ML20212D138
| ML20212D138 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/24/1987 |
| From: | Selleck K ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#187-2624 OL, NUDOCS 8703040070 | |
| Download: ML20212D138 (45) | |
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RELATED CORRESPONDENOG t
Filed: February 24:frA9_87
-p UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION F03 27 P2 :33 before the 6N .
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ATOMIC SAFETY AND LICENSING BOARD -
) [
In the Matter of ) Docket Nos. 50-445-OL
) 50-446-OL TEXAS UTILITIES GENERATING ) f COMPANY et al. )
) (Application for an (Comanche Peak Steam Electric ) Operating License)
Station, Units 1 and 2) )
)
) :
APPLICANTS' INTERROGATORIES TO INTERVENOR (Sct No. 1987-5)
Pursuant to 10 C.F.R. 5 2.740 ff the Applicants hereby propound the following interrogatories to Intervenor CASE.
Definitions As used in these Interrogatories, the following terms have the following meanings:
" Litigate" with regard to a topic or contention means to offer direct testimony relating to, to cross-examine on, to offer proposed findings or rulings regarding, or to urge the denial (or allowance subject to conditions) of the pending application on the basis of, the topic or contention in question.
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. " Identify" with respect to an expert witness means to state:
(a) The name, mailing address, age and present professional or employment affiliation of the person; (b) The profession or occupation and field of claimed i
expertise of the person; (c) The history of formal education or training of the person, including, but not limited to, (i) the name and address of each school where the person received special education or training, (ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d) The history of specialized training in the area of claimed expertise, including, but not limited to, (1) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of such training; t
(e) The history of membership of the person in any professional or trade association in the area in the claimed expertise, including, but not limited l to, (1) the name of each professional or trade association, (ii) the dates of membership, and l
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- .s 4' (iii) a description of each office held in each association; (f) A list of publications of any kind by the person in the area of claimed expertise, including, but not limited to, (i) the title and subject matter, (ii) the name and address of the publisher, and (iii) the date of publication; ,
(g) A list of any and all licenses in the area of claimed expertise, including, but~not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met; 4
(h) The amount of time the person has worked in the field of claimed expertise, stating periods where work vas other than on a full-time basis; (1) The name and address of every person, or every corporation or other institution, that has employed l the person within the last ten years of employment; (j) All periods of claimed self-employment, including a description of all duties and responsibilities thereof; l
O' (k) All previous experience in the field of claimed expertise which involved problems, analyses or studies similar to those concerning which the person is expected to testify in this proceeding;.
(1) All other litigation in which the person has been
- consulted, specifying those matters in which the person has testified, including the name of the case or matter and the court or other forum in which testimony was given; and (m) Any other experience in the field of claimed expertise.
" Identify" with respect to a document, means to state its date, its author, the type of document, its title (if any) and its present location.
All sections of the Results Reports cited herein should be read in the context that they appear within the Results Reports so that these interrogatories can be answered adequately.
I-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If the answer to this Interrogatory is an unqualified negative, you may proceed to II-1).
No testing deviation or deficiency was identified and no generic condition exists which indicates that there are inadequate controls with regard to review of deferred i preoperational testing for adherence to the requirements
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j of the TecNnical Specifications. Accordingly, no root cause determination is required. (Results Report ISAP III.a.3, page 4).
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I-2. Please state"each and every respect in which CASE disagrees with the above statement.
J (a) On what specific facts does CASE base its ,
disagreement? ,
I (b) Identify the documents upon which CASE,711L rely to sustain its position of disagreementi or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion of the above statement? If so, please:
(i) identify each expert witness whom Intervenor intends to present with respect to this conclusion; (ii) state the substance of the facte to which each expert witness is expected to testify:.
(iii) state the substance of the opinion or opinions to which each expert witness is expected to testify; (iv) provide a summary of the grounds for each j opinion to which each expert witness is expected to testify; i -s-i
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, g (d) Does the Intervenor disagree with the above
. . statement due to the methodology through which the stateNent'sconc'fasionswerereached? If so, i ~l please state the reasons why the methodology was
, flawed.
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Does the Intervenor disagree with the above
" statement due to the implementation of the action J
plan.through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
3 I-3. Prior to answering'this set of Interrogatories, has t e Intervenor reviewed the Working File for the Results yt Report in question?
I-4. Has the Intervenor propounded any Interrogatories
.4, regarding the Results Report in question in order to obtain 3
- / any information it believes to be necessary so as to make r
its review of the Working File complete?
II-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If the answer to this Interrogatory is an unqualified negative, you may proceed to III-1.)
Station procedures provide for evaluation of deferred preoperational testing and includes, among other things, consideration of the requirements of the Technical Specifications. (Results Report, ISAP III.a.3, page 4).
II-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) on what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any i
portion thereof.
_I (c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) - -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which the statement's conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.
III-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the statement
. below? (If your answer is an unqualified no you may proceed to IV-1.)
The reinspection performed under this action plan [ISAP V.a] provided reasonable assurance that the type-2 skewed welds on Brown & Root pipe supports are within the ASME allowable stress limits. (Results Report, ISAP V.a, page 26).
III-2. Please state each and every respect in which CASE disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement with the statement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion of the above statement? If so, please answer all Interrogatories I-2(c)(i) - I-2(c)(iv) with regard to their proposed testimony.
I (d) Does the;Intervenor disagree with the above statement due to the methodology through which the l statement's conclusions were reached? If so, state l
! the precise manner in which the methodology was flawed.
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l (e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
III-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the~ Working File for the Results Report in question?
III-4. Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
IV-1. Does the Intervenor intend to litigate the conclusions expressed in the following statement? (If the answer to this Interrogatory is an unqualified negative, you may proceed to V-1).
Although twelve (12) supports were found to contain undersize welds, none of these welds exceeded ASME stress limits. An evaluation of margin based on the l
measured weld size indicates that it is not likely that
- any of the type-2 skewed welds in the plant exceed ASME limits. (Results Report, ISAP V.a, page 26).
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! IV-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreeme'nt?
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e (b) Identify the documents Intervenor will rely upon to .
sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the validity of the conclusion reached in the above statement?
. If so, please answer all Interrogatories I-2(c)(i) - I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise
! manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
V-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer is ar; unqualified negative, you may proceed to VI-1).
[T] rends observed in the results of the reinspections performed under this action plan [ISAP V.a] support the position that the inspection criteria and techniques in
- the piping inspection procedure were used for the inspection of type-2 skewed welds on pipe supports.
(Results Report, ISAP V.a, page 26).
V-2. Please state each and every respect in which the 1 Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the above statement? If so, please answer all Interrogatories I-2(c)(1) - I-2(c)(iv) with respect to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to'the methodology through which its conclusions were reached? If so, state the precise manner.in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
i VI-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the statement below? (If your answer to this Interrogatory is an unqualified negative, you may proceed to VII-1.)
[T]he interface between the piping / support design activity and the damage study activity was adequately defined by procedures and functioned properly in the subject case. (Results Report, ISAP V.c, page 10).
VI-2. Please state each and every respect in which the Intervenor disagrees with the above statement. ;
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology flawed.
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I (e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
VII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to VIII-1.)
In lieu of an anchor, it is acceptable to have a two-way restraint design in combination with the other restraints, provided the seismic analysis appropriately deals with the actual support conditions and supports are designed for expected loadings, (i.e., overlap analysis). (Results Report, ISAP V.c, page 8).
VII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor bace its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Interven6r disagree with the above statement due to the methodology through which its conclusions were reached? If so, please state the manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the manner in which the implementation was flawed.
VIII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to IX-1.)
Main steam and feedwater piping stress analysis, incorporating bounding parameters, provide an adequate basis for concluding that there were no deleterious effects resulting from the sequence of events
[ associated with the main steam line lifts]. Reviews of l
existing records of UT [ Ultrasonic] examinations and hydrotests, along with acceptable results of NDEs
[non-destructive examinations] conducted for this review
[Results Report, ISAP V.e], provide additional support for this conclusion. (Results Report, ISAP V.e, page 46).
VIII-2. Please state each and every respect in which the L
Intervenor disagrees with the above statement.
l l (a) On what specific facts does the Intervenor base its l
disagreement?
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(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion mached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
VIII-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results l
report in question?
VIII-4. Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain
- any information it believes to be necessary so a.3 to make its review of the Working File complete?
IX-1. Does the Intervenor intend to litigate the validity of the conclusions expresscd in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to X-1.)
[S]ettlement of temporary supports, prior to filling
[the main steam line] with water for flushing, may have contributed to the off-location event; however, this did not adversely affect the hardware. (Results Report, ISAP V.e, page 46).
IX-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its
. conclusions were reached? If so, state the precise manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above f
i statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
X-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XI-1.)
[N]o damage occurred to the equipment identified in the NCR [ relating to possibly inadequate temporary supports of pipe to that equipment] nor was [ damage] likely to have occurred for other equipment under similar circumstance,s. (Results Report, ISAP V.e, Page 47).
X-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
J (c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, L.,-,,. . . -
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please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the actual implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
XI-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XII-1.)
[T]he procedural requirements related to fabrication and use of temporary supports are adequate. (Results Report, ISAP V.e, page 47).
XI-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
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~(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the precise manner in which the implementation was flawed.
XII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XIII-1.)
[M]aximum pipe stresses prior to the lift were well within allowable limits. (Results Report, ISAP V.e, page 16).
XII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
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(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the manner in which such methodology is flawed.-
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the manner in which the implementation was flawed.
XIII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XIV-1.)
[T]he section of piping above the cut [made during the disconnect phase prior to the lift) was quite flexible and that the internal pipe forces released when the pipe was cut may well have been sufficient to initiate a low frequency vibratory motion. While these vibratory displacements may have been startling to an observer,
. . . the stress levels in the permanent pipe were well within allowable limits. (Results Report, ISAP V.e, page 17).
XIII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any
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portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which the statement's conclusions were reached? If so, state the manner in which such methodology is flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action
. plcn through which tha statement's conclusions were reached? If so, state the manner in which the implementation is flawed.
XIV-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is unqualified agreement with the statement,3you may proceed to XV-1.)
[T]he maximum pipe stress levels were well within the allowable limits. Additionally, the stress levels during the lifting phase were generally less than during i the pre-lift phar.e. (Results Report, ISAP V.e, page l 20).
XIV-2. Please state each and every respect in which the l Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, the precise manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the actual implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.
XV-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XVI-2.)
Because of the low stress value for the feedwater piping and because the feedwater piping was not involved in the
, lift, it was concluded that the analysis for flushing l provided assurance of the adequacy of the-feedwater piping for the events surrounding.the main steam line lift. (Results Report, ISAP V.e, page 22).
XV-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
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l (c) Does the Intervenor intend to offer the testimony l l
of any expert witness with respect to the conclusion reached in the above statement? If so, 1
please answer all Interrogatories I-2(c)(i) - l I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.
XVI-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the fo'llowing statement? (If your answer is unqualified agreement with the statement, you may proceed to XVII-1.)
[L]oop 4 stresses during [the disconnecting and flushing] phases would . . . be bounded by the pre-lift and lift phase stresses, which are not detrimental.
(Results Report, ISAP V.e, page 23).
XVI-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
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'(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
1 (e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.
l XVII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an i
unqualified negative, you may proceed to XVIII-1.)
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In all cases, maximum stress levels were determined to be well within the allowable ASME limits. (Results Report, ISAP V.e, page 23).
XVII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) Cn what specific facts does the Intervenor base its disagreement? ,
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any export witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state why the implementation was flawed.
-XVIII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following ,
statement? (If your answer to this Interrogatory is at:
unqualified negative, you may proceed to XIX-1.)
The review of the fabrication inspection records indicated that all welds were acceptable prior to repositioning. The review of the Westinghouse PSI records confirmed that the welds inspected after the repositioning were also found to be acceptable.
(Results Report ISAP V.e, page 25).
XVIII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) on what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor-intend to offer the testimony l of any expert witness with respect to the ,
! conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
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I-2(c)(iv) with regard to their proposed testimony.
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(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due'to the implementation of the action-plan through which,the statement's conclusions were reached? If'so, state the reasons why the implementation was flawed.
XIX-1. Does the Intervenor intend to litigate the validity of the conclusions cxpressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XX-1.)
Based on the' review of information contained within.the hydrotest package, as well as the procedures that controlled the hydrotest, the package appeared to be complete and in accordance with the appropriate procedures, and the results of the hydrotest were satisfactory. No indications were found that suggested any lack of quality of the main steam and feedwater lines. (Results Report, V.e, page 26).
f XIX-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to 9
sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony I- of any expert witness with respect to the conclusion reached in the above statement? If so,
i please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology is flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation is flawed.
12-1. Does the Intervenor intend to litigate the
! validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an
, unqualified negative, you may proceed to XXI-1.)
i The fact that an NCR was not issued [with regard to the main steam line being off-location] is not considered to be a deviation from QA program commitments for the i following reasons:
- The off-location condition was detected and corrected by engineering in a controlled manner consistent with applicable procedures.
- The magnitude of the lift force and displacements
, were such that an engineer could reasonably l conclude that the quality of the piping and the containment penetration would not be compromised.
- The evaluations performed as part of this action plan confirmed that there were no adverse impacts due to the off-location or repositioning.
(Results Report, ISAP V.e, page 29).
l I
1 -
XX-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any i
portion thereof.
1 (c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reason why the implementation was flawed.
XXI-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following L
- statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXII-1.)
The direct causes for the procedural weaknesses identified [in this Results Report] potentially can be attributed to one or more of the following three factors. The first-is that the FSAR requirements, including the referenced codes and standards, were unclear. The second potential factor is that there were inadequate requirements for procedure preparation. The last potential factor is personnel failure. (Results Report, ISAP I.d.2, page 21).
XXI-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
l (d) Does the Intervenor disagree with the above 1
statement due to the methodology through which its conclusions were reached? If so, state-the reasons why the methodology was flawed.
i i
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.
(f) What other factors does the Intervenor contend may be direct causes of the procedural weaknesses identified?
XXI-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
XXI-4. Has-the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
XXII-1. Does the Intervenor intend to litigate the l validity of the conclusions expressed in the following l
l statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXIII-1.)
l [L]ack of experience of involved individuals likely l contributed to the preparation of inadequate procedure L revisions. (Results Report, ISAP I.d.2, page 24).
XXII-2. Please state each and every respect in which the l
l Intervenor disagrees with the above statement.
l l
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
, I-2(c)(iv) with regard to their proposed testimony.
/
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the precise manner in which the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the the precise manner in which the implementation was flawed.
l XXIII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXIV-1.)
i l
[T]he likely root cause of the deficiency (relating to administration of QC inspector tests] is inexperience on the part.of the personnel who had the responsibility for the revision and approval of the deficient procedures.
(Results Report, ISAP I.d 2, page 25).
XXIII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any i portion thereof.
(c) Does the Intervenor intend to offer the testimony 4
of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
4 I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If.so, state the reasons why-the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were l
reached? If'so, state the reasons why the j implementation was flawed.
XXIV-1. Does the Intervenor intend to litigate the validity cf the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXV-1.)
The NRC TRT concerns related to the TUGCO certification procedures contained in'SSER's 7 and 11 have been satisfactorily addressed as documented in Attachment A
[to Results Report, ISAP I.d.2]. (Results Report, ISAP I.d.2, page 28).
XXIV-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
. (a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its i
~
conclusions were reached? If'so, state the' reasons i
fwhy the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through-which the statement's conclusions were-L reached? If so, state the reasons why the implementation was flawed. ,
(f) Which TRT NCR concerns listed in Attachment A is not adequately addressed by the corrective actions taken by TUGCO?
(g) How are the TUGCO corrective actions discussed in
-your answer to the above interrogatory inadequate to address the TRT concerns?
XXV-1. Does the Intervenor intend to litigate the validity of the conclusions expressed 3- the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXVI-1.)
Based on the review of the Exit Interview Program in effect between December 1983 and May 1985, it is concluded that the program (which included the QA/QO Questionnaire and QAI programs) met the intent of item seven (7) of TUGCO's response to the NRC NOV in that it afforded QA/QC employees the opportunity to state concerns regarding quality prior to dissociation from the QA/QC department and provided a mechanism for evaluating and dispositioning such concerns. (Results Report, ISAP VII.a.6, page 36).
XXV-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
I . - - -
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend _to offer the testimony of any expert witness with respect to the
-conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached' If so, state the reasons why the implementation was flawed.
XXV-3. Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
XXV-4. Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain L
.: any information it believes to be necessary so-as to make its review of the Working File complete?
XXVI-1. Does the Intervenor intend.to litigate the validity of the conclusions expressed in the following statement?__ _(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXVII-1.)
The SAFETEAM Program and its implementation represents a significant improvement over the previous exit interview program. The program as structured, defined and implemented effectively, encourages employees to voice concerns and provides adequate means to do so.
Resolution of the employee's specific concern as stated appears satisfactory; however, related issues, some of which may have had quality implications, which arose v during the investigation were not in all cases addressed. ifith the recognition of these implications now a directed responsibility of the QA member of-the Steering Committee, effective response to all QA ramifications of employees' concerns can be achieved.
(Results Report, ISAP VII.a.6, page 36).
XXVI-2. Pleaae state each and every respect in which the Intervenor disagrees with the above statement.
I (a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to j sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony l
of any expert witness with respect to the conclusion reached in the above statement? If so, t
_ - ~ . _ - - . _ _ . - . . _ . . _ . _ _ _ _ - . _ . _ . _ - - _ . - _ _ _ _ . _ _ _ . . _ . . _ _ . . _ - - . . _ - _ _ . - - _ . _ _ . . , _
please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
-(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was-flawed.
XXVII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following atstement? (If your answer to this Interrogatory is an
. unqualified negative, you may proceed to XXVIII-1.)
No deficiencies were identified [or exist]. Therefore, no root cause evaluation and generic implications analyses were conducted [or required]. (Results Report, ISAP VII.a.6, page 36).
XXVII-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On-what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to 4 sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were' reached? If so, state the reasons why the. methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.
XXVIII-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement? (If your answer to this Interrogatory is an unqualified negative, you may proceed to XXIX-1.)
Despite the documentation problems [ discussed in Results Report, ISAP VII.a.8], there is a substantial amount of information available to indicate that it is likely that the fuel pool liner system was generally fabricated and installed utilizing qualified weld procedures and welders and that appropriate inspections and tests were actually conducted. (Results Report, VII.a.8, page 23).
(
1 1
l XXVIII-2. Please state each and every respect in which'the Intervenor disagrees with the above statement.
(a) on what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so,
.please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology is flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state the reasons why the implementation was flawed.
XXVIII-3. Prior to answering this set of Interrcgatories, has the Intervenor reviewed the Working File for the results report in question?
f[ , '
l' XXVIII-4. Has the Intervenor propounded _any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
XXIX-1. Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
Although the procedures and forms relating to work, inspection and documentation requirements contained some weaknesses, most of the problems identified more probably relate to lack of attention on the part of the QA/QC supervision responsible for the task of inspection and documentation thereof. (Results Report, ISAP VII.a.8, page 23).
XXIX-2. Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) On what specific facts does the Intervenor base its disagreement?
(b) Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c) Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement? If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
o .
( . .
(d) Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached? If so, state the reasons why the methodology was flawed.
(e) Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached? If so, state '..h'e reasons why the implementation was flawed.
t By their attorneys, Thomas G. Dignan, Jr.
R. K. Gad III William A. Eggeling Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: (617)423-6100 9
e
r actniu U3 W CERTIFICATE OF SERVICE
'87 RB 27 P2 :33 I, Kathryn A. Selleck, one of the attorneys for the Applicants herein, hereby certify that on February'24, 1987hh1Nmhde'serviceof MMW' the within document by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Adminictrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555 I
l
D l
l Renea Hicks, Esquire Ellen Ginsberg, Esquire
, Assistant Attorney General -Atomic Safety and Licensing Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Ecq.
Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111
/
/a Kathryn A. Selleck
__