-36. How and by whom was the decision made to utilize the Motions for Summary Disposition which were filed by Applicants in mid-19847 Was this an engineering decision, a management decision, or what? Specifically how, when, and by whom was the decision made to withdraw the Motions for Summary

] Disposition? Was this an engineering decision, a management decision, or i

what? Was there any discussion (verbally, taped, or in writing) regarding

[ whether or not it was cheaper to litigate the problems than it would be to l

l go out there and actually redesign and reconstruct the problem areas of the plant? Were there any time estimates, schedules, etc.? Provide complete i

and specific details.

2-37. Have Applicants changed their FSAR commitments regarding pipe support design during the time 1983 through the current time? Have Applicants, during the time 1983 through the current time, deviated, or 13

requested or received persmission to deviate, from then-current industry codes and then-current NRC regulations? If so, specifically in what way (what did they request, what were they given permission to do, etc.).

Provide specific details.

2-38. When did Applicants first receive notice that there were

, problems with the design of the cable tray supports at Comanche Peak? In what format was such notification made (a specific document, verbal communication between specific individuals, etc.)? Was such notification received prior to the testimony of, and cross-examination by, CASE Witness Mark Walsh in the May 1984 operating license hearings? Provide complete and 4

specific details.

2-39. What generic problems have been identified regarding cable tray supports between May 1984 and the current time which Applicants consider could have first been pointed out by CASE Witness Mark Walsh?

2-40. What generic problems have been identified regarding cable tray l supports between May 1984 and the current time which Applicants consider to be unassociated with problems pointed out by CASE Witness Mark Walsh?

2-41. In view of Applicants' current position, what issues contained In the May 1984 testimony of, or cross-examination by, CASE Witness Mark Walsh would now be considered by Applicants to be (or to have been) reportable or potentially reportable under 10 CFR 50.55(e)? Of those items I

listed in your response, which of them did Applicants consider to be actually reportable under 50.55(e) and (if different) which of them did Applicants actually report under 50.55(e)?

2-42. Please refer to the attached 5/19/86 DALLAS MORNING NEWS article and answer the following questions:

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2-42 (continued):

(a) Is it correct that all cable tray supports in Unit 1 are being examined for design problems? What is the status of cable tray supports in Unit 2; are they all being examined for design problems? If the answer to either is no, please explain and clarify. If the answer to either is yes, what have been the results of such examination?

(b) How many cable tray supports are there in Unit 17 How many in Unit 27 Are all of them considered to be safety-related; if not, how many are considered to be safety-related, and how many are considered to be in some other category (please specify)?

(c) How many of the cable tray supports have been checked against design drawings to date? How many have received a preliminary design review? Are final reports complete on any to date? Give complete and specific details.

I (d) Please state whether or not the following statements in the attached DMN article is correct:

" Utility officials have said the supports, instead of being individually designed, were built according to ' cookbook' designs borrowed from technical manuals that underestimated stress on the supports. Because many cables already have been installed, the utility may face the complicated task of rebuilding or tearing out supports without damaging the cables."

If the statements are not correct, please discuss and elaborate on how they are incorrect and give correct complete and specific details.

(e) Is it correct that all conduit supports in Unit 1 are being examined for design problems? What is the status of conduit supports in Unit 2; are they all being examined for design problems? If the answer to either is no, please explain and clarify. If the answer to either is yes, what have been the results of such examination?

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(f) How many conduit supports are there in Unit 17 How many in Unit 27 Are all of them considered to be safety-related; if not, how many are considered to be safety-related, and how many are considered to be in some other category (please specify)?

(g) How many of the conduit supports have been checked against design drawings to date? How many have received a preliminary design review? Are final reports complete on any to date? Give complete and specific details.

(h) Please state whether or not the following statement in the attached DMN article is correct and applies also to conduit supports:

" Utility officials have said the supports, instead of being individually designed, were built according to ' cookbook' designs borrowed from technical manuals that underestimated stress on the supports."

If the statement is not correct, please discuss and elaborate on how it is incorrect and give correct complete and specific details.

2-43. What, if any, generic type (s) of cable tray supports have Applicants requested or ordered be redesigned without further attempts at qualification? In each such instance, what was the reason or justification for this? Provide complete and specific details.

2-44. What, if any, generic type (s) of conduit supports have Applicants requested or ordered be redesigned without further attempts at 4

qualification? In each such instance, what was the reason or justification for this? Provide complete and specific details.

, 2-45. (a) What is the number of cable tray supports on which NCR's were written In 19857 in 19fl67 16

. , - , . - - - - . - , - , - - , - - - - - , - - , , --- - - - , . - - , . _ - - - . . - . - , y _

2-45 (continued):

(b) If this information is not available in this form, how many NCR's were written on cable tray supports in 19857 in 19867 (c) How many of such NCR's were written due to potential or actual problems in design?

2-46. (a) What is the number of conduit supports on which NCR's were written in 19857 in 19867 (b) If this information is not available in this form, how many NCR's were-written on conduit supports in 19857 in 19867 (c) How many of such NCR's were written due to potential or actual problems in design?

2-47. (a) What is the number of cable tray supports which had potential 10 CFR 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 j potential 50.55(e) reports were written on cable tray supports in 19857 in i

19867 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 cable tray supports? Identify the specificSeportnumbersandprovideageneraldescriptionoftheproblem.

(d) Which of the 50.55(e) reports in (c) above were determined to actually be reportable?

i 17 l

l

2-48. (a) What is the number of conduit supports which had potential 10 CFR 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 on conduit supports in 1985? In 19867 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 conduit supports? Identify the specific report numbers and provide a general description of the problem.

(d) Which of the 50.55(e) reports in (c) above were determined to actually be reportable?

2-49. Answer question 2-26 with regard to cable tray supports (if you had originally answered it only with regard to pipe supports).

2-50. When did Applicants first receive notice that there were problems with the design of the supports for heating, ventilation, and air conditioning (HVAC) at Comanche Peak? In what format was such notification made (a specific document, verbal communication between specific individuals, etc.)? Provide complete and specific details.

2-51. What generic problems have been identified regarding HVAC supports (either design or construction) between May 1984 and the current time.

2-52. Please refer to the attached 5/19/86 DALLAS MORNING NEWS article and answer the following questions:

18

. ~ _ _ _ - - . -

2-52 (continued):

(a) Is it correct that supports for HVAC "also face design problems, but that analysis and hardward inspection still is preliminary"?

What is the status of HVAC supports in Unit 1 and in Unit 2; are they all being examined for design problems? If the answer to either is no, please explain and clarify. If the answer to either is yes, what have been the results to date of such examination?

(b) How many HVAC supports are there in Unit 17 How many in Unit 27 Are all of them considered to be safety-related; if not, how many are considered ,to be safety-related, and how many are considered to be in some other category (please specify)?

(c) How many of the HVAC supports have been checked against design drawings to date? How many have received a preliminary design review? Are final reports complete on any to date? Give complete and I

specific details.

2-53. Please state whether or not the following statement in the

]

attached DMN article is correct and applies also to HVAC supports:

" Utility officials have said the supports, instead of being individually designed, were built according to ' cookbook' designs

, borrowed from technical manuals that underestimated stress on the supports."

If the statement is not correct, please discuss and elaborate on how it is incorrect and give correct complete and specific details.

2-54 Answer question 2-26 with regard to conduit supports (if fou had i

originally answered it only with regard to pipe supports).

2-55. When did Applicants first receive notice that there were problems with the design of the control room ceiling at Comanche Peak? In what format was such notification made (a specific document, verbal l

19 l

L _ _ . _ _ _ _ . _ _ _ _ - _ _ . . - . _ _ . _ _ - -

communication between specific individuals, etc.)? Do Applicants now 4

I consider that the allegation regarding the design of the control room ceiling had merit? Provide complete and specific details.

2-56. What generic problems have been identified regarding the design ,

of the control room ceiling between May 1984 and the current time.

2-57. What is the status of the redesign and reconstruction of the control room ceiling? Are final reports complete to date? Give complete and specific details.

2-58. , Answer question 2-26 with regard to the design of the control room ceiling (if you had originally answered it only with regard to pipe supports).

2-59. Are the statements in the attached DMN article correct:

, "Overall, reinspection of existing construction is about 60 i percent complete. But because procedures to check the design adequacy of the plant were not completed until January, inspection j of design work is only 20 percent to 25 percent complete, utility officials said."

! If they are not correct, specify in what regard they are incorrect, and l-j correct and clarify them. If they are totally or partially correct, what

'l justification exists for proceeding with reinspection of construction prior to reinspection of design of each item? And what met..odology, procedures, and checklists have been developed and are in use to assure that construction which has already been reinspected will be reinspected should i

it be necessary because of redesign?

i 2-60. In the right-hand column of the attached DMN article, there is a i

discussion regarding supervisors imposing unrealistic production quotas, etc. Provide the names, titles, and organizations of the individuals 1

i 4 20

I 1

l involved, state whether or not each is still employed (and in what capacity) at Comanche Peak. Wh'at efforts have been made to assure that the work performed under the conditions in question have been reinspected and/or redesigned? Have there been any other similar incidents of harassment, intimidation, or imposition of unrealistic production quotas identified, either in the reinspection effort or as part of the Applicants' in-house efforts? Provide complete and specific details.

Request for Documents Joint Intervenors request that Applicants produce the original or copies of all documents in Applicants' (or their agents) custody, possession, or control that refer or relate in any way to documents identified in or used for answering the interrogatories in this entire 2nd I

Set as set forth in the preceding. And, more specifically:

(1) In regard to the preceding questions relating to items reportable or potentially reportable under 10 CFR 50.55(e), please be sure to provide all documents that refer or relate in any way to your response, including but not limited to all logs of 50.55(e) items, notes of initial verbal notifications to NRC Region IV, initial written notifications to NRC Region IV, all follow-up notifications to NRC Region IV, all documents relating to the 50.55(e) item (including, if Applicants decided the item was not in fact reportable, all documents relating to and/or supporting that decision).

(2) Provide copies of all NCR logs which CASE has not already received. Provide for inspection and copying all NCR's written since the beginning of the CPRT effort and Stone & Webster effort. (Please check with 21 l

m

-- -e -- -

4 - --- -

CASE's Mrs. Ellis for further details regarding which logs and NCR's we have already received; we will work with you on this.)

If a document has already been supplied by Applicants to CASE in anothar proceeding, Applicants can identify with particularity the location of the documert or answer by including the name of the document, page and line number, in which docket the document was produced, and the date it was 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 answer the interrogatory.

Respectfully submitted, f Aff, *. >

gfMrs.) Juanita Ellis, Presid~ent CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 Co-Counsel for CASE Dated: June 9, 1986 l

l 22

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q o4 U,;llljjj;hpj remspection p an ;p= -._.

Le g 34 ==

Caettamod trem page 134. == tam far design proWena Tm La Angust He la date, half the apports have been "h'"*"9" E

r.

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oE g,n 3 m s now pausas e =ppia anian ~=.4 budget request es estead the effort Only 800 have recalved a preum4-acatam d=:ga enetags est ~threest as and et the aary desism revtew, and naan t* Iovel taspectors to observe correc.

n.a.a.aa v e --

b B >

  1. g year." ove wort et the past. Noonan ula ports an mot anuabia The tnys y,pi ,el management a:so met g11 2 j g I That Ladicat c E -

D x I a . .y caan b.gesathe - plant be prob.. .antata.contro*

.a ca .e - and.tastrament. with laspectors to stries the tapor.

s.- - a.co e, - ins._as S y l

O ge s .  : 3 test hasngsanwhus._catt been a per t comptees i et the plaatsaid for hem nonme of w the plaat of tasmed Dety ediciais ,ynets ly,

  • "'* Noonas said atthty accons ap M

j j j e more3han a year, and the second betag ladivideauy hgn=8 were S3 g

  • ^ poet to have been effective, and the u , g ;a. j resctar satt is $1 percent agne uo,maauna.-=.wpeemn completa.borrowa beitt fre= accordlag t.chnicai teqsauty
  • cookbook
  • d* taprov.

of the taspecuonais O 3 b w and ensaitano conname is vert manuals that maderestaand str* m.

a A major tacident occurred iam g *9 O r./3QIE!I gj g g y hj a*

g g

{

em ins.praiset hoth ee, and off4tta en the anyporta necease taterest om money borrowed by the cablas already have been tea.n.4 stiuty for the pro)sct. Lasurance the st1Hry may face the complicated man"y a,,t y ,,,ws ,

.,er,1,,,,i posed t3nansuc prodocuos quotas

,, and other costs are more thaa $1 task of rebWlag er teartag out os retaspectics tasms, forttog an-g ge , merous sistakas than tavaudated at 5., a: 2.ge la 3 p a1 Dies qs-a day.That does notinclude supports without damaging the least three months of work ca the tabu cosa, cabam

~

+a 1

= *e ,s 3a a> And asepports for banag. venni. ,panti cabie trey,=p.ctice pen.

2 b, a. pro,ruas,.cnoa scrs een probient is by se means non and ar<madrooming aim face

,e,_ ne pu,,, eat ode.

~

O y, , !aE3 1 -2 3 $ ,.4 2. g Thtlatest blow came earty this desga proNess, bat that analysts i. cia nece.= no e.dia - geauty.

Mw a e "

j g -2 ;g montt when the regalatory coe. and hardware inap-ma= still is contret mi.we es,,a as .nuty wtth pnuahwy-checks were ordered for the work After the regulatory commis

. $Pe 600 ta proposed finea nat to. man envued ne pMess.

-g O g* S Overen.retaspecnos of exisdag Tazas Unuuss maassement sa.

=

- a n a .

tansi,cled.ed for= se ~

81 e 1 000 nae isseed construenca is about 80 percent pended alt retsspecuon work for at ==amsa -pa= =si - pr-ed-

, ,autr<.a - - sa = chea me d-iga aa = = =e two weeuo.md the am,-

' .t;. a,,, @g- a!=esa;

- a

, coarna 2,a,-a.s,3 ,..d ,-t ware a-pond .amaa. - as,eco.ntros m toit od nads.g estety mm.s = e a-r. =p-== = de=sa w-= = ,e,taced bo se,e,vtso,a nat me . _tra,ted to .

a3 a ] af -y- piasadotulcanos came just only a potest a 25 perosat com'

! ., an. .e aety ha .gr w . days 550,000 nas agmast the sullty.

per pam.a=wna==a

'- l

@ W f" g jg in first nas for a maner esfasse La a

s na n,.t ave .f . esonat.d 52 *results reports

  • _ the final O , ~

, y _TH.Una's_amarg se. of _ the s SP.D.se.e _Wheth.er y . t.he.pl.aat . h reestvessekeyM* ( ^ a j Eyy ,!.

_ .e ts.

aggagt the pleet for mattspie faib tag a pb the atuttre ca. ca. .,,,,a, ,u_se _= a_e veMa.

.t Q 3 ,,,,,,,.

c,.

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Ojg f ls' E erus* of its construct!aa and teak Peak a-= Team dose en the t 'i uremurance prosroma ne nas reasp coons ne reponas i *= theMore tasa a year ta the asking. 7 a 3 -

was.lsened for repeated vtalaness mest faithfatty fouew its 82.posad*

nve nports ninsed la mid. "

M W3 d '5g l of:tegatreseem for design, coe. Nacb4 hick program plan to thele

  • Aprit have been questlosed by the -==

, S4 O 2 4 ) to g - sueensa and taspoenom of ancieer ser u the plant is ever se mart opere. chairman of the U1 Atomic Safety a pose piania and for significani ticam and ucenstes Board. the nant. -

as 2

g 3

  • g . ==aaa===* ta the plaars quaury "If the O'RT fprogram plaal to,, commiatoa ,taff and Co.,s.

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O ~w d 42 7 ., ~d a.

a 2 !~ij-.d3 8 c

. { ' prograag t, earn, that damagtag me.s i d ny. N=naasaia

to ogseongradtag of Texas Uttuties desset fly, them the plaat want the Peak opponents aute for not There la evidsace that me r*

bang m eoragb ss anucipmed ne untry pedged ie ens.w an.

5 a

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  • stock by the New York band.rsuag sponsa team altsedy has hit some meroes quesuous raised try Alonus ,

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3 q$

k . j j s ,, -

a";a

. hoa..f s:= dud b poor.Cor,  :-=== pn==s i= i=rie==aag Safety aanand p ucenstag Board chatt.

,;; pw c: J jh ,[f3 . g f. The project suffered another nu, se plan. Bioch.

Notaan streed that the reports l 3 back when the U1 Atoats Safety DisturWag flawe appeared la the ars

  • sparse
  • and that the taforma.

=

.- E and ticeastag Board granted Com att11ty's reinspecttaa program as tion they centata ara tte" bare min- =

anache Peak opponeem a heartag early as al4Asgust, accordtag to taus" that would be e ceptable to

onwhether Comanche Peat shculd tegulatory commisson inspecuon the Nuclear Regstatory Comam  ;

J" M. I be greated as artaaslot of tu coe. repara released la 2e past few stat He stso adattted that the com. *

  • sti'sinos permit. The selity and months

.= .

.( l 1 th8 tegulatory commissaan maff ap= Monthly taspecuco results for anatos staff was "not overty -

3 A pealed the decimos last week. happy" wuh some of the reporti al- _

X September. October sad November though supporung docar eatation h') -

. r And the Sortet reactor scendent - released peWy la December. contataed la voluminous illes 2 I W S7 at C34rnobyt. reewakeaang puhuc March and Ayrt!-ladicated caer maistalaed by the atttt:y la en- [>

concern about the safety of sec14ar sultaan had made aumeroes m* pacted to saasty mostquesuona power, provided a catalyst for Dab takas feinspecting construction But t'a===rha Peak opponent las County Commissoner Joha work and somedmee wortad from Bitus Garde. who represe'Its DeHas.

g g R-g Wileg Price se joie the plaars oppe. taatroceans that could be midater" based Cittaans Amoctation for

._d g aants la a can for a comp 6ete reta. pnted Sound Energy, said the accatapany- -i

'1 y

specttom of the Glen Ross factitty- laspectices myrenettag more tag files do not contata the cr.actal ,

somethtag Gat atIlfty etncials emed thaa UBS taspector heers of wort laformation needed te detaratae -

coslaldone the plaat ladicated that the esauty of the plant. -

.N9eawkue, the stility) consulp e 4 esau but troebung perces> "This to car first look at what the aan comuase as chara est evt. age of laspectica errors had been stthty has been dotag for the last at

=*

desce of problems at raman,h. comained bysetside consultanta year and a half, and tre pretty ap.

Peak. Noemas sned mapar*=s beraae paillag.* she said. "The docamestar

> ThededCsgnautyof theplatt- concerned la November when the noe la the central (Ues has just got .

O 4, '" nru channaged by fa==="u Pong etaber et festry taspecusas by bege Emptag holes la it. no paper -

MM y oppobeam la a1489tt - stin sp, enuty consultana began to exceed trait is not there.'

BiEM A ia ' p ruubeitsmestsevereprobten: as actoptable a percent error rete vuuty spokesman Deee pioretu  ?-

E' ]

g e la October, sul:ty cincials es. and ettabed se the 2 percoat to 3 said Ma Garde's assemaent "um casted 125 pipe supports of the percess range. charactertzad* the c'saditica of the

_.,l g 9.000 supports la Unit I weald have "We started getting concerned russia reporta to b4 restowed or endt!!ad at CD beceaseit was getung to be what we "We feelthry are slot more coa > q W h M manche Peak. The latest esumate call *ca the ragged edge.' and we plate than her comments would la-L retmased ity the attury indicates didat want it to go any farther,= dicate." Floretu said "We feel that 9 iS afte supports - more than to per. Noonan sa64 '"This prog-sa is the files do support the results re- -=

-j cent - elll be affected Ut111ty offl. gotag to be laag esosth, and we ports thoroughly sad in suiticient cials amid 1.000 supports need staar deal ased to nad that it's statung detalL* -

l_ work.1.70s pipe supports must be to get out of hand on as* Seid Ms Carde:'"the conclusions ,

redesigned and modified, and an.

M' After the rossistory commission by the retaspection progree are -*

otbec 1.000 sepports aan be tors nottftes sulity execsuves, steps based on the same klad of missing dows.

' M were taken to "retune* the reta. paper and atsstes supporting docu.

s Au U30 cab:e tray a.4 coa- apecues affort. he said aestauos that the plant itself is delt asppara la Umat I are betag es. Cao of the serpe reqstred higter* Desed on. -

J

________________m---- _ - - - - " - - - " - ' - --

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of }{

}{ Docket No. 50-445-CPA TEXAS UTILITIES ELECTRIC }{

COMPANY,e_t,g. t }{ (Application for (Comanche Peak Steam Electric }{ a Construction Permit) ~

Station, Units 1 and 2) }{

CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of JOINT INTERVENORS' 2ND SET OF INTERR0GATORIES AND REQUESTS FOR DOCUMENTS have been sent to the names listed below this 9th day of June ,198 6, by: Express Mail where indicated by

  • and First Class Mail elsewhere.

Administrative Judge Peter B. Bloch Nicholas S. Reynolds, Esq.

U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell Atomic Safety & Licensing Board & Reynolds Washington, D. C. 20555 ~

1200 - 17th St., N. W.

Washington, D.C. 20036 Judge Elizabeth B. Johnson 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 Dr. Kenneth A. McCollom Commission 1107 West Knapp Street Washington, D. C. 20555 Stillwater, Oklahoma 74075 Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 1

Chairman Renen Hicks, Esq.

Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building i

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 Arlington, Texas 76011 Mr. Herman Alderman Lanny A. Sinkin Staff Engineer Christic Institute Advisory Committee for Reactor 1324 North Capitol Street Safeguards (MS H-1016)

Washington, D. C. 20002 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Robert A. Woeldridge, Esq.

Worsham, Forsythe, Sampels William Counsil, Vice President & Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 3200 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., Esq.

Ropes & Gray Docksting and Service Section 225 Franklin Street (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 Prancisco, California '

1555 Connecticut Avenue, N.W., 94111-5894 Suite 202 Washington, D. C. 20009 Mark D. N6 ette, Counselor at Law Roy P. Lessy, Jr. Heron, Burchette, Ruckert & Rothwell Morgan, Lewis & Bockius 1025 Thomas Jsfierson Street, N. W.,

1800 M Street, N. W. Suite 700 Suite 700, North Tower Wsshington, D. C. 20007 Washington, D. C. 20036 ,

M si X s YA L s s.') Juanita Ellis, President

' CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 I 214/946-9446 j 2

1

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